Instructions for Reporting 2020 TSCA CDR

Instructions for Reporting
2020 TSCA Chemical Data Reporting
DRAFT
This draft is based on proposed changes
included in the
TSCA Chemical Data Reporting Revisions
Proposed Rule (RIN 2070-AK33)

U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics

April 2019

HIGHLIGHTS OF 2020 TSCA CHEMICAL DATA REPORTING (CDR)
•

The determination of the need to report is based on production volume during any
calendar year since the last principal reporting year (i.e., 2016-2019).

•

Information on the reportable chemical substance must be reported during the 2020 CDR
submission period, June 1, 2020 to September 30, 2020 (40 CFR 711.20).

•

All reporting companies must report CDR data electronically, using e-CDRweb, the CDR
web-based reporting tool, and EPA’s Central Data Exchange (CDX) system. Prior to
submitting data, submitters must register with CDX. Ensure that your pop-up blocker is
disabled before you begin to use e-CDRweb to complete your Form U.

•

Reporting is required for all chemical substances listed on the TSCA Inventory, other
than polymers, microorganisms, naturally occurring chemical substances, water, and
certain forms of natural gas (40 CFR 711.5 and 711.6) when manufacture (including
import) of those chemical substances meets the other reporting requirements. Chemical
substances that are the subject of any of certain listed TSCA actions may not be eligible
for partial or full exemptions (40 CFR 711.6).

•

Manufacturers (including importers) reporting to CDR are required to report processing
and use data, for calendar year 2019, for all reportable chemical substances when the
reporting threshold of 25,000 lb (or 2,500 lb if the subject of certain TSCA actions) is
met at any site during any calendar year during the submission period (i.e., 2016-2019)
(40 CFR 711.15(b)).

•

The reporting threshold is 2,500 lb (1,134 kg) for any person who manufactured a
chemical substance that is the subject of a rule proposed or promulgated under TSCA
section 5(a)(2), 5(b)(4) or 6; an order issued under TSCA section 5(e) or 5(f); or relief
that has been granted under a civil action under TSCA section 5 or 7. The effects of these
TSCA actions on CDR reporting are assessed based on the status of the chemical
substance as of the beginning of the submission period, June 1, 2020 (40 CFR 711.8(b)
and 40 CFR 711.15).

•

New small manufacturer and small government size standards are in place. Small
manufacturers meeting the revised definition at 40 CFR 704.3 are exempt from CDR
requirements unless they manufacture (including import) 2,500 lb or more of a chemical
substance that is the subject of a rule proposed or promulgated under sections 4, 5(b)(4),
or 6 of TSCA, or is the subject of an order in effect under section 4 or 5(e) of TSCA, or is
the subject of relief that has been granted under a civil action under sections 5 or 7 of
TSCA (40 CFR 711.9 and TSCA § 8(a)(3)(A)(ii)).

•

Upfront substantiation is required for confidentiality claims. Information submitted under
CDR may be claimed as confidential; however, such claims must be made at the time of
submission and substantiated in accordance with TSCA and the CDR rule. Submitters
must provide upfront substantiation of all confidentiality claims except for claims made
for domestic manufacture, import, and yearly production volume information. Certain
processing and use data elements, a blank response, or a response that is designated as
“not known or reasonably ascertainable” may not be claimed as confidential (40 CFR
711.30).

•

Changes to reporting requirements for company and site information:
o Report your foreign parent company, if applicable, in addition to your domestic
parent company. See the new definition for parent company. (Revised
requirement)
o Provide the applicable NAICS code for your reporting site. (New requirement)
o Provide a public contact. (New voluntary data element)

•

Changes to manufacturing information:
o Indicate whether your reported chemical is removed from the waste stream and
recycled. This requirement replaces the need to indicate whether a chemical is
removed from the waste stream and recycled, remanufactured, reprocessed, or
reused. (Revised requirement)
o Report the percent total production volume of your chemical substance that is a
byproduct. (New requirement)
o For joint submissions: The secondary submitter of a joint submission reports the
chemical specific function along with the chemical composition of the imported
product. (New requirement)

•

Changes to industrial processing and use information:
o The industrial function codes have been updated. (Revised requirement)

•

Changes to consumer and commercial processing and use information:
o The commercial and consumer product use codes have been updated. (Revised
requirement)
o Report the function of the chemical for each commercial and consumer product
code reported. (New requirement)

•

Change to the reporting process for co-manufactured chemicals: The contracting
company is required to initiate the reporting of co-manufactured chemicals and send an
alert to the producing company. (Revised requirement)

•

Changes to reporting of byproducts:
o Manufacturers of certain inorganic byproducts are now allowed to report those
substances under specified metal categories or may continue to report as listed on
the TSCA Inventory.
o New exemptions: (1) for specifically identified byproducts that are recycled in a
site-limited, enclosed system and (2) for byproducts that are manufactured as part
of non-integral pollution control and boiler equipment. Byproducts that meet the
requirement are exempted from the need to be reported.

•

Visit the CDR Web site (www.epa.gov/cdr) for program updates and announcements,
other guidance materials for 2020 reporting, and contact information for technical
assistance.

TABLE OF CONTENTS
1.
1.1
1.2
2.
2.1

2.2

2.3

3.
4.
4.1
4.2
4.3

4.4

4.5

Introduction ..................................................................................................................... 1-1
Background and Statutory Authority ................................................................................ 1-1
Changes to CDR Requirements for 2020.......................................................................... 1-1
Reporting Requirements ................................................................................................. 2-1
Step I: Is Your Chemical Substance Subject to the CDR Rule? ....................................... 2-1
2.1.1
Is Your Chemical Substance Manufactured for Commercial Purposes? (Question
A)
2-3
2.1.2
Is Your Chemical Substance on the TSCA Inventory? (Question B).................. 2-12
2.1.3
Is Your Chemical Substance Potentially Exempt from Reporting? (Question C) ... 215
2.1.4
Is your Chemical Substance Ineligible for an Exemption Because it is the Subject
of Certain TSCA Actions? (Question D)............................................................................ 2-17
Step II: Are You a Manufacturer Who Is Required to Report? ...................................... 2-19
2.2.1
Did You Manufacture (Including Import) 25,000 lb or More of the Chemical
Substance at a Single Site During any of the Calendar Years since the Last Principal
Reporting Year? (Question E) ............................................................................................ 2-20
2.2.2
Did You Manufacture (Including Import) 2,500 lb or More of the Chemical
Substance (if it is the Subject of Certain TSCA Actions? (Question F) ............................ 2-20
2.2.3
Do You Qualify for a Small Manufacturer or Small Government Exemption?
(Question G) ....................................................................................................................... 2-23
2.2.4
Did You Manufacture a Chemical Substance that is the Subject of Certain TSCA
Actions? (Question H) ........................................................................................................ 2-24
2.2.5
Do You Qualify for Any Other Reporting Exemptions? (Question I)................. 2-26
Step III: What Information Must You Report? ............................................................... 2-28
2.3.1
Is Your Chemical Substance Subject to Full Reporting due to Its TSCA Regulatory
or Consent Agreement Status? (Question J) ....................................................................... 2-30
2.3.2
Is Your Chemical Substance Listed as a Petroleum Process Stream? (Question K)230
2.3.3
Is Your Chemical Substance Listed as a Chemical for which There is Low Current
Interest in the CDR Processing and Use Information? (Question L) ................................ 2-30
When You Must Report .................................................................................................. 3-1
Instructions for Completing CDR Form U ................................................................... 4-1
Certification ...................................................................................................................... 4-1
Reporting Standard ........................................................................................................... 4-2
Part I - Section A. Parent Company Information .............................................................. 4-4
4.3.1
U.S. and Foreign Parent Company Name(s) (Block 1.A.1)................................... 4-6
4.3.2
Parent Company Dun & Bradstreet D-U-N-S® Number (Block 1.A.2) ............... 4-6
4.3.3
Parent Company Address (Blocks 1.A.3 through 1.A.8) ....................................... 4-7
Part I - Section B. Site Information .................................................................................. 4-7
4.4.1
Special Provisions for Certain Sites ....................................................................... 4-8
4.4.2
Site Name (Block 1.B.1) ........................................................................................ 4-9
4.4.3
Site Dun & Bradstreet Number D-U-N-S® (Block 1.B.2) .................................... 4-9
4.4.4
Site Street Address (Blocks 1.B.3 through 1.B.8) ................................................. 4-9
4.4.5
NAICS code (Blocks 1.B.9)................................................................................. 4-10
Part I - Section C. Public Contact Information ............................................................... 4-10
4.5.1
Public Contact Name (Blocks 1.C.1 and 1.C.2) .................................................. 4-11
i

4.5.2
Public Contact Telephone Number and Email Address (Blocks 1.C.3 and 1.C.4).. 411
4.6
Part I - Section D. Technical Contact Information ......................................................... 4-11
4.6.1
Technical Contact Name and Company Name (Blocks 1.D.1 and 1.D.2)........... 4-12
4.6.2
Technical Contact Telephone Number and Email Address (Blocks 1.D.3 and 1.D.4)
4-12
4.6.3
Technical Contact Mailing Address (Blocks 1.D.5 through 1.D.10)................... 4-12
4.7
Part II - Section A. Chemical Substance Identification .................................................. 4-13
4.7.1
Confidentiality of Chemical Substance Information (Block 2.A.1) .................... 4-14
4.7.2
Chemical Substance Identifying Number (Block 2.A.2) ..................................... 4-16
4.7.3
ID Code (Block 2.A.3) ......................................................................................... 4-17
4.7.4
Chemical Name (Block 2.A.4)............................................................................. 4-17
4.7.5
Special Provisions for Manufacturing by Contract.............................................. 4-18
4.7.6
Special Optional Provision for Manufacturers of Inorganic Byproducts ............ 4-18
4.7.7
Special Provisions for Joint Submitters of Unknown Chemical Substances ....... 4-19
4.8
Part II - Section B. Manufacturing Information ............................................................. 4-21
4.8.1
Confidentiality of Company, Site, and Technical Contact Information (Blocks
2.B.1 through 2.B.3) ........................................................................................................... 4-21
4.8.2
Reporting Manufacturing Information for Calendar Year 2019 (Blocks 2.B.4.
through 2.B.21)................................................................................................................... 4-22
4.8.3
Reporting Past Production Volume (PV) (Block 2.B.22) .................................... 4-29
4.8.4
Special Provisions for Manufacturing by Contract.............................................. 4-29
4.9
Part III - Processing and Use Information ...................................................................... 4-30
4.9.1
Confidentiality of Processing and Use Information............................................. 4-30
4.9.2
Part III - Section A. Industrial Processing and Use Data (Blocks 3.A.1 through
3.A.10) 4-33
4.9.3
Part III - Section B. Consumer and Commercial Use Data (Blocks 3.B.1 through
3.B.10) 4-42
4.9.4
Special Provisions for Manufacturing by Contract.............................................. 4-50
4.9.5
Special Provisions for Joint Submitters of Unknown Chemical Substances ....... 4-50
4.10 Manufacturing by Contract: Co-manufacture Report ..................................................... 4-50
4.10.1 Determining the Need for a Co-manufacture Report when Manufacturing by
Contract 4-50
4.10.2 The Primary Report is Completed by the Contracting Company ........................ 4-51
4.10.3 The Secondary Report is Completed by the Producing Company ...................... 4-51
4.10.4 Confidentiality of Information on a Co-manufacture Report .............................. 4-52
4.11 Joint Submissions using Part IV – Unknown Chemical Identity.................................... 4-53
4.11.1 Determining the Need for a Joint Submission using Part IV ............................... 4-53
4.11.2 The Primary Submission is Completed by the Importer or Reactant User .......... 4-54
4.11.3 The Secondary Submission is Completed by the Supplier (Foreign or Reactant) ... 454
4.11.4 Confidentiality of Information Jointly Submitted................................................ 4-55
5.
How to Obtain Copies of Documents Cited in This Instructions Document ............. 5-1
5.1
Obtaining Copies of the TSCA Rules ............................................................................... 5-1
5.2
Obtaining Copies of the Public Portion of the TSCA Inventory ...................................... 5-1
5.3
Obtaining Copies of Other Information Materials for the 2020 CDR .............................. 5-1
Appendix A .................................................................................................................................... 1
Appendix B .................................................................................................................................... 1
Appendix C .................................................................................................................................... 1
Appendix D .................................................................................................................................... 1
ii

