Chemical Data Reporting Rule
The TSCA Chemical Data Reporting (CDR) rule, revised in 2011, requires manufacturers (including importers) of certain chemical substances listed on the TSCA Inventory of Chemical Substances to report information about the manufacturing (including import), processing, and use of those chemical substances.
The CDR rule explicitly states that byproducts sent for recycling are new chemicals subject to TSCA CDR reporting because they are a feedstock to the recycler and therefore subject to TSCA reporting. This applies to several byproducts produced during the manufacture of printed boards, including copper hydroxide (WWT sludge), copper sulfate (spent baths), cupric chloride (spent etchant), and tetraamine copper dichloride (spent ammoniacal etchant). PCB manufacturers and other electronics manufacturers are subject to CDR reporting requirements.
EPA recently published a fact sheet on reporting requirements for the printed circuit board industry. Members are advised to read the fact sheet carefully. Prior to publication of the fact sheet, IPC submitted informal comments to the US EPA and asked for a meeting to discuss how the fact sheet could be improved to provide clearer advice to the industry particularly as regards reporting of Chemical Substances of Unknown or Variable Composition, Complex Reaction Products and Biological Materials (UVCBs).
EPA declined to meet with IPC and proceeded to publish the fact sheet. IPC’s letter to EPA outlines our concerns regarding the fact sheet and the required reporting under TSCA of byproducts sent for recycling.
PCB manufacturers are advised to review our CDR guidance and additional EPA guidance on CDR reporting prior in addition to the new fact sheet.
For additional information on the CDR rule, contact Fern Abrams, director of regulatory affairs and government relations, at FernAbrams@ipc.org.