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Chemical Data Reporting

Completing Form U

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23. General

  • 23.1. Does a whole new Form U need to be completed for each chemical substance?

    No. Only one Form U is submitted for a site; all reportable chemicals for a site are reported on a single Form U. The certification statement and Part I are completed once for a Form U, regardless of the number of chemical substances reported. Parts II and III are completed for each chemical substance, and Part IV is only completed in the special case of a joint submission.

  • 23.2. Can one Form U be submitted for the same chemical substance used at two different sites?

    No. You must submit a separate Form U for each site for which you are required to report. Therefore, in cases where you have two separate sites manufacturing the same chemical substance, you must prepare separate Form Us for each site.

  • 23.3 Should I report known values and estimated values differently on Form U?

    No. Report all information requested in Form U to the extent it is known to or reasonably ascertainable by you and your company.

  • 23.4. The person previously responsible for this reporting is no longer working here and we cannot locate the user ID and password to gain access to our previous chemical reporting information on e-CDRweb. How do I gain access to earlier reported data? Can you reset the passphrase to grant me access?

    To access previous chemical reporting information for a company, you must be registered in EPA’s Central Data Exchange (CDX) with your own username and password and know the eCDRweb passphrase. If in CDX you register for the exact same organizations (same Organization ID) and exact same facilities (same facility ID) as your predecessor, you will be able to see what forms were previously created and submitted.

    In the event the original passphrase has been lost, the information on the Form U itself will not be electronically accessible. However, you can request a paper copy of the previously submitted information.

    To request a copy of your site’s 2012 CDR Form U from a prior reporting year (e.g., 2012 and 2016), please submit a notarized request on company letterhead to EPA. The company letterhead must be from the company that owns the site. The request must include the name and address of the site of the desired Form U and a statement certifying you are authorized to receive this potentially confidential information.

    Please send the request to one of the following addresses:

    By U.S. Postal Service
    CDR CDX Registration Coordinator (7407M)
    U.S. Environmental Protection Agency
    Office of Pollution Prevention and Toxics
    William Jefferson Clinton Building East
    1200 Pennsylvania Ave., N.W.
    Washington, D.C. 20460

    By Hand Delivery or Courier
    CDR CDX Registration Coordinator
    WJ Clinton Building East, Room 6428
    1201 Constitution Ave., N.W.
    Washington, D.C. 20004-3302

    (202) 564-8930 or (202) 564-8940

  • 23.5. May I amend a submission from the current or most recent reporting period if I realize I made a mistake?

    If you make a reporting mistake, you must amend your Form U. The Authorized Official or the Agent will need to unlock the submission to make the changes. See the CSPP CDX Registration Guide for more information. There will be an opportunity to explain why the change is being made - please be sure to complete that section. Additionally, you will need to file a self-disclosure form. Please contact EPA to make a voluntary disclosure under EPA's Audit policy. For additional information, visit or contact the CDX Help Desk at 1-888-890-1995. Note that if you did not claim (and substantiate if required) a particular data element as confidential at the time you submitted the data element to EPA, you cannot later add a claim of confidentiality.

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24. “Known to or Reasonably Ascertainable by” Reporting Standard

  • 24.1. Please provide further clarification on the scope of what would be required under the “known to or reasonably ascertainable by” reporting standard. How would this reporting standard apply to processing and use information? How does this standard differ from the “not readily obtainable” standard, previously applicable to such reporting? Does the change of standard indicate that “extensive file searches and customer surveys” are now expected of submitters in order to assemble data for the purposes of chemical data reporting?

    The term “known to or reasonably ascertainable by” is defined at 40 CFR 704.3. It means “all information in a person’s possession or control, plus all information that a reasonable person similarly situated might be expected to possess, control, or know.” By contrast, “readily obtainable” information did not even cover all the information in a submitter’s possession or control. As defined for the 2006 submission period, it was limited to what was known by certain “management and supervisory employees of the submitter.” See 68 FR 879 (2003).

    Under the “known to” portion of the standard, a submitter must ascertain what it knows about the processing and use of a chemical substance it manufactures (including imports), without confining its inquiry to what is known to managerial and supervisory employees. A submitter would also be expected to review other information which the manufacturer (including importer) may have in its possession. This standard requires that submitters conduct a reasonable inquiry within the full scope of their organization (not just the information known to managerial or supervisory employees). The inquiry would be as extensive as a reasonable person, similarly situated, might be expected to perform within the organization. Information derived from customer surveys or other customer contacts, like any other information, would be “known to” the submitter if it is available after a reasonable inquiry within the organization. The standard does not necessarily require that the manufacturer conduct an exhaustive survey of all employees.

