What Action Has EPA Taken for Chemical Data Reporting Rule (formerly Inventory Update Reporting)?
EPA has amended the reporting requirements of the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) rule and changed its name to the Chemical Data Reporting (CDR) rule. The CDR rule requires manufacturers and importers of chemical substances listed on the TSCA Inventory to report information about the manufacturing, importing, processing and use of the chemicals. The amendment will provide improved information for EPA to better identify and manage risks associated with the chemicals.


Why Did EPA Change the Name of the Rule?
EPA changed the name from Inventory Update Reporting (IUR) to Chemical Data Reporting (CDR) to reflect the distinction between the next data collection (which includes exposure-related data) and the TSCA Inventory itself (which only involves chemical identification information). Identifying the next data collection as Chemical Data Reporting (CDR) is intended to make it easier for the public to understand what information is available to them through the data collection.

Why Did EPA Modify the IUR Rule?
The IUR modifications were enacted to meet four primary goals:

    ▲Obtain new information relating to potential exposures for chemicals listed on the TSCA Inventory
    ▲Increase the frequency that the data are reported
    ▲Increase public access to the information
    ▲Improve the usefulness of information provided to EPA


Who is Required to Report?
You may be required to report if you manufacture (including manufacture as a byproduct) or import chemicals for commercial purposes listed on the TSCA Inventory and produced in volumes of 25,000 lbs or more during the 2011 calendar year. Potentially affected entities may include:

    ▲Chemical manufacturers and importers
    ▲Manufacturers of a byproduct chemical (i.e., utilities, paper manufacturing, semiconductor and other electronic component manufacturing)

When is Reporting Due?
The 2012 submission deadline was scheduled to occur on June 30, 2012. As of June 11, 2012, EPA has amended the TSCA CDR regulations to allow for a one-time extension of the CDR reporting deadline by six weeks to August 13, 2012. Manufacturing, processing and use data from 2011 and production volume information from 2010 will be reported, and is now due August 13, 2012.

What Are Some of the Changes for 2012?
Manufacturers and importers are required to:
    ▲Report if the production volume of a chemical exceeds the 25,000 lb threshold during the 2011 calendar year
    ▲Provide upfront substantiation for each processing and use data element claimed as confidential business information (CBI)
    ▲Use e-CDR web to submit all CDR information

Manufacturing information required to be reported:
   ▲Production volume for 2010 calendar year
    ▲For 2011 calendar year
        – Production volume of chemicals manufactured and imported at a reporting site
        – Whether an imported chemical is physically located at reporting site
        – Volume of chemicals exported and not domestically processed or used
        – Whether a manufactured chemical substance, such as a byproduct, is being recycled, remanufactured, reprocessed or reused

Processing and use-related information required to be reported:
    ▲For 2011 calendar year
        – Report processing and use information of all chemicals manufactured at 100,000 lbs or more, unless otherwise exempted
        – Use reporting standard “known to or reasonably ascertainable by,” instead of the “readily obtainable” standard used in 2006
        – Report industrial processing and use information using a revised list of industrial function categories and a list of 48 Industrial Sectors (IS)    
           which replace the five-digit North American Industrial Classification System (NAICS) codes
        – Report consumer and commercial product categories separately to distinguish between the use types
        – Report consumer and commercial use information using a revised list of consumer and commercial product category codes

How Can TSG Assist Me?
Are you currently collecting 2011 data for each manufacturing and import site in the United States for your 2012 CDR submission? If not, TSG can help gather this data in an organized, professional manner to assist you in meeting EPA’s 2012 CDR reporting requirements. Since EPA has finalized the CDR rules for 2012 reporting, TSG will help guide you through these changes and ensure you are prepared to report on time. In addition, TSG is ready to assist you in preparing CDR submissions using the newly required e-CDRweb, EPA’s forthcoming electronic reporting tool.

Please contact Will Pettit for more information on TSG’s 2012 CDR services.