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Chemical Data Reporting

Partial Exemption Petitions

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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 2020 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

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 the 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 have 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 Inventory Update Reporting (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 responses to petitions for changes to the partially exempt chemicals list

  • May 30, 2019 – The Aluminum Association petitioned to add aluminum (CASRN 7429-90-5) and aluminum oxide (Al2O3) (CASRN 1344-28-1) to the list of chemical substances that are partially exempt from reporting additional information. EPA denied the petitions after considering the totality of information available during the review of the petitions and identifying current interest in the CDR processing and use information for both aluminum and aluminum oxide. The Agency's reports further explain the review of these petitions. Read the Aluminum Association’s petitions, EPA’s petition review reports, and EPA’s response to the petitions, which are also included in docket number EPA-HQ-OPPT-2019-0224 at www.regulations.gov.
  • 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.
  • 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

  • July 13, 2016 - 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 in docket number EPA-HQ-OPPT-2016-0383 at www.regulations.gov.

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