    Inquiry under the “reasonably ascertainable” portion of standard may also entail inquiries outside the organization to fill gaps in the submitter’s knowledge. Note, however, that if particular information cannot be derived or reasonably estimated without conducting further customer surveys (i.e., without sending a comprehensive set of identical questions to multiple customers), it would not be “reasonably ascertainable” to the submitter. Thus, there is not a need to conduct new customer surveys for purposes of the CDR. As described above, however, existing customer survey data may nevertheless be “known to” the organization.

  • 24.2. What are some examples of types of information that are considered to be in a person’s possession or control or that a reasonable person similarly situated might be expected to possess, control, or know?

    The term “known to or reasonably ascertainable by” is defined at 40 CFR 704.3. It means “all information in a person’s possession or control, plus all information that a reasonable person similarly situated might be expected to possess, control, or know.” By contrast, “readily obtainable” information did not even cover all the information in a submitter’s possession or control. As defined for the 2006 submission period, it was limited to what was known by certain “management and supervisory employees of the submitter.” See 68 FR 879 (2003).

    • Files maintained by the submitter or employees in the submitter’s company, such as marketing studies, sales reports, or customer surveys;
    • Information contained in standard references, such as MSDSs, that contain use information or concentrations of chemical substances in mixtures; and
    • Identification numbers from the Chemical Abstracts Service (CAS) and from Dun & Bradstreet.

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25. Part I – Company and Site Identification Information

Section A. Parent Company Information

  • 25.1. What information must I provide about my parent company?

    For purposes of CDR, a parent company is the highest-level company of your site’s ownership hierarchy as of the start of the submission period, according to the definitions of highest-level parent company at 40 CFR 711.3. Submitters must report the highest-level parent company located in the United States and, if one exists, the highest-level foreign-based parent company (40 CFR 711.15(b)(2)(i)). For each parent company, provide the company name, address, and the D&B number.

    See the Instructions for Reporting for examples of how to identify the parent company(ies) in different situations on the CDR website at

26. Part II — Section A. Chemical Substance Identification

  • 26.1. How does a submitter determine the Chemical Abstracts Service Registry Number (CASRN) for a chemical substance and what if the submitter can’t find it?

    Submitters must use the Agency’s Substance Registry Services (SRS) to report the chemical substance identification information consisting of the currently correct Chemical Abstracts (CA) Index Name and the correct corresponding Chemical Abstracts Service (CAS) Registry Number (CASRN). The SRS is EPA’s central system for information about chemical substances that are tracked or regulated by EPA or other sources. It is the authoritative resource for basic information about chemicals, biological organisms, and other chemical substances of interest to EPA and its state and tribal partners. However, submitters of Inventory-listed substances should generally know already what CASRNs have been assigned to their substances.

    Submitters will be able to connect directly to the SRS database from the e-CDRweb reporting tool to report the correct CA Index Names and CASRNs for all non-confidential chemical substances on the TSCA Inventory. TSCA Accession Numbers and generic chemical names will be listed in the SRS for chemical substances on the confidential portion of the TSCA Inventory. The use of the SRS to obtain the identities for all CDR reportable chemical substances is a convenient way to meet the chemical nomenclature requirement and will help to prevent errors in the reporting of chemical identification information for the CDR.

    Every non-confidential chemical substance reported in accordance with CDR must be accompanied by its correct CASRN, corresponding to the chemical substance’s correct, specific chemical name. (40 CFR 711.15(b)(3)(i)). Submitters may enter either a CASRN  or the specific name of the chemical substance to select the appropriate CASRN/Chemical Abstracts (CA) Index Name combination from the SRS database. To report a substance on the confidential Inventory, the TSCA Accession Number must be submitted as the chemical identifying number.

  • 26.2. If the substance is confidential, can the Accession Number or the PMN case number be used instead?

    In the case of confidential chemical substances, EPA is requiring that submitters report only the TSCA Accession Number as a chemical identifying number. If the PMN case number of a confidential substance was used for reporting in the past, submitters can use the PMN case number to search the SRS to populate the pertinent chemical identification information for the confidential chemical substance listed on the TSCA Inventory.

