Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) is complicated and if submitted inaccurately (or not at all), can result in substantial penalties. Reporting is required every 4 years, and 2016 brings a number of changes to CDR requirements. Companies required to report under the CDR rules have until September 30 to submit their reports. Yesterday we reviewed two changes to CDR requirements, and today we will review two more changes for the 2016 CDR.
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Change 3: Same reporting threshold for processing and use
There is no longer a separate threshold for reporting processing and use information. The threshold for reporting processing and use information was previously 100,000 pounds (lb) or more.
That threshold is now the same as for all other reporting—25,000 lb or more or 2,500 lb or more for substances subject to TSCA actions.
Information relating to processing and use activities is reported for the principal reporting year only. For the 2016 CDR reporting period, 2015 is the principal reporting year.
Chemicals listed in 40 CFR 711.6(a) are exempt from CDR requirements. Chemicals specifically listed in 40 CFR 711.6(b) are partially exempted from CDR requirements. You are not required to report information relating to processing and use activities for the partially exempt substances. However, these chemicals are not exempt from the other CDR reporting requirements.
Change 4: Report production volume for all 4 years
The need to report production volume for all years since the last principal reporting year is new for 2016. For a site, manufacturers (including importers) must report the total annual production volume for each year since the last principal reporting year. For 2016, the manufacturer (including importer) must report the total production volume (domestically manufactured plus imported) for 2012, 2013, and 2014. For 2015, the manufacturer (including importer) must separately report the domestically manufactured and imported production volumes.
Check Enviro.BLR.com® for critical information and guidance on TSCA’s reporting requirements and the latest news concerning efforts to reform TSCA.