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Chemical Data Reporting

How To Report Under Chemical Data Reporting

This page contains instructions and guidance on submitting information to EPA for the 2016 Chemical Data Reporting (CDR) period.

Overview

The next CDR submission period begins June 1, 2020. Please be advised that manufacturers (including importers) need to report production volume information for calendar years 2016, 2017, 2018, and 2019. While submitters will not report to EPA until 2020, they should start keeping track of their production volumes for these four years. For the 2020 CDR, the principal reporting year is calendar year 2019. Full manufacturing, processing, and use information will be required only for 2019.

The submission period for the 2016 CDR ended on October 31, 2016. Manufacturers (including importers) subject to CDR reporting requirements for 2016 who have not yet reported must do so immediately. Get reporting help by contacting EPA’s CDR help desk at eCDRweb@epa.gov.

2016 Overview

The Agency has developed guidance documents to better explain the requirements and is encouraging you to submit questions and comments on the 2016 reporting cycle to the CDR inbox available at eCDRweb@epa.gov.

Please be advised that manufacturers (including importers) need to report production volume information for calendar years 2012, 2013, 2014, and 2015. While submitters will not report to EPA until 2016, they should start keeping track of their production volumes for these four years. For the 2016 CDR, the principal reporting year is calendar year 2015. Full manufacturing, processing, and use information will be required only for 2015.

Who must report?

Manufacturers (including importers) are required to report if they meet certain production volume thresholds, generally 25,000 lbs or more of a chemical substance at any single site.

Find out how to identify if your chemical substance is one of those affected. 

  • Reporting is now triggered if the annual reporting threshold is met during any of the calendar years since the last principal reporting year (2012 – 2015).
    • In general, the reporting threshold remains 25,000 lb per site.  However, a reduced reporting threshold (2,500 lb) now applies to chemical substances subject to certain TSCA actions. See chart below.
    • For chemical substances that trigger reporting, total annual production volume must now be reported for each calendar year since the last principal reporting year (2012 – 2015).
    • There is no longer a different reporting threshold for processing and use information. That provision expired after the 2012 CDR. The reporting threshold for processing and use information is the same as the reporting threshold for CDR generally (25,000 lb or 2,500 lb), depending on existence of certain TSCA actions.
  • Certain TSCA actions may have one or more of the following effects for specific chemical substances:
    • Reduction in the threshold production volume that triggers reporting requirements
    • Limitation on certain full or partial exemptions from reporting requirements
    • Limitation on use of the small manufacturer exemption
  • Only one reporting threshold (either 25,000 lbs or 2,500 lbs) applies to a chemical substance for the 2016 CDR.  The correct reporting threshold is determined based on the chemical substance’s status as of June 1, 2016. See chart below.
Quick guide on who must report to CDR
If your chemical is subject
to one or more of these
TSCA actions as of June 1, 2016:
Your obligation to report CDR information is:
Subject to 25,000 lb reporting threshold Subject to 2,500 lb reporting threshold Not eligible for certain full or partial exemptions from reporting Not eligible for small manufacturer exemption
Not subject to TSCA action X      
TSCA section 4 rules (proposed or promulgated) X   X X
Enforceable Consent Agreements (ECAs) X   X  
TSCA section 5(a)(2) SNURs
(proposed or promulgated)
  X X  
TSCA section 5(b)(4) rules
(proposed or promulgated)
  X X X

TSCA section 5(e) orders

  X X X

TSCA section 5(f) orders

  X X  

TSCA section 5 civil actions

  X X X

TSCA section 6 rules
(proposed or promulgated)

  X X X

TSCA section 7
civil actions

  X X X

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2016 Reporting

Reporting electronically: registration in the Central Data Exchange (CDX)

To submit Form U electronically to EPA, you must register with CDX and be approved by EPA. If you have technical issues or problems regarding CDX registration, please contact the CDX Help Desk at helpdesk@epacdx.net or 888-890-1995. International callers who wish to contact the Help Desk should call 970-494-5500.

  • Register on CDX: To register for CDR reporting, go to the CDX website and register under the program "Submissions for Chemical Safety and Pesticide Programs (CSPP)." If you were previously registered on CDX for e-TSCA, e-PMN, or TRI, you are able to add the CDR reporting flow to your current registration.
  • Access e-CDRweb: The Agency-provided electronic reporting tool used to complete Form U is now available. Once you have registered in CDX, you will be able to access e-CDRweb.
  • Complete and submit your completed Form U. View a sample submission Form U (note: e-reporting is required)

Using e-CDRweb: user guides & schemas

Instructions and Guidance

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Webinars & Training

2017 Webinars

Webinar to Obtain Feedback on Improving Chemical Data Reporting (CDR), May 1, 2017

On Monday, May 1, 2017 from 1:00 – 3:00 p.m. Eastern Standard Time, EPA hosted a webinar to obtain feedback on the 2016 Chemical Data Reporting (CDR) process and requirements. EPA plans to use this feedback to improve CDR for the 2020 submission period.

