TSCA Chemical Data Reporting Required in 2020

The TSCA Chemical Data Reporting (CDR) requirements apply to facilities that manufacture domestically and import into the United States chemicals in excess of a reporting threshold of 25,000 pounds or 2,500 pounds, depending on the specific chemical. TSCA Section 8(a) requires facilities subject to the CDR rule to prepare a report every four years for electronic submittal to the U.S. EPA via Central Data Exchange (CDX). The U.S. EPA uses the data, which provides important screening-level exposure related information, to help assess the potential human health and environmental effects of these chemicals and makes the non-confidential business information it receives available to the public. The 4-year reporting cycle for the CDR rule is year 2016 through 2019. Therefore, for this reporting period, the facility is required to submit a CDR report by September 30, 2020 to the EPA. Data must be submitted for all four years of the reporting cycle.

Often overlooked, companies that import at least 25,000 pounds of scrap annually during 2016, 2017, 2018 or 2019 may be subject to the TSCA Chemical Data Reporting (CDR) in 2020. If a company process both domestic and imported scrap for materials recovery, only the imported material should be counted for purposes of determining whether reporting is necessary.

For each substance manufactured or imported in excess of 25,000 pounds per year, the regulated entity needs to fill out an EPA Form U. In order to complete the EPA Form U’s as part of the TSCA CDR rule, the facility needs to open an EPA Central Data Exchange (CDX) account, located at www.epa.cdx.gov. The CDX registration process requests some basic information, in the following order:

  • Program service (e.g., TRIMEweb, eDisclosure, NetDMR, Chemical Safety and Pesticides Programs (CSPP, etc.)

  • Program service role (Primary Authorized Official; Primary Support, etc.)

  • User information

  • Organization information

When registering the first organization, for the first time, this organization will become the primary organization. The user’s primary organization is imp