Appendices
Appendix A—Glossary ............................................................................................................. A-1
Appendix B—Chemical Substances That Are the Subject of Certain TSCA Orders,
Proposed or Final TSCA Rules, or Relief Granted under Civil Actions,
or Consent Agreements ...................................................................................... B-1
Appendix C—Chemical Substances Partially Exempt from Reporting in 2020 ....................... C-1
Appendix D—Descriptions of Codes for Reporting Processing or Use Operations,
Industrial Sectors, Function Categories, and Consumer and
Commercial Product Categories ....................................................................... D-1
LIST OF FIGURES
Figure 2-1. Decision Logic Diagram for Evaluating Step I ....................................................... 2-2
Figure 2-2. Decision Logic Diagram for Evaluating Whether a Byproduct Chemical
Substance is Subject to the CDR Rule .................................................................... 2-6
Figure 2-3. Decision Logic Diagram for Evaluating Step II .................................................... 2-19
Figure 2-4. Decision Logic Diagram for Evaluating Step III ................................................... 2-29
LIST OF TABLES
Table 2-1. Chemical Substances Covered by the Exemption for Certain
Forms of Natural Gas .............................................................................................. 2-16
Table 2-2. Examples of Evaluating Substances for the Naturally Occurring
Exemption (40 CFR 711.6(a)(3)) ............................................................................ 2-17
Table 2-3. Production Volume Threshold Examples ............................................................... 2-21
Table 2-4. Small Manufacturer or Small Government Exemption Examples (40 CFR 711.9) 2-24
Table 2-5. Examples of Manufacturing/Importing Activities under Circumstances
which do/do not Require Reporting ........................................................................ 2-28
Table 4-1. Examples of the Application of the “Known to or Reasonably Ascertainable”
Reporting Standard to Processing and Use Data ...................................................... 4-3
Table 4-2. Applying Parent Company Definition in Different Situations .................................. 4-4
Table 4-3. Parent Company Name Standardization Rules ......................................................... 4-6
Table 4-4. Substantiation Questions to be Answered when Asserting Chemical Identity
iii

CBI Claims (from 40 CFR 711.30(b) and (c)) ........................................................ 4-14
Table 4-5. ID Code for Chemical Identifying Numbers ........................................................... 4-17
Table 4-6. Metal Compound Categories for Inorganic Byproduct Chemical Substances Only 4-19
Table 4-7. Substantiation Questions to be Answered when Asserting Company, Site, or
Technical Contact Identity CBI Claims (40 CFR 711.30(c)(1)) ............................. 4-22
Table 4-8. Examples of Reporting Production Volume for Part II – Manufacturing
Information .............................................................................................................. 4-24
Table 4-9. Codes for Reporting Number of Workers Reasonably Likely to be Exposed ........ 4-25
Table 4-10. Codes for Reporting Maximum Concentration ..................................................... 4-27
Table 4-11. Examples of Reporting Byproduct Percentages and Recycling ............................ 4-28
Table 4-12. Substantiation Questions to be Answered when Asserting Processing and Use
Information CBI Claims (40 CFR 711.30(d)(1)) .................................................. 4-31
Table 4-13. Codes for Reporting Type of Industrial Processing or Use Operations ................ 4-33
Table 4-14. Industrial Sectors (IS) ........................................................................................... 4-34
Table 4-15. Codes for Reporting Function Categories (FCs) ................................................... 4-36
Table 4-16. Examples of Reporting Industrial Processing and Use Information ..................... 4-40
Table 4-17. Codes for Reporting Numbers of Sites ................................................................. 4-40
Table 4-18. Codes for Reporting Number of Workers Reasonably Likely to be
Exposed During Processing and Use ..................................................................... 4-41
Table 4-19. Product Category Codes ........................................................................................ 4-43
Table 4-20. Examples of Products Intended for Use by Children ............................................ 4-47

iv

PREFACE
The primary goal of this document is to help the regulated community comply with the
requirements of the CDR rule. This document does not substitute for that rule, nor is it a rule
itself. It does not impose legally binding requirements on the regulated community or on the U.S.
Environmental Protection Agency (EPA).
Manufacturers (including importers) are required by the CDR rule to report to EPA
information concerning the manufacturing, processing, and use of certain chemical substances
listed on the TSCA Chemical Substance Inventory. The CDR requirements have changed since
the last collection, which occurred in 2016 and was based on 2012-2015 production data.
Manufacturers (including importers) are subject to the revised reporting requirements based on
manufacturing (including importing) activities conducted since the last principal reporting year
(i.e., calendar years 2016-2019).
The 2020 submissions are due by September 30, 2020 and must be submitted via the
Internet using e-CDRweb and EPA’s Central Data Exchange (CDX). e-CDRweb is a web-based
reporting tool that allows manufacturers (including importers) to file a paperless CDR
submission and receive instant receipt confirmation of their submissions. User guides focused
solely on Instructions for using CDX and eCDRweb are available under the Instructions &
guidance tab on the How To Report Under Chemical Data Reporting page of the CDR website.
This instructions document contains the following chapters and appendices:
•

Chapter 1 - Introduction to the CDR and changes made since the 2016 reporting cycle.

•

Chapter 2 - Reporting requirements to determine which chemical substances are reportable,
who must report, and what information must be reported.

•

Chapter 3 - When you must report.

•

Chapter 4 - Instructions for completing Form U.

•

Chapter 5 - How to obtain copies of documents cited in this Instructions document.

•

Appendix A - Glossary.

•

Appendix B - Chemical substances that are the subject of certain TSCA orders, proposed or
final TSCA rules, relief granted under civil actions, or consent agreements.

•

Appendix C - Chemicals substances partially exempt from reporting in 2020.

•

Appendix D - Descriptions of codes for reporting Processing or Use Operations, Industrial
Sectors, Industrial Function Categories, and Consumer and Commercial Product Categories.

v

Chapter 1

Introduction

1. Introduction
1.1 Background and Statutory Authority
In 1977, the U.S. Environmental Protection Agency (EPA) promulgated a rule under the
Toxic Substances Control Act (TSCA) section 8(a), 15 U.S.C. 2607(a), to compile and keep
current an inventory of chemical substances in commerce in the United States. This inventory is
called the TSCA Chemical Substance Inventory (TSCA Inventory). In 1986, EPA promulgated
the Inventory Update Reporting (IUR) rule, also under TSCA section 8(a), to facilitate the
periodic updating of the TSCA Inventory and to support activities associated with implementing
TSCA. The IUR rule is now called the Chemical Data Reporting (CDR) rule and has been
amended several times since 1986, most recently in 2019.
This document pertains to CDR reporting during 2020. It provides detailed information
and examples to assist manufacturers (including importers) in reporting under the CDR rule.
Selected screenshots of the e-CDRweb reporting tool are provided throughout this document to
guide you through the completion of your Form U. These screenshots are not based on actual
data, but are hypothetical situations generated to assist submitters in completing Form U.
User guides for e-CDRweb provide detailed descriptions of the reporting tool and include
detailed screenshots. The user guides are available on the CDR website at www.epa.gov/cdr.
Appendix A of this document provides a glossary of CDR terms, which may help you to
understand the 2020 reporting requirements.
This document is not a substitute for the CDR rule in 40 CFR Part 711. To the extent
that any inconsistencies exist between the CDR rule and this document, the requirements as
promulgated in the rule should be followed. You should carefully review 40 CFR Part 711 to
determine whether you are required to report information under the CDR rule.
To comply with the CDR rule, it is important to have a thorough understanding of the
TSCA Inventory and the procedures available to determine whether a chemical substance is
listed on the TSCA Inventory. Chapter 5 of this document explains how you can obtain copies of
TSCA rules, including the CDR rule, and access the non-confidential TSCA Inventory.

1.2 Changes to CDR Requirements for 2020
In 2019, EPA changed the requirements for reporting under CDR when promulgating the
CDR Revisions rule. These changes are being implemented for the 2020 submission period. This
section summarizes the changes that are new for 2020. More specific information is provided in
the relevant chapters of this instruction manual.
Reporting of Co-manufactured Chemicals

EPA changed the reporting mechanism for co-manufactured chemicals by implementing
a multi-reporter chemical report process where the contracting company is the primary submitter
and the producing company is the secondary submitter. Under this revised reporting method, the
contracting company will initiate a co-manufacture report that will trigger the reporting
1-1

Chapter 1

Introduction

requirements for the producing company. The contracting company will report the specific
chemical identity, the volume manufactured, the processing and use information, and all other
necessary information in the co-manufactured chemical report within its Form U submission.
Using e-CDRweb, the producing company will be notified by the contracting company to
provide the production volume and other manufacturing-related information on a related comanufactured chemical report within its Form U submission. These changes are further
explained in Sections 4.4.1.2, 4.7.5, 4.8.4, 4.9.4, and 4.10.1.
Site NAICS Code

EPA now requires submitters to report the 6-digit North American Industry Classification
System (NAICS) code that best describes the activities conducted at the reporting site. Use of the
standard industry identifier provides uniformity and comparability in the presentation and
understanding of data. EPA will use the NAICS code information in its analysis of the reported
manufacturing-related information to better analyze the data by industry sector. Because
reporting under CDR is done by the manufacturing site, that site is expected to be sufficiently
knowledgeable to determine the appropriate NAICS code. This change is further explained in
Section 4.4.5.
Site Public Contact Information

EPA now allows the reporting of a public contact as a voluntary data element. The public
contact is an individual who may be contacted by the general public with questions regarding the
company and the information reported to CDR. This person may or may not be familiar with the
reported information but has been designated by the site or company to handle public inquiries.
The addition of a public contact provides an alternate company contact to the technical contact
for those who have more general questions, or in situations in which the technical contact
information has been claimed as confidential. The public contact cannot be claimed as
confidential. This change is further explained in Section 4.5.
Parent Company Identity

EPA made three changes associated with parent company reporting under CDR: (1)
added the requirement to report the highest-level foreign parent company in addition to reporting
the highest-level U.S. parent company when the ultimate parent company is located outside of
the United States; (2) replaced the definition of U.S. parent company from 40 CFR 711.3 and
with a new definition for parent company; and (3) added a requirement for reporters to report
legal name(s) and to follow a naming convention for providing the parent company name(s), the
details of which are found in Section 4.3 below.
Indication that Substance was Removed from the Waste Stream and Recycled

EPA modified the data element related to removing substances from the waste stream in
order to clarify the reporting requirement. EPA removed the terms “remanufactured, reprocessed,
reused” from the data element description, changing the term to “recycled or otherwise used for a
commercial purpose instead of being disposed of as a waste or included in a waste stream.” It is
EPA’s intention that this data element identify the chemicals that would otherwise be disposed of
as a waste and are, instead, retained in commerce. This change is further explained in Section
4.8.2.10.
1-2

Chapter 1

Introduction

Processing and Use Codes

EPA replaced the Form U Part III.A. industrial function and Part III.B.
commercial/consumer product use codes with codes based on the OECD Internationally
Harmonized Functional, Product, and Article Use Categories. Additionally, EPA added function
categories based on OECD function categories for commercial/consumer products to the Form U
Part III.B. The OECD function use categories and product and article use categories are
described in the document “Internationally Harmonised Functional, Product and Article Use
Categories”. These changes are further explained in Section 4.9 and the categories are listed in
Appendix D.
Joint Submission Chemical Function Codes

Joint submissions are most typically used when a mixture is imported, and the supplier
does not provide the importer with the specific chemical identity of the chemicals that comprise
the mixture or of the mixture formulation. The importer reports use information associated with
the overall mixture but not the individual chemicals that comprise the mixture. Therefore, EPA
now requires that the secondary submitter of a joint submission report the chemical-specific
function along with information on chemical composition. This change is further explained in
Sections 4.9.5 and 4.11.
CBI Substantiation Specifications to Align with Lautenberg Act Requirements

EPA made changes to requirements related to claiming CDR information as confidential
to be consistent with new statutory requirements. Amendments to TSCA enacted in 2016 under
the Lautenberg Act require the Agency to review and make determinations regarding the validity
of confidential claims for information submitted to EPA under TSCA. Section 14(c)(3) of TSCA
states that non-exempt confidentiality claims must be substantiated at the time of submission [82
FR 6522 (Jan. 19, 2017)]. The Agency amended the substantiation requirements for CDR to
require substantiation for all confidentiality claims except for information exempt from
substantiation under TSCA section 14(c)(2). The CBI substantiation changes reflect the
culmination of ongoing continuous improvements from the time that the Lautenberg Act was
passed through the development of plans for the 2020 CDR.
Changes to CBI Substantiation include the addition of CBI substantiation exemptions
consistent with the Lautenberg Act, changes to CBI substantiation questions, specification of
data elements that are not eligible for confidentiality claims, and the development of joint
submitter confidentiality considerations. These changes are further explained throughout Section
4.
Byproduct Provisions Including Reporting Exemptions and Optional Consolidated Category Reporting

EPA added a new data element in Form U Part II to report the percent total production
volume for a chemical that is a byproduct. This change supports identification of important
universe subpopulations and their representation in CDR with respect to production volume. This
change is further explained in Section 4.8.2.9.