    The SRS contains a cross-reference list that displays the Accession Number, generic chemical name, and the PMN case number (or for an initial TSCA Inventory substance, the TSCA Inventory reporting form number) for any confidential chemical substance listed on the TSCA Inventory. Submitters can use the SRS to select the correct Accession Number corresponding to the confidential chemical substance intended to be reported (the generic name corresponding to the Accession Number will automatically be incorporated into the report).

    EPA recognizes that there are certain circumstances where a submitter occasionally may not be sure of the particular PMN case number and Accession Number that EPA has assigned to one of its confidential chemical substances so that they do not have enough information to search the SRS. This could happen, for example, if the chemical substance were originally reported as part of a consolidated PMN and a submitter did not learn from EPA which particular case number in the consolidated PMN number sequence corresponds to which of the several reported confidential chemical substances. This could also happen if a certain PMN represented a mixture of two or more confidential chemical substances, such that multiple Accession Numbers were assigned to the different chemical substances reported in that single PMN, and a submitter didn’t already request the particular Accession Numbers from EPA for the individual chemical substances comprising that multi-component type of PMN.

    Submitters who are not able to identify the Accession Number by searching the SRS should read How do I find out if a substance is on the Inventory?” Individuals are urged to submit a complete and accurate TSCA Inventory Correspondence at least one month before the submission deadline. Note that incomplete and/or inaccurate requests may be rejected. The Agency will respond to such inquiries in as timely a manner as possible. It is the responsibility of the submitter to contact the Agency for such information in sufficient time to allow for the Agency to respond.

  • 26.3. Does EPA provide a cross-reference list of PMN Numbers and Accession Numbers?

    EPA’s Substance Registry Services (SRS) contains a cross-reference list that displays the Accession Number, generic chemical substance name, and the PMN case number (or for an initial TSCA Inventory chemical substance, the TSCA Inventory reporting form number) for any confidential chemical substance listed on the TSCA Inventory. The e-CDRweb reporting tool allows you to search SRS using the PMN number in order to populate your CDR report with the pertinent chemical identification information for confidential chemical substances listed on the TSCA Inventory. In addition, you may obtain the accession number by contacting EPA’s Hotline by phone at 202-554-1404 or by e-mail at

  • 26.4. A company is importing a mixture under a trade name, and the foreign manufacturer refuses to reveal the specific chemical identity of a confidential component of the mixture. How does the company report?

    If an importer submitting a report cannot provide the information specified in 40 CFR 711.15(b)(3)(i) because it is unknown to the importer and claimed as confidential by the supplier of the chemical substance or mixture, the importer must ask the supplier to use e-CDRweb to provide the complete, currently correct chemical identity information directly to the EPA in a joint submission. Contact information for the supplier, a trade name or other designation for the chemical substance or mixture, and a copy of the request to the supplier must be included with the importer's submission for the chemical substance.

  • 26.5. A company notices that there are CASRNs for several gas streams listed in the Partially Exempt Petroleum Process Streams listed in §711.6(b)(1) that appear to be molecularly similar to its fractionated products propane, butane and ethane. However, the CASRNs that the company previously used to report these products are not listed as partially exempt. The table below shows the CASRNs previously used in reporting by the company as compared to the CASRNS of molecularly similar partially exempt petroleum process streams.
    CASRNs used by Company CASRNS of Partially Exempt Streams
    74-98-6, Propane, C3H8 68476-49-3 Hydrocarbons,C2-4, C-3
    106-97-8, Butane, C4C10 68476-42-6 Hydrocarbons, C4-5
    74-84-0, Ethane, C2H6 68606-25-7 Hydrocarbons, C2-4

    The company wants to know whether or not these CASRNs would be considered synonyms and if they can use the CASRNs for the partially exempt process streams for their CDR submission.

    The CASRNs listed above for the partially exempt petroleum process streams are for Class 2 substances, which are combinations of possible hydrocarbons with the chain lengths in the ranges indicated. Such Class 2 substances are not intended to encompass Class 1 substances, which can be more precisely described with a specific chemical structure and molecular formula. For example, the substance identified above as butane is not considered the same substance as "Hydrocarbons, C4-5," even though it falls within the C4 to C5 range, because butane is a more precise description of the substance as it was actually manufactured, and "Hydrocarbons, C4-5" is considered to be a combination of possible hydrocarbons (not limited to alkanes) in the C4 to C5 carbon number range. A company should use the CAS number that is the best fit for the chemical substance being manufactured or imported and is consistent with how the substance is accurately described in commerce and was reported by the company for TSCA Inventory purposes. In this case, the correct CAS number for butane is 106-97-8. This substance is not partially exempt from CDR.

