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Regulatory Updates

2020 TSCA Chemical Data Reporting (CDR)

The 2020 TSCA Chemical Data Reporting (CDR) deadline has been extended from Nov. 30, 2020 until January 29, 2021, after industry reporters recently faced difficulties with the electronic submissions system, Central Data Exchange (CDX). Earlier this year, EPA revised the CDR rule to reflect the 2016 amendments to TSCA, including changes for foreign-owned businesses and the reporting responsibilities of suppliers and contractors, as well as an exemption for small businesses.

The agency uses the CDR information in a number of ways in its TSCA program, such as setting priorities for assessing the risks of thousands of existing chemicals, conducting risk evaluations, determining which companies may be responsible for contributing to industry fees to support those evaluations and for making regulatory decisions.

The CDR rules require any company that “manufactures” chemicals to report types, quantities and uses of chemicals, at a threshold level of (typically) 25,000 lbs of a chemical substance at a single site (some specific chemicals are subject to a 2,500lb threshold). CDR is required every 4 years and for the 2020 period, total annual production must be reported for each calendar year covering 2016-2019.  In addition, information regarding the number of employees that are “reasonably likely to be exposed” and maximum concentration is to be reported.  As always there are certain exemptions from the CDR rules that should be evaluated.

Manufacturing includes:

  • Importing
  • Byproducts produced coincidental to a manufacturing process.
  • Wastes that are offered for commercial purposes (other than land disposal).

Such an extension will likely ease the burden on chemical companies that are subject to the rule, who could face EPA and third-party enforcement actions should their CDR submissions reveal violations of the Toxic Substances Control Act (TSCA).

Robert W. Hanley

Robert Hanley is a Senior Consultant at TRC, supporting transaction due diligence environmental and compliance assessments, and multimedia environmental compliance audits. He has a deep understanding of Toxic Substances Control Act requirements for chemical data reporting, new chemical Pre-Manufacture Notifications, and TSCA significant new use rules and notification requirements. His auditing experience includes specialized knowledge of RCRA and Toxic Substances and Control Act (TSCA) reporting and record keeping requirements. He also provides short-term, on-site environmental management support. Dr. Hanley holds a Ph.D degree in Biology from the University of Alabama, with a specialization in environmental engineering. Contact Rob at

Catriona Smith

Catriona (Cat) Smith has over 30 years of professional experience in the interpretation and application of regulations for industrial facilities relating to compliance, remediation and negotiations with regulatory agencies. Her clients include upstream and downstream oil and gas, chem-pharma, petrochem, manufacturing and federal, state, and local governments. Ms. Smith is a Vice President and Environmental Sector Market Director for TRC, with nationwide responsibilities to manage our clients’ PFAS challenges, support and grow our Oil and Gas clients and bring multi-disciplinary solutions to their complex projects. Contact Cat at

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