1-3

Chapter 1

Introduction

EPA added two new reporting exemptions for byproducts: (1) an exemption for specific
site-limited recycled byproducts and (2) an exemption for byproducts generated by specific nonintegral processes. In addition, manufacturers of metal inorganic byproducts may elect to report
in consolidated categories for inorganic byproducts containing certain individual elemental
metals and metal compounds. These changes are further explained in Section 2.1.1.3.
Small Manufacturer Definition Update and Addition of Small Government Definition
EPA updated the small manufacturer definition and added a definition for small
governments at 40 CFR 704.3. Small manufacturers and small governments are exempted from
the need to report, unless the manufactured chemical is the subject of certain TSCA actions.
These changes are further explained below in Section 2.2.3.

1-4

Chapter 2

Reporting Requirements

2. Reporting Requirements
This chapter explains the reporting requirements for the 2020 CDR reporting cycle. CDR
reporting requirements apply to manufacturers (including importers) of chemical substances. The
term ‘chemical substance’ is defined in Appendix A.
For the 2020 submission period, manufacturers (including importers) are required to use
e-CDRweb, the CDR reporting tool, and EPA’s CDX to create an electronic version of Form U
and to submit information in response to the requirements of the CDR rule. (40 CFR Part 711)
You must register with CDX to submit online, and you must register the name of the company
on whose behalf you are submitting a Form U. EPA does not accept paper submissions or
electronic media (diskette, CD-Rom, etc.) for any CDR submission. (40 CFR 711.35)
If you reported under the 2016 CDR, you should review the reporting requirements
carefully because they have changed. You may be required to report information on chemical
substances for which you did not need to report in previous reporting cycles.
You should consider the following three steps to determine whether you are required to report
for each chemical substance that you domestically manufacture (including import) into the
United States during each year since the last principal reporting year (i.e., consider
calendar years 2016, 2017, 2018, and 2019):
•
•
•

Step I: Is your chemical substance subject to the CDR rule?
Step II: Are you a manufacturer (including importer) who is required to report?
Step III: What information must you report?

This chapter discusses each of these steps and the associated reporting requirements in
more detail.

2.1 Step I: Is Your Chemical Substance Subject to the CDR Rule?
Under the CDR rule, reporting for the 2020 CDR
reporting cycle is generally required for a chemical substance
that is manufactured (including imported), is on the TSCA
Inventory as of June 1, 2020, and is not specifically exempted by
40 CFR 711.6(a). The term “CDR reportable chemical
substance” will be used throughout this document to refer to a
chemical substance that fulfills these requirements. Figure 2-1
presents a decision logic diagram to assist you in determining
whether you manufacture a CDR reportable chemical substance.
The following subsections explain each question in greater
detail.

A CDR reportable
chemical substance is a
chemical substance that is
domestically manufactured
or imported into the United
States, is listed in the TSCA
Inventory, and is not
specifically exempted by 40
CFR 711.6(a).

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Figure 2-1. Decision Logic Diagram for Evaluating Step I

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2.1.1

Reporting Requirements

Is Your Chemical Substance Manufactured for Commercial Purposes? (Question A)

The first step in determining your reporting requirements is to determine whether you
meet the definition of manufacture or manufacturer. The following manufacturing-related terms
are defined below:
•

Manufacture – To manufacture, produce, or import for commercial purposes.
Manufacture includes the extraction, for commercial purposes, of a component chemical
substance from a previously existing chemical substance or complex combination of
chemical substances. A chemical substance is co-manufactured by the person who
physically does the manufacturing and the person contracting for such production when
that chemical substance, manufactured other than by import, is:
(1) produced exclusively for another person who contracts for such production, and
(2) that other person dictates the specific chemical identity of the chemical substance
and controls the total amount produced and the basic technology for the
manufacturing process (40 CFR 711.3).

•

Manufacture for commercial purposes – (1) To import, produce, or manufacture with
the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer, and includes among other things, such “manufacture” of any amount of a
chemical substance or mixture:
(i) For commercial distribution, including for test marketing.
(ii) For use by the manufacturer, including use for product research and
development, or as an intermediate.
(2) Manufacture for commercial purposes also applies to chemical substances that are
produced coincidentally during the manufacture, processing, use, or disposal of
another chemical substance or mixture, including both byproducts that are separated
from that other substance or mixture and impurities that remain in that chemical
substance or mixture. Such byproducts and impurities may, or may not, in themselves
have commercial value. They are nonetheless produced for the purpose of obtaining a
commercial advantage since they are part of the manufacture of a chemical product
for a commercial purpose (40 CFR 704.3).

•

Manufacturer – A person who manufactures a chemical substance (40 CFR 711.3).

For purposes of the CDR rule, a chemical substance is manufactured (including
imported) only if it is domestically manufactured or imported for commercial purposes. See
TSCA section 8(f), TSCA section 3(9), and 40 CFR 704.3, which includes a parallel definition of
“Import for commercial purposes.” As identified above, the term manufacture for commercial
purposes means that the chemical substance is produced for the purpose of obtaining a
commercial advantage. Manufacture for commercial purposes also applies to chemical
substances that are produced coincidentally during the manufacture, processing, use, or disposal
of another chemical substance or mixture, including both byproducts that are separated and
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impurities that remain in a chemical substance or mixture. (40 CFR 704.3)
2.1.1.1 Chemical Substances Manufactured by Contract
The person who contracts with another person to manufacture a chemical substance is
considered to be a co-manufacturer, along with the person that physically manufactures the
chemical substance.
As specified in the definition for manufacture, manufacturing by contract is a situation
where the contracted person manufactures or produces the chemical substance exclusively for the
contracting person, and where the contracting person dictates the specific chemical identity of
the chemical substance and controls the total amount produced and the basic technology for the
manufacturing process. Additional information, including specific co-manufacturing reporting
scenarios, is provided in Fact Sheet: Co-Manufactured Chemical Substances. For consistency,
the two parties involved in the co-manufacturing situation are called the contracting company
(who is controlling the manufacture of the chemical substance) and the producing company (who
is physically manufacturing the chemical substance).
2.1.1.2 Changes to Company Ownership or Legal Identity
Under 40 CFR 711.8(a), the reporting obligation falls to the “person who manufactured.”
EPA recognizes that in some cases, business transactions occurring during the submission period
have led to questions about who is now the “person who manufactured.” The scenarios in Fact
Sheet: Reporting After Changes to Company Ownership or Legal Identity are intended to serve
as a general aid in appropriately resolving these questions, but they will not necessarily account
for all the relevant circumstances of a particular transaction. It is ultimately the manufacturer’s
responsibility to report appropriately under CDR, notwithstanding the complexity of its own
business transactions.
2.1.1.3 Byproducts
Byproducts are chemical substances that are produced without a separate commercial
intent during the manufacture, processing, use, or disposal of another chemical substance(s) or
mixture(s) (40 CFR 704.3). If the byproduct is manufactured (including imported) in a volume
of 25,000 lb (or 2,500 lb if it is the subject of certain TSCA actions) or more at a single site
during any calendar year since the last principal reporting year (e.g., since 2015 for the 2020
submission period), then its manufacture (including import) is potentially subject to CDR
requirements. Figure 2-1 presents a decision logic diagram to assist you in determining whether
you manufacture a byproduct that is a CDR reportable chemical substance.
Byproducts may or may not, in themselves, have commercial value. They are nonetheless
produced for the purpose of obtaining a commercial advantage because they are part of the
manufacture of a chemical product for a commercial purpose. Thus, chemical substances that are
the byproducts of the manufacture, processing, use, or disposal of another chemical substance or
mixture, like any other manufactured chemical substance, are subject to CDR reporting if they
are listed on the TSCA Inventory, are not otherwise excluded from reporting, and their
manufacturers are not specifically exempted from CDR requirements.
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There are, however, conditions under which
byproducts are not required to be reported. See 40
(CFR 711.10(c)). As a general rule, if, after it is
manufactured, your byproduct chemical substance is
not put to use for a separate commercial purpose
(see 40 CFR 711.10(c)(4)(2)(ii)), you do not need to
report it.
For byproduct chemical substances that are
put to use for a separate commercial purpose, there
are three categories of exemptions:

Reporting Requirements
Can a byproduct be manufactured
if the main product is an article?
Yes, potentially. You need to
consider whether you are
manufacturing a chemical substance
as a byproduct when you are
manufacturing an article. For
example, if your use or processing of
a chemical substance (chemical A) to
manufacture an article coincidentally
produces a different chemical
substance (chemical B), apart from
the article you intended to
manufacture, then you have
manufactured a byproduct chemical
substance. This situation may occur,
for example, when you are stripping a
chemical substance off of a part of the
article, and the stripping process
results in the formation of a different
chemical substance (possibly
resulting in a “used” stripping
solution).

•

If your byproduct’s only separate commercial
purpose “is for use by public or private
organizations that (1) burn it as a fuel, (2)
dispose of it as a waste, including in a
landfill or for enriching soil, or (3) extract
component chemical substances from it for
commercial purposes” (see 40 CFR
711.10(c)(1)), then that byproduct is
excluded from CDR reporting. This
exclusion applies only to the byproduct; it
does not apply to the component chemical
substances extracted from the byproduct.

•

If a byproduct substance listed in 40 CFR
711.10(c)(2) is produced as part of the listed manufacturing processes and meets these
circumstances: (1) is site-limited, (2) is recycled or otherwise used within a physically
enclosed system that is part of the same overall manufacturing process from which the
byproduct substance was produced, and (3) when the site is reporting a different chemical
substance that was manufactured from the recycled byproduct or manufactured in the
same overall manufacturing process, that byproduct is not required to be reported (40
CFR 711.10(c)(2)). The processes and related byproduct substances listed are:
o Portland Cement Manufacturing:
 CASRN 68475-76-3, Flue dust, portland cement (commonly referred to as
cement kiln dust or CKD)
o Kraft Pulping Process:
 CASRN 66071-92-9, Sulfite liquors and cooking liquors, spent (often
comprised of what is referred to as black liquor)
 CASRN 471-34-1, Carbonic acid calcium salt (1:1) (commonly referred to
as calcium carbonate)
Note that this exclusion only applies to the amount of the byproduct that is recycled in
physically enclosed equipment; it does not apply to amounts that are not recycled or that
are recycled, but not in physically enclosed equipment.

•

If the byproduct substance is manufactured solely in the specifically listed equipment
when it is not integral to the chemical manufacturing processes of the site, that byproduct
is not required to be reported (40 CFR 711.10(c)(3)). The specifically listed equipment
are:

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o Pollution control equipment, and
o Boilers used to generate heat or electricity for that site.

Figure 2-2. Decision Logic Diagram for Evaluating Whether a Byproduct Chemical
Substance is Subject to the CDR Rule

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Interpreting 40 CFR 711.10(c)(1)
In interpreting 40 CFR 711.10(c)(1), you should consider the following important points:
•

Regarding 40 CFR 711.10(c)(1)(i), note that where that same quantity of a byproduct is
burned as a fuel, and is also being burned for other non-exempt commercial purposes
(e.g., if the combustion residue is used as a process input), then the exemption under 40
CFR 711.10(c)(1)(i) would not apply. To provide a specific example: in a paper pulping
process, black liquor is burned to generate power, and it then undergoes a chemical
change to become manufactured smelt. The smelt is then used as a process input in the
manufacture of white liquor which is then returned to the pulping process. The
exemption under 40 CFR 711.10(c)(1)(i)
Is there a distinction for CDR
would not apply to the manufacture of the
byproduct reporting when a
black liquor because the black liquor’s postbyproduct is burned for fuel or
combustion commercial purposes may include
incinerated as a waste?
non-exempt commercial purposes. If meeting
the conditions described in 40 CFR
Any distinction between burning a
711.10(c)(2) and above, however, the portion
of the byproduct smelt that is used as a process byproduct as a fuel or incinerating it
as a waste is generally not relevant
input in the manufacture of white liquor may
under the CDR. This is because the
not require reporting. If a certain amount of
CDR exempts both byproducts whose
the black liquor was instead burned solely to
“only commercial purpose” is for
generate power and a separate amount was
burning as a fuel (40 CFR
used for a non- exempt commercial purpose,
711.10(c)(1)(i)), and byproducts that
the exemption under 40 CFR 711.10(c)(1)(i)
are “not used for commercial
would have applied only to the amount burned
purposes” (40 CFR 711.10(c)(4)(ii)).
solely to generate power. If the black liquor
This latter category would include
was instead incinerated solely for destruction,
incineration, solely for destruction.
the exemption under 40 CFR 711.10(c)(4)(ii)
would have applied.

