EPA Webinar This Week and More on Chemical Data Reporting (CDR)

As reported here previously, 2020 is a reporting year for quadrennial Chemical Data Reporting (CDR). Since the last report here, the pending revisions to the CDR regulations were finalized on April 9, 2020 (download here).

Due to the severe lateness of the finalized CDR regulations, EPA also extended the reporting window by 2 months (download here). ISRI requested an extension of at least 2 months in a meeting with the Office of Information and Regulatory Affairs (OIRA) on February 11, 2020. The EPA staff at the OIRA meeting took notice. The reporting period for CDR starts June 1 and ends November 30, 2020 (2 months later than usual).

In late breaking news, EPA is offering a webinar, Tuesday, May 19, 2020, on 2020 CDR requirements. You need to register for the EPA webinar and may do so here.

Also, EPA just released a prepublication version of the revised definition of “small manufacturer” for CDR purposes. The CDR regulations have included a reporting exemption for a small manufacturer that meets the definition of “small manufacturer or importer”. According to the prepublication version, EPA has increased the annual sales thresholds specified in the existing definition by a factor of 3.

Under the revised definition, one or more facilities that are part of a company with total annual sales below $12 million are completely exempt from reporting. Also, a reporting exemption by substance applies to a facility that (i) is part of a company with total annual sales below $120 million and (ii) had 100,000 lb or less in annual CDR activity (e.g., 75,000 lb of copper in imported scrap). Members should determine whether they or any one of their facilities could qualify for CDR's small manufacturer (or importer) exemption.

The revised CDR definition of small manufacturer will take effect 30 days after publication in the Federal Register. Because the revised definition will take effect after the beginning of reporting on June 1, 2020, members should not report prior to the effective date, in case they qualify for the small manufacturer exemption under the new higher annual sales thresholds.


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