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EPA Announces Deadline Extension for 2016 TSCA and CDR Submissions
by: Thomas C. Berger, Martha E. Marrapese of Keller and Heckman LLP  -  Publications
Monday, September 19, 2016

EPA has announced that it will be formally extending the deadline for 2016 Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) submissions -- from September 30 to October 31.  The extension is intended to be a one-time action, and will be published in the Federal Register

The deadline is being extended in response to comments from the regulated community that raised concerns, in part, about the ability to make timely reports given several aspects of required electronic reporting under EPA’s Central Data Exchange (CDX) system.  An August 30, 2016 letter from the American Chemistry Council (ACC) is specifically referenced by EPA.

For the 2016 submission period, companies must report under CDR if at one or more U.S. sites they manufactured or imported at least 25,000 pounds of a reportable chemical substance during any one of the calendar years 2012, 2013, 2014, or 2015.  For substances subject to certain regulatory actions, the reporting threshold is 2,500 pounds per year per site.  Industry may recall that, for similar reasons, four years ago EPA extended the submission deadline for 2012 CDR reports from June 30, 2012 to August 13, 2012.

For additional information on CDR see: https://www.epa.gov/chemical-data-reporting

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