•

Regarding 40 CFR 711.10(c)(1)(ii), although the manufacture of a byproduct is not
reportable if the byproduct is subsequently disposed of as a waste for purposes of
enriching the soil (e.g., to change the soil properties in a desirable way, such as by
serving as a filler to make the soil less dense or enhancing moisture retention), a
substance used as a fertilizer is not necessarily an excluded byproduct. For instance, if
the substance’s ordinary manner of use is as a fertilizer, then the substance is not a
byproduct in the first place, and the provisions at 40 CFR 711.10(c)(1) are inapplicable.

•

Regarding 40 CFR 711.10(c)(1)(iii), individual component chemical substances
extracted from a byproduct are reportable substances if they are extracted for a
commercial purpose, even if the manufacture of the byproduct itself is not reportable
pursuant to 711.10(c)(1).
A “component chemical substance” means a chemical substance that already exists in the
byproduct. If the recycling process involves breaking chemical bonds or forming new
chemical bonds to convert a chemical substance in the byproduct into a different
chemical substance (which is then extracted), then the recycling process does not count
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as extracting a component chemical substance of the byproduct. Note: In circumstances
where other substances in the byproduct are chemically reacted in order to facilitate the
separation of a desired component chemical substance, such that the component
chemical substance itself is not chemically changed before being extracted, then the
process does constitute an extraction of the unchanged component chemical substance.
Interpreting 40 CFR 711.10(c)(2)
points:
•

In interpreting section 40 CFR 711.10(c)(2), you should consider the following important
Manufacturers would be exempted from the need to report the listed byproduct
substances only for the volumes of the byproduct substance that are:
o recycled or otherwise used to manufacture another chemical substance within an
enclosed system, within the same overall manufacturing process, and on the same
site as that byproduct was originally manufactured and
o when the site is reporting under CDR a different chemical substance that was
manufactured from the byproduct or manufactured in the same overall
manufacturing process.
Volumes that are used for a commercial
purpose distinct from their manufacture
as a byproduct, such as when directly
incorporated into already manufactured
Portland Cement or removed for some
use outside of the Kraft pulping process,
remain reportable. Also, volumes that
are removed from the enclosed systems,
such as those that are stored in an open
tank or pit, or stored in any nonconnected tank or vessel, are excluded
from this exemption and remain
reportable.

•

What is reported if only part of my
byproduct meets the byproduct
exemption?
The volume of cement kiln dust (CKD)
that is manufactured as a byproduct may
be recycled in a manner that meets the
exemption in 40 CFR 711.10(c)(2) and
used for a separate commercial purpose,
for example as an additive to Portland
Cement. In this situation, the volume that
meets the exemption would not be reported
under CDR but the volume that is used as
an additive to Portland Cement would be
reported (as long as it meets other
requirements, such as production volume).

For the purposes of CDR, EPA
considers an enclosed system to be a
system of equipment directly connected
to the production process that is designed, constructed, and operated in a manner which
prevents emissions, hence exposures to workers, or the release of any chemical substance
into the facility or environment during the production process. For such systems,
exposure and release could only occur due to loss of integrity or failure of the
manufacturing process equipment or control systems.
Any equipment that the byproduct is present in at any point during the process sequence,
such as tanks, reaction vessels, reactors, processing units (e.g., a drum filter), and/or
connecting lines, must: (a) be of high structural integrity and contained on all sides, (b)
pose no foreseeable potential for escape of constituents to the facility or environment
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during normal use, and (c) be connected directly by pipeline or similarly enclosed device
to a production process. Also, any transfers or holding steps occurring in this system
must be necessary to the recycle process and must take place within physically enclosed
equipment that meet the aforementioned criteria. For example, hard piping or completely
sealed (i.e. welded) equipment would meet these criteria if connected directly to other
enclosed equipment, preventing potential releases including fugitive emissions.
Interpreting 40 CFR 711.10(c)(3)
points:

In interpreting section 40 CFR 711.10(c)(3), you should consider the following important

•

Integral processes: An integral process is the portion of the manufacturing process that is
chemically necessary or provides primary operational support for the production of the
intended product.
o Byproducts manufactured in equipment that is integral to the production
processes remain subject to reporting under CDR, unless otherwise exempted.
o For example, utilities that produce electricity as a product may be using boilers as
part of their production of electricity, and therefore those boilers are considered
equipment integral to the production process. Thus, byproducts produced by
these electric utility boilers would continue to be subject to reporting.
o Another example, reverberatory furnaces, which may function similarly to some
boilers, can have a chemical processing function such as smelting. This and
similar equipment, when used in such scenarios, would be considered integral to
the main production process and any resultant manufactured byproduct
substances would continue to be subject to reporting.

•

Non-integral processes: For the purposes of this exemption, certain associated processes
that are not chemically required to produce the intended product would be considered
non-integral. For example, such processes could include ones required due to other
regulations. Byproducts manufactured due to the use of pollution control equipment and
boilers that generate heat or electricity on-site, when such equipment is not part of the
main production process, are exempted from reporting under CDR.
o Examples of non-integral pollution control equipment include flue gas
desulfurization (FGD) and selective catalytic reduction (SCR) systems. If a
byproduct substance produced from this equipment is recycled for a commercial
purpose subsequent to its manufacture, the byproduct would be exempted from
reporting under CDR.

•

The exemption is limited to the byproduct itself. If the byproduct is subsequently used to
manufacture a different chemical substance, the subsequent chemical substance is subject
to reporting under CDR.

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General discussion about byproducts
You should note that your byproduct may have a separate commercial purpose even if
you do not intentionally commercialize it. You may be sending the byproduct, which you
consider a waste, to another person or site. If that other person or site uses your byproduct in
such a manner that it has a commercial purpose, then you are potentially required to report the
byproduct for purposes of CDR (assuming you meet other reporting requirements such as
production volume and the chemical substance is not otherwise exempted from reporting).
It is important to properly identify your byproduct chemical substance. Byproducts are
formed by a reaction, and, generally, EPA considers each combination of substances resulting
from a reaction to be either:
1. A mixture, composed of two or more well-defined chemical substances to be named and
listed separately; or
2. A reaction product, or combination of chemicals from a reaction, to be listed as a single
chemical substance, using one name that collectively describes the products or the
reactants used to make the products. This type of byproduct is typically complex.
Complex byproducts can be identified as a single chemical substance that represents the
process stream. Complex chemical substances are listed on the TSCA Inventory as chemical
substances of Unknown or Variable composition, Complex reaction products and Biological
materials (“UVCB” chemical substances). In such cases, you should not determine the volumes
of the individual chemical components or species that comprise the UVCB chemical substance;
rather, a single UVCB chemical substance name is proper for the chemical and the volume of
the UVCB substance as a whole entity should be used. Further information on UVCB chemical
substances is available on the EPA website at www.epa.gov/tsca-inventory/chemical-substancesunknown-or-variable-composition-complex-reaction-products-and .
Although complex byproducts may be named as a single UVCB chemical substance, in
certain circumstances it may be appropriate to treat a product combination as a mixture of
chemical substances or even just a single well-defined chemical substance, even though there are
uncharacterized components to the mixture. Specifically, where the submitter has a factual basis
to reasonably conclude that the uncharacterized components are exempt from CDR irrespective
of their chemical identity, a lack of information about the chemical identity of those exempt
components is not an obstacle to treating the remainder of the product combination as a mixture
for CDR purposes. Thus, for example, where a submitter reasonably concludes (after
considering all the facts known and reasonably ascertainable) that the uncharacterized
components of a byproduct will not be used for commercial purposes after they are manufactured
(or if the only commercial purpose is for one of the uses listed in 40 CFR 711.10(c)(1)), for CDR
purposes the submitter may treat the byproduct as the remaining component, or as a mixture of
the remaining components. The submitter then considers the need to report for the remaining
component(s).
By contrast, where a submitter has not characterized certain components of a product
combination or byproduct stream and lacks the basis to conclude that those components are
necessarily exempt from CDR, it is not appropriate to treat that product combination or
byproduct stream as a mixture. For example, if a submitter cannot reasonably assess whether an
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uncharacterized fraction of its byproduct will be subsequently used for a commercial purpose, it
is likely that the submitter will need to treat that byproduct as a single UVCB chemical substance
for CDR purposes.
Below are a few examples describing byproduct reporting. Additional information about
byproduct reporting under CDR is provided on the CDR website at www.epa.gov/cdr.
Example 2-1. For example, a manufacturing process involving the use of solvent A results
in spent solvent A. Depending upon the specific manufacturing scenario, there are two
different ways that the manufacturer could characterize spent solvent A. How the reclaimed
solvent A is reported is dependent upon the manufacturer’s characterization for TSCA.
1. Spent solvent A is characterized as a mixture of individual chemical substances: In
this case, separating solvent A from the mixture is not considered manufacturing,
and the manufacturer does not report for CDR purposes the recycled solvent A.
Note that, depending upon what is done with the remaining portion of the mixture,
any components of the mixture that were manufactured may need to be individually
reported.
2. Spent solvent A is characterized as a manufactured UVCB chemical substance: In
this case, the solvent A extracted from the spent solvent A is also considered to be
manufactured, and therefore is reportable for purposes of CDR. In this situation, the
UVCB chemical substance itself may be exempt for purposes of CDR. (40 CFR
711.10(c)(1)(iii))
A byproduct that is manufactured for a commercial purpose and, after manufacture, is
used for a separate commercial purpose, may be excluded from reporting under CDR by 40 CFR
711.10(c)(1)(ii). 40 CFR 711.10(c)(1)(ii) states that if the byproduct’s only commercial purpose
is for use by public or private organizations that dispose of it as a waste, including in a landfill or
for enriching soil, the byproduct is exempt from being reported under CDR.
Examples 2-2 and 2-3 describe manufacturers that may be subject to RCRA requirements
and how the 711.10(c)(1)(ii) byproduct exemption applies in these circumstances.

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Example 2-2. Company ABC manufactures a byproduct. The byproduct does not qualify
as a RCRA hazardous waste and does not meet the requirements of any exemption in 40
CFR 261.4. The manufacturer wishes to dispose of the byproduct, which can be used to
enrich soil (e.g., to change the soil properties in a desirable way to make the soil less dense
or enhancing moisture retention). Company ABC provides this byproduct to another
person who then disposes of it as a waste by spreading it on land to enrich the soil. If this
disposal of the byproduct is the byproduct’s sole commercial use, the byproduct qualifies
for the CDR reporting exemption under 40 CFR 711.10(c)(1)(ii). Company ABC is not
subject to reporting under the CDR, respecting the manufacture of its byproduct.

Example 2-2. Company ABC manufactures Byproduct X in a manner that does not
meet the exemption in 40 CFR 711.10(c)(3). Byproduct X is not considered a RCRA
solid waste because it serves as a feedstock to produce a zinc fertilizer and meets the
requirements of 40 CFR 261.4(a)(20) (i.e., it is a hazardous secondary material used to
make zinc fertilizers). The zinc fertilizer that is produced meets the requirements of 40
CFR 261.4(a)(21). Byproduct X is not being disposed of as a waste and therefore does
not meet the CDR byproduct exemption at 40 CFR 711.10(c)(1)(ii). Company ABC is
subject to reporting under the CDR, respecting the manufacture of its byproduct.

If your byproduct is manufactured (including imported) for commercial purposes, and it
is subsequently put to use for a commercial purpose other than those listed in 40 CFR
711.10(c)(1), you may be required to report this chemical substance and should evaluate
Question B on Figure 2-1 (see also Section 2.1.2).
2.1.1.4 Impurities
An impurity is a chemical substance which is unintentionally present with another
chemical substance (40 CFR 704.3). Although impurities may be produced for the purpose of
obtaining a commercial advantage because they are part of the manufacture of a chemical
product for a commercial purpose, they are not manufactured for distribution in commerce as
chemical substances per se and have no commercial purpose separate from the chemical
substance, mixture, or article of which they are a part. Thus, a chemical substance that is
manufactured or imported solely as an impurity is not subject to the CDR reporting
requirements. See 40 CFR 711.10(c)(4)(i).
2.1.2

Is Your Chemical Substance on the TSCA Inventory? (Question B)

The following subsections provide information to help you determine whether your
chemical substance is listed on the TSCA Inventory.

