TSCA CDR Reporting Period Starts June 1

Posted on 5/4/2020 by Anthony Cardno, CHMM

What happens every four years and is coming up again in November 2020?

Hint: It’s not the US Presidential election…  

If you guessed Chemical Data Reporting (CDR) or “Form U” reporting required under the Toxic Substances Control Act (TSCA)—you’re right!

On April 9, 2020, EPA extended the CDR reporting date to November 30, giving chemical manufacturers two additional months to get their reports in. Normally, these reports are due by September 30.  

The window to submit CDR reports opens on June 1, 2020.

Who Must Submit the TSCA CDR?

Any site that manufactured (or imported) for commercial purposes 25,000 lbs. or more of any chemical substance on the TSCA Inventory during any single year since the previous reporting year is subject to the upcoming reporting requirement.

The CDR reporting trigger is:
  • site-specific (companies with several sites manufacturing or importing the same chemical do not add individual sites together)
  • chemical-specific (sites that manufacture more than one chemical do not add different chemicals together)
  • year-specific (sites that manufactured the chemical in any of the reporting years do not add the four years together)
There is a lower trigger of 2,500 lbs. or more for any person who manufactures (or imports) for commercial purposes any chemical substance that is subject to a Significant New Use Rule (SNUR), a chemical management standard promulgated under TSCA §6, or a civil action for seizure or relief under TSCA §7.

Import = Manufacture

As is standard under TSCA, “importing” is considered to be “manufacturing” for the purposes of the CDR. If you are the importer of record bringing the substance into the Customs Territory of the United States, in the EPA’s eyes you are the manufacturer of that chemical. The Customs Territory is defined as the 50 states, the District of Columbia, and Puerto Rico.

Exclusions to TSCA Form U or CDR Reporting

There are numerous exclusions from CDR requirements, including:
  • anything specifically excluded from being a chemical substance under TSCA by the statutory definition (which includes pesticides, nuclear material, tobacco products, food, drugs, and cosmetics registered under other regulatory programs)
  • small quantities manufactured for research and development
  • substances imported as part of an article
  • byproducts with no commercial chemical purpose
  • substances resulting from various chemical reactions
  • non-isolated intermediates
  • certain polymers
  • microorganisms
  • naturally occurring chemical substances
In addition, certain petroleum process streams and inorganic chemical substances are partially excluded from CDR requirements. Small manufacturers are also excluded from the CDR unless subject to certain TSCA rules (mentioned above).

Persons subject to the CDR must submit “Form U” electronically via the e-CDRweb reporting tool in conjunction with EPA’s Central Data Exchange (CDX). The required contents of the “Form U” include:
  • total volume manufactured/imported at the site
  • site-limited status of chemical substances
  • worker exposure information
  • maximum concentration and physical form(s) for each chemical substance
For certain years, only manufacturing/importing totals are required rather than detailed calculations.

TSCA Regulations Online Course

The Toxic Substances Control Act (TSCA) is undergoing major changes. Be confident you know how the Lautenberg Law impacts your responsibilities for chemical management, inventory reporting, and recordkeeping.

The TSCA Regulations Online Course is updated to cover throughout the year to cover new requirements that professionals in the chemical manufacturing, import/export, storage, and processing fields must know.

Tags: CDR, chemicals, form U, reporting and recordkeeping, TSCA

Find a Post

Compliance Archives

Lion - Quotes

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!

Henry Watkins

Hazardous Waste Technician

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

Download Our Latest Whitepaper

What to do before, during, and after a RCRA hazardous waste inspection to defend your site from rising State and Federal penalties.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.