December 7, 2021

Volume XI, Number 341

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December 07, 2021

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December 06, 2021

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TSCA CDR Deadline Extended to January 29, 2021

On November 25, 2020, EPA formally extended the deadline for the 2020 Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) submissions -- from November 30, 2020 to January 29, 2021.  EPA noted that this will be the final extension for the 2020 CDR.  EPA previously announced an extension of the reporting period from its original September 30, 2020 deadline via an April 9 Federal Register notice.

EPA extended the deadline in response to comments from stakeholders who raised concerns about the ability to timely report due to technical issues with electronic reporting using EPA’s Central Data Exchange (CDX) system and staffing and other resource limitations arising from the COVID-19 pandemic.  EPA references six letters received by the Agency over the past two months raising these issues.  The regulated community will likely recall that EPA extended the submission deadline for the 2016 CDR due to problems with EPA’s electronic reporting system. 

For the 2020 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 2016, 2017, 2018, or 2019.  In addition to production volume information for each year, companies must provide manufacturing activity, processing, and use information for 2019.  For substances subject to certain regulatory actions, the reporting threshold is 2,500 pounds per year, per site. 

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

© 2021 Keller and Heckman LLPNational Law Review, Volume X, Number 330
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About this Author

Gregory A. Clark, Keller Heckman, EPA Contractor Lawyer, Environmental matters Attorney
Associate

Gregory Clark joined Keller and Heckman in 2010. He practices in the area of environmental law.

While in law school, Mr. Clark served as an articles editor for the Virginia Journal of Law and Technology. Prior to law school, Mr. Clark worked as an EPA contractor, primarily for the Water Security Division in the Office of Groundwater and Drinking Water. In this arena, Mr. Clark worked on validation of molecular biology and microbiology methods and on emergency preparedness. He led development of what is now EPA's Water Laboratory Alliance...

202-434-4302
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