Last Chance for Complying with the 2024 CDR Submission

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Chemicals

29 Aug 2024

The 2024 Chemical Data Reporting period is from June 1 to September 30, covering production data from 2020 to 2023.

As a United States chemical manufacturer or importer, it should be no surprise that the Chemical Data Reporting (CDR) submission period is here again. Time flies when you’re maintaining careful records of your chemical substances and production volumes!

What is CDR?

Under the Toxic Substances Control Act (TSCA), the United States Environmental Protection Agency (EPA) requires manufacturers and importers to provide information on the production of their chemicals currently used in commerce. CDR, like a leap year, occurs every four years and allows the EPA to collect and evaluate exposure-related data to ensure public safety from potential hazardous chemicals. The submission period for 2024 begins June 1 to September 30, so it is critical you evaluate your regulatory obligations under this rule.

Do you meet the requirements?

The good news is that there are thresholds that need to be met before reporting is required. For the 2024 submission period, production volumes are based on data from 2020 to 2023. Reporting is required if you manufactured or imported ≥25,000 lbs. per site of any chemical substance currently listed on the TSCA Inventory. If this threshold is reached at any site during any of the reporting years (2020 to 2023), you must report total annual production volume for each of these years. Some chemicals may be subject to certain rules or orders under TSCA, like the Significant New Use Rules, which enforce greater control over production volume. Chemicals that fall under these rules or orders must report substances ≥2,500 lbs. for each site.

You may be in luck, though, as certain groups (e.g., small manufacturers) and activities may receive exemptions on reporting. If your chemical substance is a polymer, microorganism, naturally occurring substance, water, or certain form of natural gas, you are entitled to a full exemption from reporting. Furthermore, if your chemical substance is one the EPA has deemed of “low current interest,” you do not have to report your industrial processing and use information.

What’s new for 2024 reporting?

If you’re a new chemical substance submitter for this period, there’s no need to worry about sweeping changes. Now, when reporting function categories and consumer and commercial product categories, you must use the Organization for Economic Co-operation and Development (OECD)-based codes listed in column A of the tables found in 40 CFR 711.15(b)(4)(i)(C)(2) and 40 CFR 711.15(b)(4)(ii)(A)(2) of the Code of Federal Regulations.

Need assistance?

Navigating CDR and all the associated regulations can be difficult. If you have questions about this topic or a related topic, contact our experts at Intertek Assuris – we’re here to help!

References

TSCA Chemical Data Reporting Requirements https://www.ecfr.gov/current/title-40/chapter-I/subchapter-R/part-711

Sarah Zupko

Scientific & Regulatory Affairs Associate 1, Chemicals Group, Intertek Assuris

As part of the Notifications Team in the Chemicals Group, Sarah’s primary role is assisting clients in maintaining compliance with the relevant chemical regulations in the United States. Sarah is involved in preparing dossiers for submissions under Section 5 of the TSCA, interpreting and staying up to date on regulations related to VOCs and PFAS, and reviewing toxicological study reports.

Sarah attended the University of Guelph, where she received an Honours B.Sc. in Biomedical Toxicology.