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Chemical Data Reporting

2016 Chemical Data Reporting Frequent Questions

These Frequent Questions (FQs) are intended to clarify the reporting requirements for Chemical Data Reporting for the 2016 reporting period.

In EPA’s August 16, 2011, Chemical Data Reporting rule, the Agency changed the name of its chemical reporting regulation from the Inventory Update Reporting (IUR) Rule to the Chemical Data Reporting (CDR) Rule, which is codified at 40 CFR 711. However, throughout this document, EPA has retained the use of the term “IUR” to reflect historic terminology and has used the term "CDR" to describe the revised reporting requirements under the new rule. In other words, EPA is using “IUR” to refer to the 2006 and earlier submission periods; it’s using “CDR” to refer to the 2012 and later submission periods, to which the new rules apply.

These FQs should be used for information only and are not a substitute for the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule. You should carefully review the CDR regulations, located at 40 CFR Part 711, for specific information on how to comply with CDR requirements.

If you need more help, visit EPA's Chemical Data Reporting webpage, contact EPA's TSCA Hotline at tsca-hotline@epa.gov, call 202-554-1404, or send an email to eCDRweb@epa.gov.

Last updated: July 11, 2016.

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General CDR Questions

  1. Purpose of the CDR
  2. 2016 Submission Period
  3. Reporting Assistance and Training

Determining the Chemical Substances Subject to the CDR Rule

  1. General
  2. Manufactured Chemicals (Including Imported) for Commercial Purposes
  3. Toll Manufacturers
  4. Importers
  5. Chemical Substances on the TSCA Inventory - General
  6. Mixtures
  7. Byproducts
  8. Non-TSCA Uses
  9. Exemptions from Reporting

Determining If You Are a Manufacturer or Importer Required to Report

  1. Production Volume Thresholds
  2. Small Manufacturers
  3. Certain Regulated Chemical Substances
  4. Small Quantities for Research and Development
  5. Imported Articles
  6. Impurities
  7. Non-Isolated intermediates

Determining the Information You Must Report

  1. Processing and Use Reporting Threshold
  2. Full Reporting for Chemical Substances
  3. Partial Reporting Exemptions

Completing Form U

  1. General
  2. “Known to or Reasonably Ascertainable by” Reporting Standard
  3. Part I -- Company and Site Identification Information
    • Section A. Parent Company Information (Blocks 1.A.1-1.A.8)
    • Section B. Site Information (Blocks 1.B.1-1.B.8)
    • Section C. Technical Contact Information (Blocks 1.C.1.-1.C.10)
  4. Part II Section A. – Chemical Substance Identification (Blocks 2.A.1-2.A.4)
  5. Part II Section B. – Manufacturing Information
    • Physical Form (Blocks 2B.13-2B.19)
    • Other: Maximum Concentration, Recycling (Blocks 2.B.11-2.B.12)
    • Past Production Volume (Block 2.B.20)
  6. Part III – Processing and Use Information
    • Section A. Industrial Processing and Use Data (Blocks 3.A.1-3.A.10)
    • Section B. Consumer and Commercial Use Data (Blocks 3.B.1-3.B.10)
  7. Parts II and III — Estimating Number of Workers Reasonably Likely to be Exposed to a Chemical Substance (Block 2.B.10 and Sections 3.A. & 3.B.)
    • What to Consider When Estimating?
    • Estimating Workers in Part II and Part III
  8. Part IV — Joint Submissions (Sections 4.A.-4.D.)

Asserting Confidential Business Information (CBI) Claims and Certification Statements

  1. General
  2. Part I – Company and Site Information (Blocks 2.B.1-2.B.3)
  3. Part II – Chemical Substance and Manufacturing Information (Block 2.A.1 and Blocks 2.B.4-2.B.20)
  4. Part III – Processing and Use Information (Sections 3.A. and 3.B.)
  5. Part IV – Joint Submissions (Sections 4.A.-4.D.)

Other Issues

  1. Recordkeeping Requirements
  2. Penalties for Not Submitting a Report
  3. Additional Regulatory Information for CDR Chemical Substances