    EPA expects that use of SRS to identify chemical substances and their correct CASRNs will help improve the accuracy of identification. In the example above, a search of “butane” or “106-97-8” gives two results: one for 106-97-8 and another for 68476-85-7. The systematic name for CASRN 68476-85-7 is “petroleum gases, liquefied” which also is listed in the table at 40 CFR 711.6(b)(1) as partially exempt from CDR reporting. However, in the SRS section titled “Associated Identifiers”, CASRN 106-97-8 is listed as an incorrectly used CAS number. None of the CASRNs that the company previously used list the partially exempt CASRNs as synonyms and vice versa.

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27. Part II — Section B. Technical Contact Information

  • 27.1. What role does the technical contact play?

    The technical contact is the person whom EPA may contact for clarification of the information in a CDR submission. The technical contact should be a person who can answer questions about the reported chemical substance(s). Typically, a person located at the manufacturing site is best able to answer such questions. However, companies may use their discretion in selecting a technical contact or multiple technical contacts, as provided by the e-CDRweb reporting tool. Submitters should consider, in selecting the technical contact, that EPA may have follow-up questions about a CDR submission one or more years after the submission date. The technical contact need not be the person who signs the certification statement. The technical contact can be selected from the drop down list of registered support registrants.

  • 27.2. Are companies allowed to use their discretion in identifying the most appropriate technical contact to list on the Form U? Do technical contacts need to be physically located at the reporting site?

    While companies are allowed to use their discretion in selecting a technical contact or multiple technical contacts, as permitted by the e-CDRweb reporting tool, EPA expects a technical contact to be someone who can answer detailed follow-up questions that EPA may have regarding the Form U. EPA has found that technical contacts not at the reporting site generally are less knowledgeable about the chemical substance or the types of information needed for the Form U and therefore may not be able to discuss follow-up questions. Also, it has been EPA’s general experience that short-term contractors have not been suitable technical contacts because they may no longer be under contract with the submitting company a year or more after the Form U is submitted when EPA may want to contact them.

  • 27.3. Can two different plant sites within the same company that are both reporting under CDR have different technical contacts?

    Yes. A different technical contact may be reported for each site. A Form U would be completed for each plant site, and each Form U would list the technical contact able to answer questions about the information in the report. In fact, a different technical contact may be provided for each chemical substance reported on the Form U.

  • 27.4. Can companies have more than one technical contact for a site?

    Yes. The e-CDRweb reporting tool allows the identification of a different technical contact for each chemical substance.

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28. Part II — Section C. Manufacturing Information

29. Part II — Section D.1 — Industrial Processing and Use Data

30. Part II – Section D2 – Consumer and Commercial Use Data

  • 30.1. The Consumer and Commercial Category code allows a submitter to report “other” in place of one of the listed codes. When should “other” be used, and how much information should be provided?

    Codes for “Other” should rarely be used and only when you know that the listed codes do not apply. When “other” is used, include a description at a comparable level of specificity as found with the current codes. Do not chose “other” or use the written description to provide additional, more specific detail than is provided by simply choosing the existing codes.

  • 30.2. Why do submitters have to designate whether the indicated product category is consumer use, commercial use, or both, when submitters may not always know who ultimately uses their products?

    The intent of the consumer and commercial use data element is to identify the exposed populations. These two populations (i.e., consumers and commercial workers) are very different from each other, and the ability to distinguish uses between the two enables better exposure-based screening of chemical substances. Submitters may not always have detailed information about how the chemical substance(s) they make are used and to what extent they are used. However, EPA believes that industry possesses a greater knowledge than EPA about its own operations and the downstream uses of chemical substances it manufactures and sells, even if they do not control their customers’ sites.

  • 30.3. How do submitters report CDR information for chemical substances they manufacture and sell directly to consumers?