View the “Webinar to Obtain Feedback on Chemical Data Reporting” presentation.

You can provide written feedback pertaining to the 2016 CDR reporting period by submitting it to ecdrweb@epa.gov.  Please use “CDR suggestion” in the subject line.

EPA is seeking feedback on all aspects of CDR, including:

  • Use of the CDR electronic reporting tool, including accessing the tool and uploading information via the Agency’s Chemical Data Exchange (CDX).
  • Special reporting situations, such as joint submissions and toll manufacturers.
  • Help for reporting, including guidance documents, fact sheets, webinars, and other technical assistance.
  • Ways to reduce the reporting burden while still obtaining useful information.

2016 training and workshops

EPA is providing several webinar outreach sessions to walk submitters through the Chemical Data Reporting (CDR) reporting requirements and using the 2016 CDR reporting tool, e-CDR web, to complete the electronic CDR Form U.

CDR Reporting Requirements and eCDRweb Reporting Tool Webinar, June 1, 2016

EPA held a webinar to familiarize submitters with Chemical Data Reporting (CDR) requirements and how to use the 2016 eCDRweb reporting tool. During this webinar, EPA reviewed uploading the XML schema and searching the Substance Registry Services (SRS).

CDR Reporting Requirements and eCDRweb Reporting Tool Webinar, May 4, 2016

EPA held a webinar to familiarize submitters with Chemical Data Reporting (CDR) requirements and how to use the 2016 eCDRweb reporting tool.

CDR Reporting Requirements and eCDRweb Reporting Tool Webinar, April 6, 2016

EPA held a webinar to familiarize submitters with Chemical Data Reporting (CDR) requirements and how to use the 2016 eCDRweb reporting tool.

2016 CDR reporting requirements webinar, February 4, 2016

EPA held a CDR Reporting Requirements webinar to familiarize industry with the 2016 reporting requirements of the Chemical Data Reporting (CDR) rule. 

Overview of the 2016 CDR reporting application webinar, October 14, 2015.

EPA held a webinar to provide industry with an overview of the 2016 reporting application for the Chemical Data Reporting (CDR) rule. 


2012 CDR resources

View 2012 CDR guidance documents, training software, reporting forms and other resources.

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Partial exemption petitions

Overview

EPA maintains a list of partially exempt chemicals for which the CDR processing and use information is of "low current interest" at 40 CFR 711.6(b)(2)(iv). Manufacturers of these listed chemicals are exempt from reporting the processing and use information required by 40 CFR 711.15(b)(4). Chemical substances are included on this list only if EPA has determined that there is low current interest in the processing and use information for that substance.

EPA may amend the list of partially exempt chemicals on its own initiative or in response to a request from the public. The public may submit a petition to request that a chemical be added to or removed from the partial exemption. Note: The partial exemption listing is chemical-specific, not site- or use-specific. Therefore, when a chemical is listed under the partial exemption in 40 CFR 711.6(b)(2), all manufacturers (including importers) are exempt from reporting the processing and use information required under 40 CFR 711.15(b)(4) for the listed chemical substance.

View the list of chemicals for which processing and use reporting is not required.

Who can submit a petition?

A petition may be submitted by any person, regardless of whether the person manufacturers, imports, or uses the chemical, or is otherwise interested in the chemical. When evaluating the petition, EPA will consider the production volume and use information for all manufacturing or importing sites and all uses. This information is not restricted to the submitting site.

Considerations used by EPA when deciding whether to grant the petition are listed at 40 CFR 711.6(b)(2).

How do I submit a petition?

Your petition to amend the partial exemption chemical list must be submitted in writing and must contain the identity of the chemical in question, as well as its Chemical Abstract Service (CAS) Registry Number. If a CAS Registry Number is not known to or reasonably ascertainable by you (the petitioner), an EPA-designated Accession Number for confidential substances or a premanufacture notice (PMN) case number can be submitted in lieu of a CAS Registry Number. There are regulatory deadlines for submission of petitions as specified in 40 CFR 711.6(b)(2)(iii)(C). The deadlines for submitting partial exemption petitions for the 2016 CDR reporting period have passed.

Your petition must also contain a written rationale for the request that provides sufficient specific information addressing the considerations listed below and in 40 CFR 711.6(b)(2)(ii), including citations and relevant documents, to demonstrate to EPA that the collection of the information in 40 CFR 711.15(b)(4) for the chemical in question either is or is not of low current interest. If a request related to a particular chemical is resubmitted, any subsequent request must clearly identify new information contained in the request. EPA may request other information that it believes necessary to evaluate the request. EPA will issue a written response to each request within 120 days of receipt of the request. This response will provide a status report for the petition review.

