October 22, 2019

October 21, 2019

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Deadline for TSCA Chemical Data Reporting Extended to October 31, 2016

Last week, US EPA announced in the Federal Register that it has extended the deadline for companies subject to its Chemical Data Reporting (CDR) rule to submit data on the chemical substances they manufacture and import pursuant to the Toxic Substances Control Act (TSCA) from September 30, 2016 to October 31, 2016.

Under the rule, regulated companies must disclose certain information on the chemical substances they manufacture or import. This information can include specific production volume, processing and use, or other relevant technical data. Additionally, upfront substantiation is required for Confidential Business Information (CBI) claims for processing and use information, as well as for site identity and chemical identity. CBI claims must be made and substantiated at the time the information is submitted. Otherwise, the information reported will not be confidential.

Because all data must be submitted electronically using US EPA’s web-based reporting tool (e-CDRweb) through EPA’s Central Data Exchange (CDX), we recommend uploading the required data to US EPA well in advance of the October 31, 2016 deadline to avoid any last-minute problems. If a company fails to submit and upload all applicable data by the deadline, it could face potential enforcement action and penalties.

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Steve Owens, Environmental Attorney, Squire Patton Boggs Law Firm
Of Counsel

Steve Owens focuses his practice on environmental, safety and health issues. From 2009 until November 30, 2011, Steve served as the United States Environmental Protection Agency’s Assistant Administrator, Office of Chemical Safety & Pollution Prevention. Appointed by President Obama and unanimously confirmed by the US Senate, Steve was responsible for managing US regulatory and scientific programs on pesticides and industrial chemicals including nanotechnology and biotechnology under the Toxic Substances Control Act (TSCA); Federal Insecticide, Fungicide and...

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Allen A. Kacenjar Jr, Squire Patton Boggs Law Firm, Environmental Law Attorney
Partner

Allen Kacenjar’s practice encompasses all areas of environmental law with particular emphases in regulatory development and advocacy, complex high-stakes environmental litigation, risk management counseling and complex environmental deal-making.

Allen’s primary focus is on minimizing his clients' exposure to environmental liabilities, whether through proactive efforts to shape evolving environmental laws, development of business practices, evaluation of transactional risks or aggressive litigation. Through his representation of major corporations, public entities and industry advocacy groups, Allen has obtained substantial experience under all major state and federal environmental laws including the Clean Air Act; Clean Water Act; Resource Conservation and Recovery Act (RCRA); Toxic Substances Control Act (TSCA); Comprehensive Environmental Response, Compensation and Liability Act (CERCLA); and Ohio’s Voluntary Action Program (VAP).

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Danelle Gagliardi Environmental Lawyer Squire Patton Boggs
Associate

Danelle Gagliardi represents a wide variety of clients in complex environmental transactions, litigation and regulatory compliance, including those in the metals, mining, iron and steel, oil and chemical industries, as well as real estate developers and shipping and logistics companies. She has a strong background in the Clean Air Act (CAA), Clean Water Act (CWA), Toxics Substances Control Act (TSCA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and California’s Proposition 65 (Prop 65).

Danelle has a multistate...

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