January 18, 2021

Volume XI, Number 18


January 15, 2021

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Deadline Approaching: TSCA CDR Reports Due November 30, 2020

Every four years, under the Chemical Data Reporting (CDR) Rule issued pursuant to the Toxic Substances Control Act (TSCA), manufacturers (including importers) must provide U.S. EPA with information on the production and use of certain chemicals in commerce.  EPA uses CDR data to support risk screening, risk assessment, chemical prioritization, risk evaluation, and risk management activities.   

The CDR reporting requirement applies to manufacturers and importers with production (or importation) volumes of 25,000 lbs or more of certain chemicals, or 2,500 lbs or more of certain reduced reporting threshold chemical substances.  CDR reporting obligations for the 2020 reporting period are triggered if the annual production or importation thresholds at a particular facility were met or exceeded during any of the calendar years 2016 through 2019.  There are some limited exemptions, including for small volumes or impurities.  

CDR reports must be submitted through EPA’s Central Data Exchange (CDX) system, and are due by November 30, 2020.

© 2020 Foley & Lardner LLPNational Law Review, Volume X, Number 321



About this Author

Sarah Slack, environmental compliance counseling lawyer, Foley Lardner law

Sarah Slack is senior counsel and an environmental lawyer in the Business Law Department at Foley & Lardner LLP. Ms. Slack is a member of the Environmental Regulation Practice and the Life Sciences and Energy Industry Teams.

Ms. Slack divides her time between remediation/redevelopment work, environmental compliance counseling, transactions and environmental litigation. Ms. Slack has extensive experience on the cutting edge of Clean Air Act, Clean Water Act, Superfund, and RCRA enforcement, as well as citizen suit litigation, settlement...

Nicholas R. Johnson Foley Lardner Law Firm state voluntary cleanup programs lawyer

Nicholas (Nick) Johnson is an associate with Foley & Lardner LLP and a member of the firm’s Environmental Regulation Practice.

Mr. Johnson has substantial experience in all facets of environmental law and corporate environmental risk management, including both contested proceedings and general regulatory guidance and advice with respect to CERCLA, RCRA, TSCA, the Clean Water Act, the Clean Air Act, state voluntary cleanup programs, and other state and federal environmental laws. Mr. Johnson routinely works with buyers, sellers, investment...