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2.1.2.1 What is the TSCA Inventory?
Authorized by section 8(b) of TSCA, the TSCA Inventory is a list of chemical substances
manufactured (including imported) for commercial purposes in the United States. The TSCA
Inventory was compiled originally in the late 1970s; chemical substances have been added
continually through EPA’s New Chemicals Program. During 2017 and 2018, EPA worked with
companies, using the TSCA Inventory Notification (Active-Inactive) rule, to divide the
Inventory into “active” and “inactive” lists. EPA keeps a Master Inventory File, which is the
authoritative list of all the chemical substances reported to EPA for inclusion on the TSCA
Inventory, and which includes the active and inactive designations. Information on how to access
the non-confidential portion of the TSCA Inventory file, commonly referred to as the “public
TSCA Inventory,” is available at www.epa.gov/tsca-inventory. The public TSCA Inventory
contains chemical substances for which the identity is not considered confidential and the
generic identification of chemical substances for which the specific identity has been claimed as
TSCA Confidential Business Information (CBI). The TSCA Inventory status of chemical
substances can also be determined from EPA’s Substance Registry Services (SRS), available at
www.epa.gov/srs. See Section 2.1.3 for information about chemical substances that may be
potentially exempt from reporting.
2.1.2.2 How Do You Determine Whether a Chemical Substance is Listed on the TSCA
Chemical Substance Inventory?
The following methods may help you determine whether your chemical substance is
listed on the TSCA Inventory:
•

Locate the chemical substance on the public section of the TSCA Inventory (see Chapter
5 for information on obtaining the TSCA Inventory);

•

Search SRS for information on the TSCA Inventory listing status (note that you can
search the SRS directly by accessing the website at www.epa.gov/srs or by using the
CDR reporting tool);

•

Search company records to determine whether the chemical substance was
previously reported to EPA under CDR;

•

Search company records for a commenced PMN or other communication with EPA that
confirmed the chemical substance was on the TSCA Inventory;

•

Search company records for a Notice of Commencement of manufacture or import for a
PMN substance that was submitted to EPA; and

•

Search company records for a Notice of Activity submitted to EPA to move a chemical
from the inactive to the active portions of the TSCA Inventory.

Searching for previous CDR, PMN, and NOC submissions may be particularly helpful if
your chemical substance is listed on the confidential portion of the TSCA Inventory.
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Several commercial databases have incorporated the public section of the TSCA
Inventory (which excludes chemical substances with confidential identities) and can indicate
whether a given chemical substance is listed on that portion of the TSCA Inventory. Because
these databases are not generated or reviewed by EPA, the Agency cannot guarantee the
accuracy of the information. If you use a commercial database that fails to include all reportable
chemical substances and, as a result, you fail to report information for these chemical substances,
you may be in violation of TSCA (40 CFR 711.1(c)).
The CDR reporting related to mixtures and UVCB substances (chemical substances that
are of Unknown or Variable composition, Complex reaction products, or Biological materials)
requires careful consideration by submitters. Whenever a submitter has manufactured or
imported a combination of several chemicals, the
submitter must first determine whether for TSCA
Hydrates are mixtures of the
purposes it is a mixture or a single UVCB or other
corresponding non-hydrated chemical
indefinitely described (Class 2) chemical substance.
substance and water and, therefore,
A mixture is any combination of chemicals that meets
are not listed on the TSCA Inventory.
the statutory definition of “mixture” at TSCA section
Note that you may be required to
3(10). (See Appendix A). Mixtures are not reported to report the corresponding nonCDR – rather the mixture’s component chemical
hydrated component chemical
substances, the chemical substances that make it up,
substance. Adjust the reported
are potentially subject to reporting, as described
production volume to exclude water.
below. A UVCB substance is an indefinite
combination of chemicals, that does not meet the
statutory definition of “mixture” at TSCA section 3(10), whose number and individual identities
and/or composition are not precisely or completely known. A UVCB combination of chemicals
is subject to reporting under CDR and is considered a single chemical substance. Generally, the
determination of whether a combination of chemicals is a mixture or a UVCB substance is made
by the time that substance has been commercialized and, as such, would be clear early in the
CDR process. The following discussion is presented with this generality in mind.
•

If you imported a mixture, you will need to report the individual chemical components of
the mixture to the extent that your total volume for the individual chemical substance
triggers reporting (i.e., generally, to the extent that such volume reaches the reporting
threshold, 25,000 lb or 2,500 lb if the subject of certain TSCA actions).

•

If you domestically manufactured a mixture, you will need to determine whether any
chemical substances were formed from a chemical reaction that occurred as part of
manufacturing the mixture. If a chemical reaction has occurred, a chemical substance
formed from the chemical reaction may be subject to reporting, based on its production
volume or the applicability of other exemptions. If a chemical reaction has not occurred,
you have not manufactured any reportable chemical substances in the production of the
mixture. In such a case, the production of the mixture has not triggered any CDR
reporting requirement.

•

Domestic manufacturers and importers should also consider whether the combination of
the chemicals they have domestically manufactured or imported (respectively) should be
chemically identified for TSCA purposes as a single UVCB chemical substance instead
of a mixture.
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EPA has developed two Inventory nomenclature guidance documents related to the mixtureUVCB determination:
•

Toxic Substances Control Act Inventory Representation for Chemical Substances of
Unknown or Variable Composition, Complex Reaction Products and Biological
Materials: UVCB Substances. Available online at:
www.epa.gov/sites/production/files/2015-05/documents/uvcb.pdf ;

•

Toxic Substances Control Act Inventory Representation for Combinations of Two or
More Substances: Complex Reaction Products. Available on-line at:
www.epa.gov/sites/production/files/2015-05/documents/rxnprods.pdf

Example 2-3. Company X manufactures 100,000 lb of magnesium sulfate heptahydrate,
which is considered under TSCA to be a mixture of magnesium sulfate and water. The nonhydrous portion of the magnesium sulfate heptahydrate mixture, magnesium sulfate,
constitutes 48,838 lb, which exceeds the 25,000 lb threshold. Therefore, Company X is
required to report 48,838 lb of magnesium sulfate under the CDR rule.
In the event that you are not able to find your chemical substance on the TSCA
Inventory, contact the TSCA Hotline at (202) 554-1404 for assistance to determine whether
reporting is required. If your chemical substance is on the TSCA Inventory, you should review
Question C on Figure 2-1 (Section 2.1.3) to determine whether you qualify for any other
reporting exemptions.
2.1.3

Is Your Chemical Substance Potentially Exempt from Reporting? (Question C)

Five groups or categories of chemical substances, though included on the TSCA
Inventory, are largely exempt from reporting under the CDR rule. These groups are polymers,
microorganisms, naturally occurring chemical
substances, water, and certain forms of natural
Polymers, microorganisms, water,
gas. Sections 2.1.3.1 through 2.1.3.5 provide
and certain forms of natural gas are
more details for each group of chemical
not exempted from reporting when
substances. You may also refer to 40 CFR
they are the subject of any certain
711.6(a) for precise definitions of these groups.
TSCA actions. See Section 2.1.4 for
Note, however, that these exempted chemical
more details.
substances (except for chemical substances that
are exempted because they are naturally occurring) become subject to reporting again if they are
the subject of any of certain TSCA actions. Section 2.1.4 provides details for when the
exemption does not apply. Note that the act of importing does not change the identity of a
chemical substance or group. For example, a naturally occurring chemical substance remains
naturally occurring when it is imported.
To help identify chemical substances that are exempt from reporting under the CDR rule,
EPA has labeled most of these chemical substances on the TSCA Inventory with the letters
“XU.” In the SRS, most of these chemical substances are identified as being “TSCA CDR
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Exempt” under the Statutes/Regulations heading. This and other flags are embedded into the
Substance Registry Services (SRS) chemical lookup within the current edition of e-CDRweb
reporting tool and have been updated to reflect the 2020 reporting requirements. When the
chemical lookup function is used, and the selected chemical has been assigned a special flag, the
reporting tool will display a notice on the screen indicating the exemption status of the chemical.
Please note that you are advised to use the flags only as a guide; you are responsible for verifying
whether a chemical substance listed on the TSCA Inventory is exempt from reporting.
If your chemical substance is not in one of the following five categories of chemical
substances, it is a CDR reportable chemical substance and you should review Step II of the
reporting requirements (Section 2.2, Figure 2-3). If your chemical substance is in one of the five
categories, you should review Question D (Section 2.1.4).
2.1.3.1 Polymers
Polymers are in most cases exempt from CDR reporting. The CDR definition of polymer
is sufficiently broad to include virtually all those chemical substances that are generally
considered polymers. The definition also includes siloxanes and silicones, silsesquioxanes,
rubber, lignin, polysaccharides (such as starch and gums), proteins (such as gelatin and
hemoglobin), and enzymes. However, for chemical substances that result from hydrolysis,
depolymerization, or chemical modification of polymers, regardless of the extent of these
processes, if the final products are no longer polymeric (e.g., a mixture of amino acids that is the
result of hydrolysis of a polypeptide), the chemical substances are not considered to be polymers
and must be reported if not otherwise excluded (40 CFR 711.6(a)(1)). See Appendix A or 40
CFR 711.6(a)(1) for the specific definition of polymers for purposes of the CDR rule.
2.1.3.2 Microorganisms
Microorganisms are exempt from CDR reporting. A microorganism is any combination
of chemical substances that is a living organism and that meets the definition of
“microorganism” at 40 CFR 725.3. Any chemical substance produced from a living
microorganism is reportable unless otherwise excluded (40 CFR 711.6(a)(2)).
2.1.3.3 Certain Forms of Natural Gas
Table 2-1 identifies certain forms of natural gas that are exempt from CDR reporting (see
40 CFR 711.6(a)(4)).
Table 2-1. Chemical Substances Covered by the Exemption for
Certain Forms of Natural Gas
Form of Natural Gas

CAS Registry Number

Natural gas (petroleum), raw liquid mix

64741-48-6

Natural gas condensates

68919-39-1

Gasoline natural

8006-61-9

Gasoline (natural gas), natural

68425-31-0

Natural gas

8006-14-2

Natural gas, dried

68410-63-9

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2.1.3.4 Naturally Occurring Substances
Chemical substances that are described in 40 CFR 710.4(b) of the TSCA Inventory
Reporting Regulations are considered “naturally occurring.” Such chemical substances are not
reportable under CDR if the chemical substance is produced solely by means described in
section 710.4(b). Examples of chemical substances that are typically naturally occurring
materials are raw agricultural commodities, water, air, crude oil, rocks, ores, and minerals.
However, because the section 710.4(b) exemption is process-specific rather than chemicalspecific, if you manufacture any chemical substance in a manner other than just as described in
section 710.4(b), you are required to report it unless it is otherwise exempted (40 CFR
711.6(a)(3)). For this reason, minerals and certain agricultural products are sometimes
considered not to be naturally occurring because of the means by which they are produced or
isolated. Whether a chemical substance is considered “naturally occurring” depends on the
manner in which it is produced and isolated. Table 2-2 presents some examples of evaluating
chemical substances for the naturally occurring chemical substance exemption.
Table 2-2. Examples of Evaluating Chemical Substances for the Naturally Occurring
Exemption (40 CFR 711.6(a)(3))


Calcined clays formed by heating naturally occurring clay typically must be reported because such heating is
generally not done solely to remove water; a chemical change is primarily intended.



Chemical substances that are removed/isolated from nature by physical or natural means are typically
considered to be “naturally occurring.” Using water to extract a chemical substance from a naturally occurring
chemical substance is considered a natural means of removal. However, using any other solvent is not
considered a natural means of removal and would result in the extracted chemical substance being potentially
subject to reporting.



In an electrostatic separation, small particles are removed from a liquid or gas stream. The process is
essentially analogous to gravitational separation. Chemical substances that are processed by this means are
considered to be “naturally occurring.”



Mined coal is typically included in the naturally occurring chemical substances category.



Ammonia and nitric acid are generally produced by chemical synthesis and are, therefore, generally not
considered to be “naturally occurring.”

2.1.3.5 Water
Water, including both naturally occurring water and manufactured water (CASRN 7732
18-5), is exempt from CDR reporting.
2.1.4

Is your Chemical Substance Ineligible for an Exemption Because it is the Subject of
Certain TSCA Actions? (Question D)

With the exception of naturally occurring chemical substances, chemical substances must
be reported if they are the subject of any of the following (even if the chemical substance is
otherwise exempt, (40 CFR 711.6)):
•
•
•

A rule proposed or promulgated under TSCA section 4, 5(a)(2),5(b)(4), or 6;
An order issued under TSCA section 4, 5(e) or 5(f);
Relief that has been granted under a civil action under TSCA sections 5 or 7; or
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•

Reporting Requirements

An enforceable consent agreement (ECA) under 40 CFR Part 790.

See Appendix B for an overall chart that describes the effects on CDR requirements of
the different TSCA actions.
Example 2-4. Company A manufactured 35,000 lb of Chemical X, a polymer, in 2018.
Chemical X is part of an enforceable consent agreement (ECA) between EPA and Company
A, in which Company A is performing additional testing on Chemical X. Although Chemical
X is a polymer that normally would be exempt from CDR reporting, it is part of an ECA and,
thus, Company A is required to report Chemical X for the 2020 CDR. Additionally,
Company B manufactures 40,000 lb of Chemical X in 2019. Although Company B is not a
party to the ECA, Company B is also required to report Chemical X for the 2016 CDR.
Special flags are used throughout the TSCA Inventory to identify those substances on the
Inventory that are the subject of an EPA rule or order promulgated under TSCA, as well as to
indicate the types of full or partial exemptions from TSCA reporting requirements. These flags
are embedded into the Substance Registry Services (SRS) chemical lookup within the current
edition of e-CDRweb reporting tool and have been updated to reflect the 2020 reporting
requirements. When the chemical lookup function is used, and the selected chemical has been
assigned a special flag, the reporting tool will display a notice on the screen indicating the TSCA
action or exemption status of the chemical. Please note that you are advised to use the flags only
as a guide; you are responsible for verifying whether a chemical substance listed on the TSCA
Inventory is exempt from reporting or ineligible for exemption from reporting. If you have
determined that your chemical substance is a CDR reportable chemical substance, evaluate Step
II on Figure 2-3 to determine whether you are a manufacturer (including importer) who is
required to report.

