TSCA Chemical Data Reporting (CDR) Season is here. Have you started yet?

January 19, 2021

By: Farhana Momin and Carol Kawa

Toxic Substances Control Act – Chemical Data Reporting (TSCA CDR) season is here. The reporting deadline is January 29, 2021.

This reporting requirement applies to US facilities that meet the following criteria:

  • Manufacture or import certain chemicals listed in the TSCA inventory, and
  • Exceed chemical production volume thresholds of 25,000 lbs/yr (or 2,500 lbs/yr for TSCA action chemicals)

Please note that EPA broadened the TSCA definition of small manufacturer on May 28, 2020. The definition now includes:

  • Facilities that have sales (combined with parent company) under $120 million, unless that company has a site that produced more than 100,000 lbs of a particular substance
  • Facilities that have sales (combined with parent company) under $12 million, irrespective of production volumes

The “small manufacturer” exemption does not apply to certain chemicals subject to TSCA actions.

Reach out to us today for more information on how we can help your facility with:

  • Chemical assessments
  • Threshold determinations
  • Complying with reporting requirements
  • General TSCA CDR questions.

Farhana Momin, P.E.
Project Engineer
Farhana’s primary area of practice is in the environmental compliance field, with a focus on air quality. Her air quality-related projects include the preparation of air compliance reports, Title V/SIP air permit applications, semiannual reports, and responses to proposed enforcement actions for clients in a variety of industries.

Carol Kawa, P.E.
Senior Engineer
Carol has 10 years of experience in the chemical engineering and environmental compliance field, including industry experience and environmental consulting. Carol has conducted compliance audits, maintained air quality compliance systems, performed greenhouse gas and criteria pollutant inventories, and completed regulatory and compliance reporting documentation for facilities in a variety of industries.

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