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20. Processing and Use Reporting Threshold
    • 20.1. What is the threshold for processing and use reporting?

      There is no separate threshold for processing and use information. If you are reporting a chemical under CDR, you must also report its processing and use information unless the chemical substance is exempted from processing and use reporting by 40 CFR 711.6(b). Processing and use information is only reported for the principal reporting year (i.e., 2019 for the 2020 reporting period) .

    • 20.2. If a company does not manufacture or import a chemical substance, does the company have to report processing and use information for TSCA chemicals purchased from a manufacturer for use in making a product?

      Only companies that manufacture or import chemical substances (as defined under TSCA) are required to report. If you purchase a chemical substance from a manufacturer (including importer) you are not required to report information under CDR for that purchased chemical substance.

    • 20.3. Company A manufactures over 25,000 pounds of a chemical substance and exports 90 percent of it. Since the remaining 10 percent is less than 25,000 pounds, does Company A need to report processing and use information in Part II of the form?

      Yes. The need to complete the processing and use information in Part II – Section D is based on the overall production volume, which would include the amount exported. Once a chemical substance is exported, further reporting is not needed on the exported volume. However, if the chemical substance goes to a distributor prior to being exported, Company A may need to report on any processing activities that might occur prior to export, such as the repackaging of the material. If it is directly exported, Company A would not need to report processing and use information on that volume that is directly exported.

    • 20.4. Must processing and use activities be reported for an inorganic chemical substance that meets the reporting threshold?

      Yes. Manufacturers (including importers) of inorganic substances have the same reporting obligations as manufacturers (including importers) of organic substances. Some substances which are defined as inorganic (e.g., water, certain ores and minerals) will still receive a full or partial exemption as they are classified under other exemption categories.

21. Full Reporting for Chemical Substances
    • 21.1. What is full reporting under CDR?

      Full reporting means that all Parts of Form U must be completed.

    • 21.2. Which chemical substances are subject to full reporting?

      Reportable chemical substances manufactured (including imported) in amounts of 25,000 pounds or more at a single site during any calendar year since the last principal reporting year (e.g., for the 2020 reporting period the last principal reporting year is 2015; therefore the years considered are 2016-2019 ) are subject to full reporting for the current principle reporting year (e.g., 2019 for the 2020 reporting period). Full reporting means that all Parts of Form U must be completed. Additionally, chemical substances that are the subject of certain TSCA actions are reportable when manufactured (including imported) in quantities of 2,500 pounds or more at a single site during any calendar year since the last principal reporting year.

      If you manufacture a chemical substance that is partially exempt from full reporting, reporting of data elements in Part II – Section D of Form U (industrial processing and use and consumer and commercial use data elements) is not required. The list of partially exempted chemical substances is found in 40 CFR 711.6(b), and is replicated on the CDR website and in EPA’s Substances Registry Services (SRS). The eCDRweb reporting tool will search SRS and report back to you if your chemical substance is partially exempted.

      See TSCA Chemical Data Reporting Fact Sheet: Chemical Substances which are the Subject of Certain TSCA Actions for information on how to identify chemical substances that are the subject of a TSCA action that affects the reporting threshold or the partial exemption status, including how to search EPA’s Substance Registry Services to identify the status of a chemical.

22. Partial Reporting Exemptions
    • 22.1. What substances are exempt from Processing and Use Information reporting because they qualify for a partial reporting exemption?

      If a chemical substance is subject to reporting but qualifies for a partial exemption, a company must report the information required by 40 CFR 711.15(b)(1)-(3) (which corresponds to Part I and Part II – Section A - C of Form U); however, a company is not required to report the information described in 40 CFR 711.15(b)(4) (which corresponds to Part II – Section D of Form U). Chemical substances in the following two groups qualify for a partial exemption from reporting requirements:

      1. Petroleum process streams listed in 40 CFR 711.6(b)(1) and
      2. Specific chemical substances listed in 40 CFR 711.6(b)(2)(iv)

      Note that these partial exemptions are negated if the chemical substance is the subject of any of certain TSCA actions.

      The most recent additions to partially exempt chemicals list can be found on the CDR Petition page.

    • 22.2. If a company manufactures more than 25,000 pounds of a chemical substance listed as a petroleum process stream at 40 CFR 711.6(b)(1)) and is not the subject of any TSCA actions that would negate its partial exemption, which sections of Form U must be completed?

      Based on these facts, the company only needs to complete Part I (site identification) and Part II – Sections A - C (chemical substance and technical contact identification and manufacturing information) of Form U. Part II – Section D (processing and use information) of Form U is not applicable.

    • 22.3. How do the “specific chemical substances” get listed for partial exemptions from CDR reporting?

      EPA created a partial exemption for certain chemical substances for which EPA has identified a low current interest in their processing and use information. The specific chemical substances are listed at 40 CFR 711.6(b)(2)(iv). If your chemical substance is partially exempt, you are required to complete only Part I and Part II – Sections A-C of the Form U.

      EPA may add additional chemical substances to the partially exempt list on its own initiative or in response to a petition from a member of the public. In 40 CFR 711.6(b)(2)(iii), EPA provides a process whereby any person may request EPA to amend the chemical substance list. Such a request must be submitted to EPA no later than 12 months prior to the start of the next principal reporting year.