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2.2 Step II: Are You a Manufacturer Who Is Required to Report?
If you determined from Step I that you manufacture (including import) a CDR reportable
chemical substance, Figure 2-3 presents a decision logic diagram that may help you determine
whether you are a manufacturer (including importer) who must then report. The following
subsections explain each question in greater detail.

Figure 2-3. Decision Logic Diagram for Evaluating Step II

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Reporting Requirements

Did You Manufacture (Including Import) 25,000 lb or More of the Chemical
Substance at a Single Site During any of the Calendar Years since the Last Principal
Reporting Year? (Question E)

You are subject to CDR reporting if you manufactured (including imported) a chemical
substance in production volumes of 25,000 lb or greater at any single site you owned or
controlled during any calendar year since the last CDR principal reporting year. (A reduced
reporting threshold of 2,500 lb applies to chemical substances subject to certain TSCA actions see Section 2.2.2.) For the 2020 CDR, the last principal reporting year was 2015. Therefore, you
need to consider production for calendar years 2016, 2017, 2018, and 2019. If you both
domestically manufacture and import the same chemical substance, add the domestically
manufactured and imported volumes at each site for a calendar year to determine whether the
amount of the chemical substance meets or exceeds the 25,000 lb threshold during that calendar
year. Do not subtract the volume of chemical substance directly exported. The site at which a
chemical substance is imported is described in 40 CFR 711.3 and Section 4.4.1 of this document.
Information about determining production volumes for mixtures and when reporting in
categories is provided at the end of Section 2.2.2.
2.2.2

Did You Manufacture (Including Import) 2,500 lb or More of the Chemical
Substance (if it is the Subject of Certain TSCA Actions? (Question F)

Under 40 CFR 711.8(b) and 40 CFR 711.15, the reporting threshold is 2,500 lb (1,134
kg) for any person who manufactured a chemical substance that is the subject of any of the
following TSCA actions:
•
•
•

A rule proposed or promulgated under
TSCA section 5(a)(2), 5(b)(4) or 6
An order issued under TSCA section
5(e) or 5(f)
Relief that has been granted under a
civil action under TSCA section 5 or 7

Substances that have undergone a change in
TSCA regulatory status from 2016 to June 1,
2020
•

See Appendix B for assistance in
determining whether your chemical substance
is the subject of certain TSCA actions.
You are subject to CDR reporting if you
manufactured (including imported) a chemical
substance which is subject to a TSCA action
listed above in production volumes of 2,500 lb
or greater at any single site you owned or
controlled during any calendar year since the
last CDR principal reporting year. For the 2020
CDR, the last principal reporting year was
2015. Therefore, you need to consider
production for calendar years 2016, 2017,
2018, and 2019. If you both domestically

•

The effects of TSCA actions on CDR
reporting are assessed based on the status of
the chemical substance as of the beginning of
the submission period, when the reporting
obligation becomes current. For reporting
obligations in 2020 that depend on whether a
chemical substance “is the subject of” a listed
action, consider the status of a chemical
substance as of June 1, 2020.
A change in TSCA regulatory status does not
mean that submitters should apply different
reporting thresholds to manufacture occurring
before and after the effective date of the
action. Only one reporting threshold applies to
a chemical substance for the 2020 CDR. The
correct reporting threshold is determined
based on the chemical substance’s status as of
June 1, 2020.
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manufacture and import the same chemical substance, add the domestically manufactured and
imported volumes at each site for a calendar year to determine whether the amount of the
chemical substance meets or exceeds the 2,500 lb threshold during that year. Do not subtract the
volume of chemical substance directly exported. The site at which a chemical substance is
imported is described in 40 CFR 711.3 and Section 4.4.1 of this document.
Table 2-3 provides examples of how the production volume threshold applies.
Table 2-3. Production Volume Threshold Examples
Description

2020 Reporting Requirement

Company A, which has only one manufacturing site,
manufactured 26,000 lb of Chemical X, which is not
exempt from reporting, at its site in 2017.

Company A must report for Chemical X because
it manufactured 25,000 lb or more of Chemical X
at its sole manufacturing site in 2017.

Company B, which has only one manufacturing site,
manufactured 26,000 lb of Chemical X at its site in 2016
and 20,000 lb of Chemical X in 2018.

Company B is required to report for Chemical X
because it manufactured more than 25,000 lb of
Chemical X in 2016.

Company C has two manufacturing sites for Chemical X.
In 2016 through 2019, Site 1 manufactured 13,000 lb per
year of Chemical X and Site 2 manufactured 15,000 lb
per year. Chemical X is not the subject of any of the
TSCA actions listed in 40 CFR 711.8(b).

The 25,000-lb threshold is applicable for Chemical
X. Company C is not required to report for
Chemical X at either site because production was
less than 25,000 lb at each site during all the years
in the reporting period.

Company D has two manufacturing sites for Chemical X.
In 2016 through 2019, Site 1 manufactured 10,000 lb per
year of Chemical X and Site 2 manufactured 150,000 lb
per year of Chemical X. Chemical X is not the subject of
any of the TSCA actions listed in 40 CFR 711.8(b).

The 25,000-lb threshold is applicable for Chemical
X. Company D must report for Chemical X at Site
2 because at this location production was 25,000 lb
or more. Company D is not required to report for
Chemical X for Site 1 because production was less
than 25,000 lb during all the years in the reporting
period.

Company E has one site where it imports and
manufactures Chemical X. Company E manufactured
21,000 lb of Chemical X and imported 5,000 lb of
Chemical X in 2019.

Company E must report for Chemical X because
the aggregate volume manufactured at and
imported by its site in 2019 was 25,000 lb or more.

Company F has one site where it manufactured 30,000 lb
of Chemical X in 2016. The company directly exported
25,000 lb of Chemical X and sold the remaining 5,000 lb
in the United States.

Company F must report for Chemical X because
it manufactured over 25,000 lb in 2016. The
amount directly exported does not affect the
determination of the need to report.

Company G manufactured 5,000 lb of Chemical Z per year
during 2016 through 2019. Chemical Z is subject to a TSCA
section 4 test rule with a sunset date of June 30, 2020.
Chemical Z is not the subject of any of the TSCA actions
listed in 40 CFR 711.8(b).

Company G is not required to report for Chemical
Z. Chemical Z is subject to the 25,000 lb
reporting threshold, because a TSCA section 4
test rule is not a TSCA action which triggers use
of the reduced reporting threshold (i.e., it is not
one of the actions listed in 40 CFR 711.8(b)).

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Description

2020 Reporting Requirement

A TSCA section 5(a)(2) significant new use rule (SNUR) is
issued for Chemical Y in 2017. The annual production
volumes for Chemical Y by Company H are 1,000 lb in
2016, 10,000 lb in 2017, 5,000 lb in 2018, and 2,000 lb in
2019.

As of the beginning of the submission period
(June 1, 2020), Chemical Y is a chemical
substance that is the subject of a TSCA section
5(a)(2) SNUR; therefore, a reduced reporting
threshold of 2,500 lb would apply. Because the
2,500 lb reporting threshold was exceeded at least
once from 2016 to 2019, Company H must report
for Chemical Y.

A TSCA section 5(a)(2) SNUR was issued for Chemical Y
in 2017 and revoked in February 2020. Chemical Y is not
currently the subject of any of the TSCA actions listed in 40
CFR 711.8(b). The annual production volumes for Chemical
Y by Company H are 1,000 lb in 2016, 10,000 lb in 2017,
5,000 lb in 2018, and 2,000 lb in 2019.

As of the beginning of the submission period on
June 1, 2020, the SNUR is no longer in effect.
Therefore, the reporting threshold for Chemical Y
is 25,000 lb. Because the production volume did
not meet or exceed 25,000 lb in at least one year
from 2016 to 2019, Company H is not required to
report for Chemical Y.

A proposed TSCA section 5(a)(2) SNUR for Chemical P is
published in the Federal Register on August 1, 2020.
Chemical P is not currently the subject of any of the other
TSCA actions listed in 40 CFR 711.8(b). The annual
production volumes for Chemical P by Company J are
2,000 lb in 2016, 20,000 lb in 2017, 2,500 lb in 2018, and
12,000 lb in 2019.

As of the beginning of the 2020 submission
period on June 1, 2020, Chemical P is not the
subject of a proposed or promulgated SNUR.
Therefore, the 2020 CDR reporting threshold for
Chemical P is 25,000 lb. Publication of the SNUR
after June 1, 2020 would not cause the 2020 CDR
reporting threshold to change during the 2020
submission period. Because the production
volume did not meet or exceed 25,000 lb in at
least one year from 2016 to 2019, Company J is
not required to report for Chemical P.

Meeting the Reporting Threshold for Chemical Substances in Mixtures
In many cases, reportable chemical substances are components of a mixture. Although
mixtures themselves are not reportable, the 25,000 lb (or 2,500 lb threshold if the subject of
certain TSCA actions) is applicable for each CDR reportable chemical substance comprising a
mixture; therefore, the chemical substances making up a mixture may individually be reportable.
If you manufacture chemical substances as part of a mixture, you would determine your CDR
reporting requirements by following Questions A-F (Sections Error! Reference source not
found. through 2.2.2) for each chemical substance in the mixture. As described in Section
2.1.2.2, hydrates are mixtures of the corresponding non-hydrated chemical substance and water.
UVCB Chemical Substances: Note that, under TSCA, a complex combination of
chemical substances is in most cases considered to be a single UVCB chemical substance. In
such cases, reporting is triggered based on the volume of the UVCB chemical substance
manufactured (that is, the whole entity), and not based on the volume of individual chemical
components which may be present in the UVCB chemical substance. See Section 2.1.1.3 for
further discussion of UVCB chemical substances.
Imported Mixtures: As an importer (see 40 CFR 704.3) of a mixture of chemical
substances listed on the TSCA Inventory, you must determine whether the individual component
chemical substances of a mixture are reportable. To do so, you would determine whether the
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annual aggregated volume of a particular reportable chemical substance was 25,000 lb or 2,500
lb or more at the site that controls the importation. The threshold volume is applicable for each
CDR reportable chemical substance in a mixture. You can determine the production volume for
each chemical substance in the mixture that you imported during a particular calendar year by
using the weight and percent composition of the chemical substance in the mixture. For each
imported chemical substance, you would aggregate the volume of the chemical substance in all
annual imports associated with the reporting site as defined in 40 CFR 711.3 and add the amount
of the chemical substance domestically manufactured at the same site, if any, to determine
whether the total volume of the chemical manufactured (including imported) meets the 25,000 lb
or 2,500 lb threshold. Note that a chemical substance that is imported solely in small quantities
for research and development, as an impurity, or as part of an article or in a manner described in
40 CFR 711.10(c)(1) through (4) is not subject to the CDR reporting requirements (40 CFR
711.10).
If you have determined that you are manufacturing a CDR reportable chemical substance
and meet the applicable reporting threshold of 25,000 lb (or 2,500 lb if subject to certain TSCA
actions), evaluate Question G to determine whether you qualify for a small manufacturer
exemption.
Meeting the Reporting Threshold when Reporting Inorganic Byproducts in Metal Categories
See the document Chemical Data Reporting (CDR) Support Document: Proposed
Optional Reporting in Metal Categories for Inorganic Byproducts for information on how to
determine if you are allowed to report by category and, if you are, how to determine if you meet
the reporting threshold when reporting multiple substances within a single category. Such
reporting is allowed only in limited circumstances, specifically for inorganic byproducts that
contain certain metals. See also Section 4.7.6.
2.2.3

Do You Qualify for a Small Manufacturer or Small Government Exemption?
(Question G)

Small manufacturer (the same standard will be used for all manufacturers, except for
small governments) (40 CFR 704.3):
(1) First standard. A manufacturer (including importer) of a substance is small if its total
annual sales, when combined with those of its parent company (if any), are less than $110
million. However, if the annual production or importation volume of a particular
substance at any individual site owned or controlled by the manufacturer or importer is
greater than 45,400 kilograms (100,000 lbs), the manufacturer (including importer) will
not qualify as small for purposes of reporting on the production or importation of that
substance at that site, unless the manufacturer (including importer) qualifies as small
under standard (2) of this definition.
(2) Second standard. A manufacturer (including importer) of a substance is small if its total
annual sales, when combined with those of its parent company (if any), are less than $11
million, regardless of the quantity of substances produced or imported by that
manufacturer (including importer).
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For purposes of the definition of a small manufacturer, total annual sales include all sales
of the company, not just the total sales of a given chemical substance.
Small government means the government of a city, county, town, township, village, school
district, or special district with a population of less than 50,000. States and tribal governments are
not considered small governments.
If you have determined that you are a small manufacturer or small government that is
manufacturing a CDR reportable chemical substance, evaluate Question H (described in the next
section) to determine whether you are exempt from any reporting.
If you do not qualify for a small manufacturer or small government exemption, evaluate
Question I in Figure 2-3 (further described in Section 2.2.5) to determine whether you qualify for
any other reporting exemptions.
2.2.4

Did You Manufacture a Chemical Substance that is the Subject of Certain TSCA
Actions? (Question H)

Small manufacturers and small governments are exempt from CDR requirements unless
they manufacture (including import) a chemical substance that is the subject of a rule proposed
or promulgated under sections 4, 5(b)(4), or 6 of TSCA, or is the subject of an order in effect
under section 4 or 5(e) of TSCA, or is the subject of relief that has been granted under a civil
action under sections 5 or 7 of TSCA (40 CFR 711.9 and TSCA § 8(a)(3)(A)(ii)). The SRS
provides information regarding which chemical substances fall into these groups. Table 2-4
provides examples of how the small manufacturing exemption applies.
Table 2-4. Small Manufacturer or Small Government Exemption Examples (40 CFR 711.9)
Description

2020 Reporting Requirement
Site 1 is not required to report for Chemical X
because combined sales in 2019 did not exceed
$11 million.

