Get Ready for CDR

May 31, 2016
Ann Grimaldi

The reporting period for the Toxic Substances Control Act Chemical Data Reporting (CDR) rule starts on June 1, 2016 and continues through September 30, 2016. The CDR rule requires manufacturers (including importers) to provide EPA with information on the production and use of chemicals in commerce in large quantities. Notwithstanding significant progress in TSCA reform, with amendments likely to be passed this year, it is unlikely that those legislative changes will affect this upcoming regulatory obligation.

The rule applies to manufacturers and importers only. Generally, these entities are required to report if the production volume of a chemical substance is 25,000 lbs or more at any single site. However, a lower production volume of 2,500 lbs applies to chemical substances that are the subject of certain TSCA actions, such as Significant New Use Rules. See https://www.epa.gov/chemical-data-reporting/how-report-under-chemical-data-reporting for further information. The data collected through CDR is used to support EPA’s regulatory activities such as priority setting and risk screening.

EPA has provided guidance documents and will be conducting webinars on the CDR rule. For more information see: https://www.epa.gov/chemical-data-reporting/how-report-under-chemical-data-reporting#webinars.

Ann Grimaldi

Ms. Grimaldi maintains a diverse environmental law practice focusing on chemical and product regulation and litigation defense. Her practice areas include Proposition 65, California's Safer Consumer Products Regulations, California's Rigid Plastic Packaging Container Act and the federal Toxic Substances Control Act. Ms. Grimaldi graduated from the University of California Hastings College of the Law magna cum laude and holds a Bachelor of Science Degree in Bacteriology from University of California, Davis. Prior to attending law school, she worked as a research assistant in laboratories at the University of California, San Francisco Cancer Research Institute and at the University of California, San Francisco School of Medicine.