CDR is a collection of basic exposure-related information on the types, quantities, and uses of chemical substances manufactured domestically or imported into the United States.

• Chemical substances listed on the TSCA Inventory
• Chemical substances listed on the TSCA Inventory

Information is submitted every four years

• Most recently submitted in 2016, covering calendar years 2012 2015
• The current submission period is in 2020, covering calendar years 2016 and 2019

In 2016, about 5,660 sites reported approximately 8,700 chemicals, resulting in close to 42,500 chemical reports

EPA has finalized the CDR Revisions Rule (March 2020), which affects the 2020 CDR reporting requirements

EPA has published a final rule to extend the submission period from September 30 to November 30, to provide additional time to reporters to become familiar with these requirements

When: The submission period is June 1 to November 30, 2020

Who: Manufacturers, including importers, of chemical substances that:

• Are listed on the TSCA Inventory as of June 1, 2020
• Have a production volume of 25,000 lbs or greater at a site in at least one of the years 2016 2019 – unless subject to certain TSCA regulatory actions, in which case the production volume is 2,500 lbs or greater
• Are not eligible for a full or partial exemption from CDR

EPA revised Small Manufacturer Definition (not subject to CDR):*

• (1) First standard. A manufacturer (including importer) of a substance is small if its total annual sales, when combined with those of its parent company (if any), are less than $120 million. However, if the annual production or importation volume of a particular substance at any individual site owned or controlled by the manufacturer or importer is greater than 45,400 kilograms (100,000 lbs), the manufacturer (including the importer) will not qualify as small for purposes of reporting on the production or importation of that substance at that site, unless the manufacturer (including importer) qualifies as small under standard (2) of this definition.
• (2) Second standard. A manufacturer (including importer) of a substance is small if its total annual sales, when combined with those of its parent company (if any), are less than $12 million, regardless of the number of substances produced or imported by that manufacturer (including importer).

* does not apply if substances listed in TSCA sections 4,5,6, or 7

• May 19, 2020, EPA CDR Presentation
• Revised Small Manufacturer Definition
• Access the TSCA Inventory

There are two areas within the “New TSCA” that ink manufacturers should pay particular attention to.

• TSCA inventory reset rule: The goal of the reset rule is to subdivide the Inventory into separate lists of “active” and “inactive” substances. EPA will include these active and inactive designations on the TSCA Inventory as part of its regular publications of the Inventory.
• TSCA Import-Export requirements: The Toxic Substances Control Act (TSCA) places requirements on those importing chemicals into or exporting chemicals out of, the customs territory of the United States.