Site 1, which is one of several sites owned by Company A,
had a production volume of 120,000 lb of Chemical X in
2017. The total annual sales of Company A (all sites
combined) were $7.25 million in 2019.
Site 2, which is one of several sites owned by Company B,
had a production volume of 90,000 lb of Chemical X in
2016, 75,000 lb in 2017, 82,000 in 2018, and 95,000 in
2019. The total annual sales of Company B (all sites
combined) were $80 million in 2019. None of the other sites
produce Chemical X.

Site 2 is not required to report for Chemical X
because annual production volume of that chemical
substance did not exceed 100,000 lb at any of
Company B’s sites during 2016-2019, and
Company B had total annual sales of less than $110
million.

Site 3, which is one of several sites owned by Company C,
had a production volume of 200,000 lb per year of Chemical
X in 2016 through 2019. Site 4, another site owned by
Company C, had a production volume of 75,000 lb per year
of Chemical X in 2016 through 2019. The total annual sales
of Company C (all sites combined) were $90 million in
2019.

Company C must report for Chemical X at Site 3
because annual production volume at Site 3
exceeded 100,000 lb in at least one year from 2016
to 2019. Company C is not required to report for
Chemical X at Site 4 because annual production
volume at site 4 did not exceed 100,000 lb and total
annual sales was less than $110 million.

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Description

2020 Reporting Requirement

Site 5, which is one of several sites owned by Company D,
had a production volume of 50,000 lb of Chemical X in
2018. The total annual sales of Company D (all sites
combined) were $125 million in 2019.

Company D must report for Chemical X at Site 5
because total annual sales in 2019 exceeded $110
million and the production volume of Chemical X
at Site 5 exceeded 25,000 lb in at least one year
from 2016 to 2019.

Site 6, which is one of several sites owned by Company E,
had a production volume of 120,000 lb of Chemical X in
2016. The total annual sales of Company E (all sites
combined) were $7.25 million in 2019. Chemical X is
subject to a section 4 test rule.

Site 6 is required to report for Chemical X. Even
though combined sales are less than $11 million,
this chemical substance is subject to a test rule and
therefore must be reported.

Site 7, owned by Company F, whose total annual sales is $90
million in the principal reporting year (2019), manufactures
Chemical X, which is the subject of a TSCA section 5(e)
consent order and a TSCA section 5(a)(2) SNUR. The annual
production volume of Chemical X ranges between 3,000 and
5,000 lb from 2016-2019.

Site 7 is required to report for Chemical X. Based
on the sales of less than $110 million and
production volume below 100,000 lb, Company F
would qualify as a small manufacturer. Chemical X
being the subject of a SNUR does not affect the
small manufacturer exemption. However, Chemical
S being the subject of a 5(e) consent order does
affect the exemption: the small manufacturer
exemption does not apply to Company F with
respect to its manufacture of Chemical X.
Both the SNUR and the 5(e) consent order trigger
the reduced reporting threshold of 2,500 lb.
Therefore, because Chemical X is subject to a
SNUR and a section 5(e) consent order and because
Company F has produced Chemical X in amounts
above 2,500 lb in at least one year from 2016 to
2019 (in this case all four years), Company F would
be required to report.

Site 8 is owned by Company G and manufactured 25,000 lbs
of Chemical X in 2016 and 20,000 lbs in 2017. Chemical X
was the subject of a TSCA section 4 test rule promulgated in
2019. Company G’s total annual income was the following:
$1 million in 2016, $2 million in 2017, $9 million in 2018,
and $12 million in 2019.

Site 8 is required to report for Chemical X. On June
1, 2020, Chemical X is subject to a TSCA section 4
test rule, which means that Company G cannot
apply the small manufacturer exemption to its
manufacture of this substance.
Because annual production volume of Chemical G
was 25,000 lb or greater in at least one year from
2016 to 2019 (in this case in 2016), Company G
must report for Chemical X.

Site 9 is owned by Company H and manufactures Chemical
X. Chemical X has been subject for several years to a TSCA
section 4 test rule which sunsets on May 1, 2020. Company
H, whose total annual sales were $9 million in 2019, has
manufactured Chemical X in annual amounts above 25,000
lb from 2016-2019.

Company H is not required to report for Chemical
X. Although Chemical X was the subject of a TSCA
section 4 test rule (which could have eliminated the
ability to apply the small manufacturer exemption to
manufacture of Chemical X), June 1, 2020 is after
the sunset date. As of June 1, 2020, Chemical X is
no longer the subject of a TSCA section 4 test rule.
Therefore, Company H, with total annual sales less
than $11 million in 2019, would be eligible to apply
the small manufacturer exemption to its
manufacture of Chemical X.

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Description

2020 Reporting Requirement

Municipal utility 1 is owned by a US city containing a
population of 39,250. This utility produces 57,000 lb of
Chemical X in 2016 and approximately the same amount
in years 2017 through 2019.

Municipal utility 1 is not required to report under
CDR, because it is owned by a US city with a
population that does not exceed 50,000, and
therefore qualifies for the small government
exemption.

Public utility district 1 is owned by a US county containing
three separate townships, in 2016, one containing a
population of 8,300, the second containing a population of
33,600, and the third containing 10,850. The county had a
total population of 52,750 in 2016. The population
fluctuates in each township through 2019, but does not drop
below 50,000 total in any single year.

Public utility district 1 is required to report for any
chemicals meeting the reporting requirements.
Based on its 2019 population, it does not qualify
for the small government exemption as its
population is greater than 50,000.

Public utility district 2 is owned by a US county containing
three separate townships, in 2016 and 2017, one containing
a population of 26,550, the second containing a population
of 6,400, and the third containing 12,700 (total of 45,650 for
the county). In 2018, a fourth township containing a
population of 8,900 is added to the county, raising the total
population that the utility district services to 54,550. The
population fluctuates in each township through 2019, but
does not drop below 50,000 total.

Public utility district 2 is required to report for any
chemicals meeting the reporting requirements.
Although it would have qualified for the small
government exemption in 2016 and 2017, its
population grew and exceeded the 50,000
population threshold for 2019, the principal
reporting year. The public utility is required to
consider reporting based on the annual production
volume during each years of the reporting cycle
(2016-2019).

2.2.5

Do You Qualify for Any Other Reporting Exemptions? (Question I)

If you manufacture a reportable chemical substance under the following circumstances,
you are not required to report for those chemical substances under the CDR rule if:
•

The chemical substance is manufactured solely in small quantities for research and
development (40 CFR 711.10(a)).
Chemicals that are routinely used in a laboratory are not considered to be chemicals used
for research and development for purposes of this exemption. For example, a
manufacturer of a solvent that supplies testing labs for the routine use of testing samples
of other materials is not conducting research and development.

•

The chemical substance is imported as part of an article (40 CFR 711.10(b)). An article is
defined in 40 CFR 704.3 as “a manufactured item (1) which is formed to a specific shape
or design during manufacture, (2) which has end-use function(s) dependent in whole or in
part upon its shape or design during end use, and (3) which has either no change of
chemical composition during its end use or only those changes resulting in composition
which have no commercial purpose separate from that of the article, and that result from
a chemical reaction that occurs upon end use of other chemical substances, mixtures, or
articles; except that fluids and particles are not considered articles regardless of shape or
design.”
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EPA considers imported items articles if they are manufactured in a specific shape or
design for a particular end-use application and this design is maintained as an essential
feature in the finished product. Thus, EPA views materials such as metal or plastic sheets,
wire, coated fabric, rolled carpet, sheets of plywood, and other similar materials as
articles, even if, for example, subsequent to import they are rolled or drawn thinner, cut,
printed, laminated, or thermoformed, provided they meet the above definition. Chemical
substances that are part of such articles are not subject to reporting under the CDR rule. If
the shape of an item does not serve a function with respect to the item’s end use (e.g., it is
imported in a particular shape for the sake of shipping convenience) then it would not be
considered an article. Thus, chemical substances that are part of items not considered by
EPA as articles, such as metal ingots, billets, and blooms are subject to reporting under
the CDR rule.
For additional information, see Fact Sheet: Imported Articles.
•

The chemical substance is manufactured as an impurity, a non-isolated intermediate, or
under any of the other circumstances identified in 40 CFR 711.10(c)(1) through (4).

•

If, within one year prior to the start of the submission period, (i.e., June 1, 2019 to May
31, 2020), you submitted all of the information required by the CDR rule in response to
another rule promulgated under section 8(a) of TSCA (such as the Preliminary
Assessment Information Reporting (PAIR) rule at 40 CFR Part 717, Subpart B), you are
not required to report the same information under CDR for the same chemical substance
during 2020 (40 CFR 711.22(a)).

Table 2-5 presents examples of the manufacturing/importing activities listed above.
If you manufacture a CDR reportable chemical substance in quantities greater than
25,000 lb (or 2,500 lb if the subject of certain TSCA actions), and do not qualify for any
reporting exemptions, you should evaluate Step III, described in the following section, to
determine what information you must report for your chemical substance.

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Table 2-5. Examples of Manufacturing/Importing Activities under Circumstances which
do/do not Require Reporting
Description

2020 Reporting Requirement

Company A manufactures 400,000 lb of a chemical
intermediate called Chemical X during the production of a
polymer. Chemical X is manufactured in Reactor 1 and is
subsequently entirely consumed when reacted with other
chemicals. Chemical X never leaves Reactor 1, except for
sampling purposes.

Company A does not need to report Chemical X
because it is considered to be a non-isolated
intermediate and is therefore fully exempt.

Company B manufactures 400,000 lb of a chemical
intermediate called Chemical Y during the production of a
polymer. Chemical Y is manufactured in Reactor 1 and
transferred to a storage tank until needed. Chemical Y is
then transferred to Reactor 2 where it is mixed with other
reactants to form the desired polymer, at which point
Chemical Y is destroyed. Chemical Y never leaves this
production site.

Company B is required to report Chemical Y.
When Chemical Y was transferred to the storage
tank, it was isolated, and, thus, does not meet the
definition for “non-isolated intermediate.”

Company C imports 10 million lb of Chemical Z in the form Company C is not required to report Chemical Z
of thin sheets. Company C cuts these sheets into the desired because it is considered to be an article and
size and shape, which are sold to consumers.
therefore exempt from reporting.
Company D imports 10 million lb of Chemical W in the
form of pellets. Company D subsequently melts and molds
Chemical W into the desired shape, which is sold directly to
consumers.

Company D is required to report Chemical W
because it imported pellets whose shape or design
when imported was not related to their end use.

Company D domestically manufactures 10 million lb of
Chemical W. Company D subsequently sells Chemical W to
Company E in the form of pellets. Company E melts and
molds the pellets.

Company D is required to report as the
manufacturer of Chemical W. Company E is not
required to report because it is neither
manufacturing nor importing Chemical W.

2.3 Step III: What Information Must You Report?
Once you determine from Steps I and II that
you are a manufacturer (including importer) of a
CDR reportable chemical substance and are required
to report, this section will help you determine what
information you must report.
You are required to report the information
described in 40 CFR 711.15(b) in Parts I and II and,
unless you qualify for a partial exemption, Part III
of Form U.

