Now in Effect – Reporting Requirements Under US EPA's New Chemical Data Reporting Rule

    View Authors February 2012

    The reporting period for Chemical Data Reporting (CDR) under the Toxic Substances Control Act (TSCA) is now underway. US EPA’s new CDR rule affects users, manufacturers, importers and processors of chemical substances across a wide spectrum of industries and makes a number of significant changes to existing reporting requirements including:


    • Reporting production volume information
    • Reporting processing and use information
    • Other technical data that must be reported
    • Reporting for chemicals subject to TSCA rules or orders
    • Special requirements for reporting byproducts
    • New requirements for confidential business information claims
    • Industry codes changes
    • Electronic reporting now required
    • Shorter times between reporting periods

    Under the new CDR, entities must report all data required by the rule between February 1, 2012 and June 30, 2012. US EPA has advised that it will not postpone the reporting deadline. Entities subject to the new rule must submit all data required for the current reporting cycle to US EPA during this five-month window or face the risk of enforcement by US EPA. To help our clients understand the new CDR, Squire Sanders lawyers created a PDF overview of the revised reporting requirements necessary for compliance with US EPA’s revised CDR. For additional information or assistance regarding CDR, please contact one of the Squire Sanders lawyers listed in this publication or one of the Squire Sanders lawyers with whom you routinely work.