Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) Rule (formerly IUR)
On August 16, 2011 the U.S. Environmental Protection Agency (EPA) issued the final Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule (formerly the Inventory Update Reporting (IUR) rule). The CDR rule 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. With the final rule, the reporting frequency will increase from every 5 to every 4 years. The reporting deadline for the 2011 submission period is June 30, 2012.
Byproducts Reporting
The final CDR rule explicitly states that byproducts sent for recycling are new chemicals because they are a feedstock to the recycler and therefore subject to TSCA reporting. IPC submitted extensive comments expressing our dissatisfaction with EPA's interpretation that byproducts sent for recycling are new chemicals and the overly burdensome reporting requirements proposed.
Reporting requirements for byproducts are vague and confusing. EPA participated in a workshop to clarify reporting obligations for manufacturers that send byproducts for recycling. A summary of the workshop and important information regarding byproduct reporting obligations can be found in an IPC Outlook article.
Reporting Requirements
The reporting deadline for the 2011 submission period is June 30, 2012. Information on 2011 manufacturing, processing and use information must be reported on chemicals on the TSCA Inventory that are manufactured or imported above 25,000 pounds.
Electronic reporting is required. In order to report under the TSCA CDR rule you must register to Central Data Exchange (CDX). Learn more about how to register. If you are already registered with CDX, begin the reporting process for the CDR rule.
Reporting Requirements for the 2012 Submission Period Include:
- Reporting the manufacturing (or importing) volume of a chemical at a single site
- Reporting manufacturing data and processing and use data
- Identifying consumer and commercial categories associated with the reportable chemical
Reporting Requirements Beginning with the 2016 Submission Period:
In addition to the reporting requirements listed above, beginning in 2016, a manufacturer will be required to report the manufacturing (or import) volume of a chemical on the TSCA Inventory for each calendar year since the last principal reporting year. In this case, manufacturers will need to report the chemical’s volume for 2012, 2013, 2014, and 2015. If, during any calendar year, the volume of chemical manufactured (or imported) is 25,000 pounds or more, manufacturers (and importers) are required to report manufacturing and processing and use information on the chemical.
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