    If submitters manufacture (including import) 25,000 pounds or more (2,500 pounds for a chemical subject to certain TSCA actions) of a chemical substance and sell it for direct consumer use, mark the “Not Applicable” box under Part II – Section D.1 of Form U to denote that there is no industrial processing of the chemical substance. Complete Part II – Section D.2 to reflect the manner in which consumers use the chemical substance.

  • 30.4. How is “intended for use by children” defined for purposes of CDR?

    For purposes of reporting in accordance with the CDR regulation, under 40 CDR 711.3, “intended for use by children” means the chemical substance or mixture is used in or on a product that is specifically intended for use by children age 14 or younger. A chemical substance or mixture is intended for use by children when the submitter answers “yes” to at least one of the following questions for the product into which the submitter’s chemical substance or mixture is incorporated:

    1. Is the product commonly recognized (i.e., by a reasonable person) as being intended for children age 14 or younger?;
    2. Does the manufacturer of the product state through product labeling or other written materials that the product is intended or will be used by children age 14 or younger?; or
    3. Is the advertising, promotion, or marketing of the product aimed at children age 14 or younger?


    Certain products, such as household cleaning products, automotive supplies, and lubricants, typically are not intended to be used by children age 14 or younger. As such, if a submitter determines that the chemical substance or mixture is used only in automotive care products and lubricants, for example, he would typically report “No” for children’s use for Product Categories C401 and C402.

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  • 30.5. How does harmonizing CDR function and product codes with OECD-based codes impact reporting codes for consumer/commercial product categories?

    The 2020 CDR Revisions rule updated consumer/commercial product codes based on OECD product categories. Under this rule, the previous 33 consumer/commercial product categories are being replaced by 96 updated, OECD-based product codes. The updated codes will be fully implemented by the next reporting cycle in 2024. The updated codes for reporting consumer and commercial product categories are listed in Table 11 and the function codes are in Table 8 in 40 CFR 711.15.

    Reporting using the new OECD-based codes will be phased in during the 2020 and 2024 CDR submission periods. Manufacturers (including importers) of the chemicals listed in Table 7 at 40 CFR 711.15 are required to use the updated codes in 2020 CDR submissions. All manufacturers (including importers) are required to use the updated codes in 2024 submissions and beyond.

    Additional details about the function and product categories and how they are related to the OECD categories can be found in the Technical Support Document: Harmonizing CDR Functional and Product codes with OECD Functional, Product, and Article Codes located in the CDR Revisions rulemaking docket at, docket number EPA-HQ-OPPT-2018-0321. Crosswalk tables can be found in the Instructions for Reporting on the CDR website at

  • 30.6. What is the distinction between consumer, commercial, and industrial chemical use categories?

    “Consumer use” encompasses the use of a chemical or mixture containing a chemical that is sold to or made available to consumers for their use (including as part of a manufactured product or article, e.g. laundry and dishwashing products, furniture, clothing). See 40 CFR 711.3.

    “Commercial use” is the use of a chemical or mixture containing a chemical in a commercial enterprise providing a saleable good or service (e.g. dry cleaning, carpet cleaning, or oil change services). See 40 CFR 711.3

    “Industrial use” is the use at a site in which one or more chemicals or mixtures are manufactured (including imported) or processed. See 40 CFR 711.3.

    In short, a company that is processing or otherwise using the chemical at a manufacturing site would report the processing or use under the industrial processing and use section of the CDR report. Additionally, these uses are not necessarily mutually exclusive – a use may be industrial, consumer, and commercial (e.g., a lubricating oil could be used in all three categories).

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31. Part II — Estimating Number of Workers Reasonably Likely to be Exposed to a Chemical Substance

32. Joint Submissions (Primary Form)

  • 32.1. When are joint submissions allowed?

    A joint submission is most typically used when a substance or a mixture is imported and the supplier does not provide to the importer the specific chemical identity of the substance or substances that comprise the mixture. Joint submissions are allowed only where a supplier will not disclose to the manufacturer (including importer) the specific chemical name of the imported chemical substance or of a reactant used to manufacture the chemical substance, because the supplier claims the specific chemical name is confidential. This may happen, for instance, when a company is importing a mixture under a trade name, and the foreign manufacturer refuses to reveal the chemical identity of a component of the mixture that the foreign manufacturer considers confidential or trade secret. In this case, the importer and the supplier can jointly report the information through a joint submission. The importer must ask the supplier of the confidential chemical substance to directly provide EPA with the correct chemical identity in a Secondary Form U (see 40 CFR 711.15(b)(3)(i)(A)).

