September 30, 2016 is the deadline for filing under the Chemical Data Reporting (CDR) rule, a provision of the Toxic Substances Control Act (TSCA). Sometimes referred to as Form U reporting, the CDR is filed every four years by facilities that manufacture or import chemicals above certain thresholds. A lot has happened since the last reporting period in 2012, and there are some notable changes in reporting requirements for this year’s CDR submittal. For instance:

The manufacture / import and use threshold remains at 25,000 pounds per year per site; however, lower thresholds (2,500 pounds) apply to approximately 1,900 chemicals which are the subject of certain TSCA actions.

Facilities need to evaluate production / import data for the four year period from 2012 – 2015, and file a report containing data for each year if an applicable threshold was exceeded in any year.

Expanded manufacturing, processing, and usage data will be required for 2015 data.

All submittals must be made electronically through EPA’s Central Data Exchange (CDX) platform.

If you haven’t already done so, your first task is to gather data on chemical production from 2012-2015 (don’t forget to include imports!) and evaluate if you are subject to reporting. In addition to the lower thresholds, there are full and partial exemption provisions for certain chemicals and facilities.

Greystone has been tracking the CDR requirements and can assist your company in assessing your applicability, confirming reporting requirements, registering in CDX and completing the reports, as needed. Call Rob Walters at 973-420-7832 or Peter Baty at 925-482-7851 for more information.