Submit your petition to the address listed below:

By delivery service:
OPPT CDR Submission Coordinator
Attn: Inventory Update Reporting and Chemical Data Reporting
U.S. Environmental Protection Agency
Office of Chemical Safety and Pollution Prevention
EPA East Bldg., Room 6428
1201 Constitution Avenue, N.W.
Washington, DC, 20004
Phone: 202-564-8958

By mail:
OPPT CDR Submission Coordinator
Mailcode 7407M
Attn: Inventory Update Reporting and Chemical Data Reporting
Office of Chemical Safety and Pollution Prevention
Environmental Protection Agency
1200 Pennsylvania Ave., NW.
Washington, DC 20460

Petition results

What happens to my petition once I submit it?

EPA has established a review process for the petitions. There are several steps in this review process and at any place in this process EPA may contact the petitioner for clarification or additional information. The petitioner may also submit additional information to its petition at any time before EPA issues a final decision. No later than 120 days after receipt of the petition, EPA must issue a response to the petitioner. The response need not have EPA's final decision. However, if EPA does make a final decision before the 120 days has passed, EPA may notify the petitioner immediately.

In making its determination of whether this partial exemption should apply to a particular chemical substance, EPA will consider the totality of information available for the chemical substance in question, including but not limited to, one or more of the following considerations:

  • Whether the chemical qualifies or has qualified in past IUR collections for the reporting of the information described in 40 CFR 711.15(b)(4).
  • The chemical substance's chemical and physical properties or potential for persistence, bioaccumulation, health effects, or environmental effects (considered independently or together).
  • The information needs of EPA, other federal agencies, tribes, states, and local governments, as well as members of the public.
  • The availability of other complementary risk screening information.
  • The availability of comparable processing and use information.
  • Whether the potential risks of the chemical substance are adequately managed.

Recent additions to partially exempt chemicals list

  • March 22, 2016 – EPA amended the list of chemical substances that are partially exempt from reporting additional information by adding six chemicals in response to a petition the Agency received. The chemicals are Fatty acids, C14-18 and C16-18 unsaturated, methyl esters (Chemical Abstract Services Registry Number (CASRN) 67762-26-9); fatty acids, C16-18 and C-18 unsaturated, methyl esters (CASRN 67762-38-3); fatty acids, canola oil, methyl esters (CASRN 129828-16-6); fatty acids, corn oil, methyl esters (CASRN 515152-40-6); fatty acids, tallow, methyl esters (CASRN 61788-61-2); and soybean oil, methyl esters (CASRN 67784-80-9). Read the Federal Register notice.
  • On November 10, 2014, EPA amended the list of chemical substances that are partially exempt from reporting additional information by adding six chemicals in response to a petition the Agency received. The chemicals are D-Fructose (CAS RN 57-48-7); 1,2,3-propanetricarboxylic acid, 2-hydroxy-, sodium salt (1:3) (CAS RN 68-04-2; 1,2,3-propanetricarboxylic acid, 2-hydroxy- (CAS RN 77-92-9); 1,2,3-propanetricarboxylic acid, 2-hydroxy-, potassium salt (1:3) (CAS RN 866-84-2); corn, steep liquor (CAS RN 66071-94-1); and soybean oil, epoxidized (CAS RN 8013-07-8). Read the Federal Register notice.
  • June 19, 2014 -- EPA amended the list of chemical substances that are partially exempt from reporting additional information by adding three chemicals in response to a petition the Agency received. The chemicals are 1,3-Propanediol (CAS RN 504-63-2); Palm Kernel Oils (CAS RN 8023-79-8); and Bentonite, (Acid Leached) (CAS RN 70131-50-9). Read the Federal Register notice.

Other petitions

  • The American Forest & Paper Association (AFPA) petitioned for a full exemption from CDR reporting for the following four pulping chemicals:
    • Sulfite Liquors and Cooking Liquors, white (CAS No. 68131-33-9) (white liquor)
    • Sulfite Liquors and Cooking Liquors, spent (CAS No. 66071-92-9) (black liquor)
    • Sulfite Liquors and Cooking Liquors, spent, oxidized (CAS No. 68514-09-0) (black liquor, oxidized)
    • Sulfite Liquors and Cooking Liquors, green (CAS No. 68131-30-6) (green liquor).

Read the petition.

Although EPA has procedures in place for partially exempting chemicals from certain reporting obligations under section 8(a), AFPA indicates that a “partial exemption would not result in relief for the pulp and paper industry.” Therefore, this petition was handled under the Administrative Procedures Act. Read EPA’s response to the petition. The petition and EPA’s response to the petition are available in docket number EPA-HQ-OPPT-2016-0383 available at www.regulations.gov.

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