    This may also happen in the event a manufacturer cannot provide the entire chemical identity of a chemical substance it manufactures because the chemical substance is manufactured using a reactant having a specific chemical identity that the reactant supplier claims as confidential and will not reveal to the manufacturer. In this case, the manufacturer and the supplier of the reactant can jointly report the information through a joint submission. The manufacturer must submit a report directly to EPA containing all information he or she knows or can reasonably ascertain about the chemical identity. Furthermore, the manufacturer must also ask the reactant supplier to directly provide to EPA the correct chemical identity of the confidential reactant in a Secondary Form U (see 40 CFR 711.15(b)(3)(i)(B)).

    Because signatures are required by each party of a joint submission, secondary submitters who wish to report must each register with CDX and complete a Secondary Form U report. The reporting tool will match both submissions based upon the unique ID number sent by the manufacturer (including importer) to notify the supplier of the partial CDR submission. Suppliers do not have access to any of the information submitted to EPA by the manufacturers (including importers), unless the manufacturers provide it directly to the suppliers. Likewise, the manufacturers (including importers) cannot see the information that the suppliers report to EPA. This way, the confidentiality of information for all submitters is protected. The information provided by both submitters will be combined and processed as one joint submission once they are received by EPA.

  • 32.2. I’m an importer. Am I required to initiate a joint submission?

    No. If you know the specific chemical identity for the imported substance you are reporting, you can provide the full information on your primary form. A joint submission is only necessary when an importer cannot provide the specific chemical identity of the imported chemical substance.

  • 32.3. As a company generally has no contractual means to require foreign suppliers of already purchased materials to either register with CDX or file a joint submission electronically, what can the company do to ensure that a foreign supplier prepares a secondary submission?

    The joint submission requirement is to properly ask that suppliers provide secondary submissions to EPA. Therefore, it is the responsibility of the domestic company, the primary submitter, to ask the foreign company, the secondary submitter, to complete a Secondary Form U and send the information to EPA by the end of the submission period. The secondary submitter is expected to provide the chemical composition of an imported product or mixture, the chemical-specific function of each constituent substance, and information on chemical composition of the imported product or mixture. It is also the responsibility of the primary submitter to include a copy of the request to the secondary submitter with the Primary Form U that the primary submitter sends to EPA. (See 40 CFR 711.15(b)(3)(i)(B)). This is done when reporting using the eCDRweb electronic reporting tool.

  • 32.4. How will the manufacturer’s information be matched with the foreign supplier’s information if they are filing separately?

    After the manufacturer (including importer), acting as a Primary Submitter, fills in the trade name or other proprietary identifier in the “Chemical Identification” section of the “Joint Submission Report”, the primary submitter will use instructions in a box labeled “Unique Identifier for Joint Submission” to send an e-mail with a unique ID number and language to notify the supplier, acting as secondary submitter for the partial CDR submission containing information for the trade name product. The ID number will be used to link the joint reports in an internal database after the secondary submitter reports the correct chemical identity information to EPA by completing a Secondary Form U.

  • 32.5. A company plans, as a primary submitter, to submit a joint submission with the supplier of a mixture the company imports. Although the company knows the chemical identity of the chemical substances used in the mixture, the supplier has asked that the identity be kept confidential. In this case, does the company submit a joint submission using the trade name instead of using the chemical name?

    No. Joint submissions are used only in cases when a supplier will not disclose to the submitter the specific chemical identity of the imported TSCA Inventory chemical substance or a reactant used to manufacture the TSCA Inventory chemical substance because the name is claimed confidential. If a manufacturer (including importer) actually knows or can reasonably ascertain the chemical identity (e.g., the CASRN or Accession Number) of a chemical substance subject to CDR, the manufacturer (including importer) must provide that information irrespective of a supplier’s confidentiality claims.

    If, on the other hand, the manufacturer (including importer) as primary submitter wishes to claim the chemical identity as confidential, the chemical substance must be listed on the confidential portion of the TSCA Inventory, in which case the submitter must check the confidential business information (CBI) box and provide the appropriate upfront substantiation. The substantiation question at 40 CFR 711.30(b)(1) accommodates consideration of harm to the submitter’s competitive position, which could include consideration of the competitive positions of business partners or others with which the supplier has contractual or similar relations.

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