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Chemical Data Reporting

Using the 2016 CDR Database

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Data dictionary

EPA has generated a data dictionary to assist users in interpreting and using the 2016 CDR data. This information is relevant when navigating either the 2016 Access data file(13 MB, May, 2020) , Excel data (37 MB, May, 2020) or comma separated values (.csv) files .csv data MB, May, 2020) .

Factors to consider when using the database

In May 2017, EPA published the initial 2016 CDR database to provide the public, government officials, non‐governmental organizations, and industry access to non‐confidential information on the manufacture (including import), processing, and use of chemicals in commerce at national and regional levels. However, data withheld from this release included some aggregate production volumes and all site-specific production volumes.

In May 2020, EPA released updated 2016 CDR data which includes information that was previously classified as confidential business information (CBI), like aggregate production volumes and site-specific production volumes. The Lautenberg Act amendments to TSCA were signed into law during the 2016 CDR submission period and changed CDR CBI reporting requirements. As a result, EPA conducted a thorough substantiation and verification process with companies that submitted 2016 CDR data. This process allowed the agency to to determine which claims met the new legal standard and ensure that valid CBI claims remained protected.

Reporting thresholds

CDR reporting is triggered by the amount of a chemical manufactured (including imported), rather than the hazard or potential exposures associated with a chemical. Understanding reporting thresholds of manufactured (including imported) chemicals that trigger reporting is important when using and interpreting the CDR data.

  • 25,000 pounds or greater: Reporting for 2016 and future submission periods was triggered based on whether site-specific production volume met or exceeded 25,000 pounds during any calendar year since the last principal reporting year.  For 2016, the last principal reporting year was 2011 and therefore the submitter considered annual production from 2012 to 2015.
  • 2,500 pounds or greater: For chemicals subject to certain TSCA actions, the production volume reporting threshold was lower, and for those chemicals the submitter considered whether the annual production volume met or exceeded 2,500 pounds.
  • For all reportable chemicals, manufacturers (including importers) were required to report the full manufacturing data for the principal reporting year (e.g., calendar year 2015 for 2016 CDR and calendar year 2019 for 2020 CDR) and production volume for each calendar year since the previous principal reporting year (e.g., 2012 to 2015 for 2016 CDR and 2016 to 2019 for 2020 CDR).

Due to these reporting thresholds, totals of CDR production volumes reported may underestimate the actual total amount manufactured and imported in the United States, particularly if there are a substantial number of sites that manufacture (including import) the chemical in quantities less than 25,000 pounds per year or are otherwise exempted from reporting (such as small manufacturers). When comparing changes in production over time at a site, particularly on regional or national levels, it is important to take into account changes in the reporting thresholds across the years.

Reporting in ranges

The following data elements are reported as ranges to reduce the industry reporting burden:

  • Manufacturing Information:
    • Number of workers reasonably likely to be exposed to the chemical
    • Maximum concentration of the chemical
  • Processing and use Information:
    • Percent production volume for each product category
    • Number of sites for each product category
    • Number of workers for each product category
    • Maximum concentration for consumer and commercial use

Processing and use information

Processing and use of chemicals is often not under the control of the manufacturers (including importers); therefore, they may have incomplete knowledge of these activities. Manufacturers (including importers) were required to report processing and use information that was known to or reasonably ascertainable by them. They were not required to collect information from their customers regarding end uses. In addition, CDR submitters were not required to report processing and use information for quantities that were exported. As a result of these factors, the processing and use information in the CDR public database presents only a limited picture of the actual processing and use situation in the United States.

Confidential Business Information

It is important for users of the CDR public database to understand what data submitters were permitted to claim as confidential business information (CBI), and the way in which the public database has been aggregated and masked to protect CBI. Submitters could designate individual CDR data elements as CBI when they reported information. However, chemical identity could only be claimed confidential if the chemical were listed on the confidential portion of the TSCA Inventory.

Processing and use data elements could be claimed as CBI if a submitter believed that the release of information would reveal trade secrets or confidential commercial or financial information. Submitters were required to substantiate confidentiality claims for chemical identity, site identification, processing and use information, and other non-exempt data elements by answering a series of questions. A blank response or a response that was designated as “not known or reasonably ascertainable” could not be claimed as confidential.

Production volume could also be claimed as CBI.

In preparing the CDR public database, EPA takes care to avoid releasing CBI while also publishing as much information as possible. Users examining individual records will notice CBI-protected entries in some data fields.

If all of the production volumes for a chemical were not claimed as CBI, then the public CDR database would include specific values for individual and aggregated production volumes for that chemical. However, if some or all of the reported production volumes for a given chemical substance were claimed as CBI, then some or all of the individual CBI production volumes were not published and aggregated production volumes were published as a range.