Basic Information about Chemical Data Reporting
On this page:
- What is CDR?
- How does EPA use the CDR data?
- Who must report?
- Chemicals exempt from reporting
- Manufacturers exempt from reporting
- CDR data
The Chemical Data Reporting (CDR) rule, under the Toxic Substances Control Act (TSCA), requires manufacturers (including importers) to provide EPA with information on the production and use of chemicals in commerce.
Under the CDR rule, EPA collects basic exposure-related information including information on the types, quantities and uses of chemical substances produced domestically and imported into the United States. The CDR database constitutes the most comprehensive source of basic screening-level, exposure-related information on chemicals available to EPA, and is used by the Agency to protect the public from potential chemical risks.
The information is collected every four years from manufacturers (including importers) of certain chemicals in commerce generally when production volumes for the chemical are 25,000 lbs or greater for a specific reporting year. Collecting the information every four years assures that EPA and (for non-confidential data) the public have access to up-to-date information on chemicals.
The CDR rule is required by section 8(a) of the Toxic Substances Control Act (TSCA) and was formerly known as the Inventory Update Rule (IUR).
EPA uses CDR data to support risk screening, risk assessment, chemical prioritization, risk evaluation, and risk management activities, among other activities. This information allows EPA to develop an understanding of the types, amount, end uses, and possible exposure to chemicals in commerce.
The data include information on the manufacture (including import), industrial processing and use, and consumer and commercial use of certain chemicals currently listed on the TSCA Chemical Substance Inventory (TSCA Inventory), a list of chemicals that are manufactured (including imported) or processed in the United States. Currently, processing and use information helps EPA screen and prioritize chemicals for the purpose of identifying potential human health and environmental effects.
Manufacturers (including importers) are required to report if they meet certain production volume thresholds, generally 25,000 lbs or more of a chemical substance at any single site.
- Reporting is triggered if the annual reporting threshold at a manufacturing (including importing) site is met during any of the calendar years since the last principal reporting year. For the 2020 submission period, the need to report is based on the production volume for the calendar years 2016-2019.
- In general, the annual reporting threshold is 25,000 lbs per site. However, a reduced reporting threshold (2,500 lbs) applies to chemical substances subject to certain TSCA actions. Find out how to identify if your chemical substance is one of those affected.
- For chemical substances that trigger reporting, total annual production volume must be reported for each calendar year since the last principal reporting year. For the 2020 submission period, the total annual production volume is reported for the calendar years 2016-2019.
- The reporting threshold for processing and use information is the same as the reporting threshold for CDR generally (25,000 lbs or 2,500 lbs), depending on the existence of certain TSCA actions.
- Certain TSCA actions may have one or more of the following effects for specific chemical substances:
- Reduction in the threshold production volume that triggers reporting requirements
- Limitation on certain full or partial exemptions from reporting requirements
- Limitation on use of the small manufacturer exemption
- Find out how to identify if your chemical substance is one of those affected.
- Only one reporting threshold (either 25,000 lbs or 2,500 lbs) applies to a chemical substance for the 2020 CDR. The correct reporting threshold is determined based on the whether the chemical substance is the subject of the certain TSCA actions as of June 1, 2020.
Manufacturers (including importers) may not be required to report information on certain chemicals to CDR because of the type of chemical or because of the manner of manufacture (including import) or use of the chemical.
- Chemicals manufactured (including imported) for non-TSCA uses are not required to be reported (e.g., pesticides are exempt from reporting under CDR by TSCA). If a portion of a manufacturer’s (including importer’s) production is not subject to TSCA (for example, if the use is regulated by the Food and Drug Administration), then the production associated with the non-TSCA second use will not be reported to CDR. Note that manufacturers may report downstream non-TSCA uses for their chemical.
- Generally, water and naturally occurring substances are exempt from CDR requirements. Three other groups of chemicals (polymers, microorganisms, and certain forms of natural gas) are also generally exempt from CDR requirements. It is important to note that a particular polymer, microorganism, or form of natural gas may not be exempt if the chemical becomes the subject of certain TSCA actions, such as an enforceable consent agreement.
- Chemicals that are non-isolated intermediates, imported as part of an article, impurities, or byproducts destined for certain commercial uses are exempt from reporting.
EPA has finalized amendments to the definition of small manufacturer in accordance with TSCA section 8(a)(3)(C). Click here for more information.
- Total sales during 2019, combined with those of the parent company, domestic or foreign (if any), are less than $12 million; or
- Total sales during 2019 of the parent company, domestic or foreign (if any), are less than $120 million and annual production volume of a qualifying chemical substance does not exceed 100,000 lbs at any individual plant site. If the annual production volume of the chemical substance at any particular site is more than 100,000 lbs, the manufacturer is required to report for that particular site.
The CDR regulation requires all companies to report data electronically using e-CDRweb, the CDR web-based reporting tool, and EPA's Central Data Exchange (CDX) system. Those individuals involved with completing the CDR Form U using e-CDRweb can register in CDX at any time.
Businesses required to comply with the CDR regulation should have a thorough understanding of the TSCA Inventory and the criteria used to determine the listing of a substance on the TSCA Inventory.
User Roles: New Agent Role
For 2020 reporting, EPA has enabled the “Agent” user role, in addition to the current “Authorized Official” and “Support” user roles. The Agent role will be familiar to companies preparing other TSCA submissions such as those needed for the TSCA new chemicals program.
The Authorized Official and Support roles remain unchanged. Each role is defined as follows:
- Authorized Official: An Authorized Official has the ability to create, amend, unlock, and submit the Chemical Data Report (CDR) form electronically to EPA. The Authorized Official also has the ability to assign Supports (including Agents) to individual sites.
- Agent: An Agent has the ability to create, amend, and/or unlock the Chemical Data Report (CDR) form electronically to EPA. The Agent has the ability to submit only amended forms to EPA.
- Support: An Support has the ability to modify any unlocked form that he/she is assigned to by the Authorized Official.
Visit the Chemical Safety and Pesticide Programs (CSPP) CDX Registration Guide for more information on registration. If you have any technical issues or problems regarding CDX registration, please contact the CDX Help Desk at firstname.lastname@example.org or 888-890-1995. International callers who wish to contact the Help Desk should call 970-494-5500.