The reporting threshold for
processing and use activities is the
same as that for manufacturing
information.
You must use the same reporting
threshold for reporting processing and
use information as you use for
reporting all manufacturing
information (i.e., either 25,000 lb or
2,500 lb).

Basic company and site identification information, (submitted on Part I of Form U) is
required by 40 CFR 711.15(b)(1) and (b)(2). Chemical identification and information pertaining
to the manufacture (including import) of chemical substances (submitted on Part II of Form U)
is required by 40 CFR 711.15(b)(3). Note that the basic company and site information is
reported once per site, while the manufacturing information is reported separately for each
reportable chemical substance at the site. Industrial processing and use, and consumer and

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commercial uses of the chemical substance (submitted on Part III of Form U) is required by 40
CFR 711.15(b)(4). Certain manufacturing information and all processing and use information
are only reported for the principal reporting year (2015).
Manufacturers (including importers) of partially exempt chemical substances listed in 40
CFR 711.6(b)(1) and 711.6(b)(2) are not required to report processing and use information
described in 40 CFR 711.15(b)(4) for those chemical substances, but are otherwise required to
report the information requested on basic identity and manufacturing information described in
40 CFR 711.15(b)(2) and (3) for those chemical substances. Note that these partial exemptions
are negated if the chemical substance is the subject of any of certain TSCA actions.
Figure 2-4 presents a decision logic diagram to assist you in determining the CDR
information you must report. The following subsections explain each question in greater detail.

Figure 2-4. Decision Logic Diagram for Evaluating Step III
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2.3.1

Reporting Requirements

Is Your Chemical Substance Subject to Full Reporting due to Its TSCA Regulatory
or Consent Agreement Status? (Question J)

Chemical substances that are the subject of certain TSCA regulatory actions (40 CFR
711.6). See Section 2.1.4 for a more detailed description of the chemical substances that meet
these criteria. If you manufacture (including import) these chemical substances at quantities at
or above the applicable reporting threshold (i.e., either 25,000 or 2,500 lb if the subject of certain
TSCA actions), you must report all CDR information (i.e., manufacturing, processing, and use
information) regardless of any exemptions for which the chemical substance would otherwise
qualify. The SRS provides information on TSCA regulatory status of chemical substances.
If your chemical substance is not part of a TSCA regulatory action or consent agreement,
continue to evaluate Questions K and L as seen on Figure 2-4 and described in the following
sections to determine whether your chemical substance is partially exempt.
2.3.2

Is Your Chemical Substance Listed as a Petroleum Process Stream? (Question K)

Manufacturers (including importers) of certain petroleum process streams, regardless of
the production volume, do not need to complete Part III of Form U for these chemical
substances. The chemical substances termed “petroleum process streams” for purposes of CDR
that are partially exempt from CDR requirements are those listed by CAS Registry Number at 40
CFR 711.6(b)(1).
2.3.3

Is Your Chemical Substance Listed as a Chemical for which There is Low Current
Interest in the CDR Processing and Use Information? (Question L)

EPA created a partial exemption for certain chemical substances for which EPA has
identified a low current interest in their processing and use information. The specific chemical
substances are listed at 40 CFR 711.6(b)(2)(iv). The most recent additions to the partially exempt
chemicals list can be found under the Petition Results tab of the How To Report Under Chemical
Data Reporting page of the CDR website.
If your CDR reportable chemical substance manufactured (including imported) in
quantities at or above the applicable reporting threshold (i.e., either 25,000 or 2,500 lb if subject
to certain TSCA actions) is partially exempt, you are required to report only Parts I and II of the
reporting form. Otherwise, you are required to report Parts I, II, and III of the reporting form,
covering manufacturing, processing, and use information for your CDR reportable chemical
substance. Chapter 3 provides information about when you must report this information to EPA.

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Example 2-5. Company ABC produces Chemical Q, which is not the subject of any of the
TSCA actions listed in 40 CFR 711.6 or 711.8(b), nor is it listed as a petroleum process stream
or identified as low current interest for EPA. At the site, Chemical Q was produced in amounts
of 30,000 lb in 2016, 10,000 lb in 2017, 50,000 lb in 2018, and 5,000 lb in 2019.
Because Chemical Q is not the subject of any of the TSCA actions listed in 40 CFR 711.8(b),
the 25,000 lb threshold would be applicable for Chemical Q. Since the 25,000 lb threshold was
exceeded at least once from 2016 to 2019 (in this case, in 2016 and 2018), Company ABC
would be subject to reporting. Chemical Q is not the subject of any of the TSCA actions listed in
711.6, is not listed as a petroleum process stream or identified as low current interest for EPA,
so it is not partially exempt. Therefore, for the principal reporting year of 2019, Company ABC
would report additional manufacturing information and the processing and use data based on the
5,000 lb it produced that year.

Example 2-6. Company DEF begins producing Chemical Z in 2017. Chemical Z is not the
subject of any of the TSCA actions listed in 40 CFR 711.8(b). The production volumes at the
site are 2,000 lb in 2017, 25,000 lb in 2018, and no production for 2019.
Chemical Z is not the subject of any of the TSCA actions listed in 40 CFR 711.8(b); therefore,
the 25,000 lb threshold would be applicable for Chemical Z. Since the 25,000 lb threshold was
met in 2018, Company DEF would be subject to reporting. However, since there was no
production in 2019, the principal reporting year, the production volume would be reported as
zero, the manufacturing information needed to be reported would be limited to the company and
plant site information (40 CFR 711.15(b)(2)) and the chemical specific information on identity
as well as the production volume for 2013 and 2018 (40 CFR 711.15(b)(3)).

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When You Must Report

3. When You Must Report
For the 2020 reporting cycle, you are required to report information (pertaining to
calendar years 2016, 2017, 2018, and 2019) during the 2020 submission period. The 2020
submission period begins June 1, 2020 and ends September 30, 2020 (40 CFR 711.20).
Your submissions for the 2020 reporting cycle must be submitted to EPA via the Internet
and through EPA’s Central Data Exchange (CDX) no later than September 30, 2020. You
should note that registration with CDX is required prior to accessing e-CDRweb to submit your
CDR information (40 CFR 711.35). Separate user guides are available covering the specifics of
CDR registration and use of the e-CDRweb reporting tool. If you are required to report, failure to
file your report during this period is a violation of TSCA sections 8(a) and 15 and may subject
you to penalties. (40 CFR 711.1(c))

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Instructions for Completing CDR Form U

4. Instructions for Completing CDR Form U
This chapter will help you complete the CDR Form U. Separate user guides covering the
specifics of CDX registration and use of the e-CDRweb reporting tool are available at
https://www.epa.gov/chemical-data-reporting/how-report-under-chemical-data-reporting.
Section 4.1 describes how to certify your submission. Section 4.2 discusses the reporting
standard – the effort required to comply with the CDR rule. Sections 4.3 through 4.11 provide
information to help you complete each required section of Form U.
You are required to use the CDR reporting tool, e-CDRweb, to submit information for
each CDR reportable chemical substance. If you are reporting information for more than one
chemical substance at your site, you must report information for all reportable chemical
substances on one Form U. If you are reporting for multiple sites, you must submit a separate
Form U for each site.
Form U is comprised of a certification statement and four parts, as follows:
•

The certification statement and Part I of Form U are completed once per reporting site. Part I
contains company, site, and contact information.

•

Part II is completed for each reportable chemical substance at the site and contains
information associated with the identity, manufacture, and properties of the chemical
substance.

•

Part III is completed for each reportable chemical substance at the site and contains
information associated with the processing and use of the chemical substance.

•

Part IV is reserved for the special case of a joint submission and is completed by the
secondary submitter.

Note: Items such as the validation page and the SRS search page will appear in separate
windows. As described in the eCDRweb user guides, ensure that your pop-up blocker is
disabled before you begin to complete Form U.

4.1 Certification
Your CDR submission must be certified, indicating that your submitted information has
been completed in compliance with the CDR requirements and that any confidentiality claims
are true and correct. To certify, the certification statement must be electronically signed and
dated by an authorized official at your company. The authorized official typically is a senior
official with management responsibility for the person (or persons) completing the form. You
must include the printed name, title, and email address for the person signing the certification.
See the user guide on CDX Registration for information on how to complete an electronic
signature agreement.
This certification statement applies to all the information supplied on the form. The
certification statements appear when the submission process has been initiated, at which time the
submitter must either certify or cancel the submission process. Note that knowingly providing
false or misleading information or concealing required information may be punishable by fine or
imprisonment or both under TSCA section 16(b).
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4.2 Reporting Standard
Submitters are required to exercise certain levels of due diligence in gathering the
information required by the CDR rule. You must report your information to the extent that the
information is known to or reasonably ascertainable by you and your company. The term
“known to or reasonably ascertainable by” is defined in 40 CFR 704.3 and discussed more fully
below.
Known to or reasonably ascertainable by means all information in a person’s
possession or control, plus all information that a reasonable person similarly situated might be
expected to possess, control, or know.
Under TSCA section 8(a), EPA may collect information associated with chemical
substances to the extent that it is known to or reasonably ascertainable by the submitter. This
includes, but is not limited to, information that may be possessed by employees or other agents
of the company reporting under the CDR rule, including persons involved in the research,
development, manufacturing, or marketing of a chemical substance and includes knowledge
gained through discussions, symposia, and technical publications. For purposes of CDR, the
known to or reasonably ascertainable by standard applies to all the information required by the
rule.
Examples of types of information that are considered to be in a person’s possession or
control, or that a reasonable person similarly situated might be expected to possess, control, or
know include:
• Files maintained by the submitter, such as marketing studies, sales reports, or customer
surveys;
• Information contained in standard references, such as MSDSs, that contain use information or
concentrations of chemical substances in mixtures; and
• Information from the Chemical Abstracts Service (CAS) and from Dun & Bradstreet D-U-N
S®.
The hypothetical examples in Table 4-1 illustrate the anticipated application of the
“known to or reasonably ascertainable” reporting standard, in the specific context of the
collection of processing and use data under the CDR. Because the standard applies on a case-by
case basis, however, these examples cannot substitute for a complete analysis of a submitter’s
particular circumstances.

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Table 4-1. Examples of the Application of the “Known to or Reasonably Ascertainable”
Reporting Standard for Processing and Use Data.
Scenarios, Actions, and Outcomes
Scenario: Company XYZ discovers that it has no knowledge of how a particular reportable chemical substance
(chemical substance #1) is processed or used by its customers. Company XYZ usually maintains marketing data
documenting customers’ use of its chemicals, in line with the reasonable business practices typical of comparable
manufacturers, but it irrevocably lost these data for chemical substance #1 due to an inadvertent computer
malfunction. Company XYZ has many customers, but it expects that it could substantially reconstruct this missing
information by briefly contacting its largest customer and asking that customer what chemical substance #1 is
generally used for.
Application of KRA Reporting Standard:
If:

Then:

Company XYZ contacts its largest customer and reports on the basis of
the processing and use data that the customer was willing to provide.

Duties Likely Fulfilled

Company XYZ did not endeavor to supplement the information it already
knew.

Duties Not Fulfilled

Scenario: Company XYZ has never maintained information on how a particular reportable chemical substance
(chemical substance #2) is processed or used by its customers. However, it is typical for comparable manufacturers
to collect such information as part of their reasonable business practices. Company XYZ has many customers but it
expects that it could substantially fill this data gap by reviewing the public web site of its largest customer.
Application of KRA Reporting Standard:
If:

Then:

Company XYZ reviews its largest customer’s web site, and reports on the
basis of the information contained in the web site.

Duties Likely Fulfilled

Company XYZ did not endeavor to supplement the information it already
knew.

Duties Not Fulfilled

Scenario: Company ABC maintains seasonal marketing data on changes in use patterns for a particular chemical
substance (chemical substance #3). Comparable manufacturers typically only maintain such data on an annual
basis, in line with reasonable business practices. Company ABC irrevocably loses its summer marketing data for
chemical substance #3, due to an inadvertent computer malfunction. Company ABC expects that it could
substantially reconstruct the missing summer marketing data by contacting its largest customer and asking the
customer what it used or processed chemical substance #3 for in the past summer.
Application of KRA Reporting Standard:
If:

Then:

Instead of attempting to reconstruct the summer data by contacting its
largest customer, Company ABC reports on the basis of the processing
and use data that it already knows (regarding the winter, spring, and fall
of the year).

Duties Likely Fulfilled

Company ABC designated the information as “not known or reasonably
ascertainable” simply because one of the seasonal marketing reports was
missing.

Duties Not Fulfilled

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Scenarios, Actions, and Outcomes
Scenario: Company ABC has never maintained information on how a particular reportable chemical substance
(chemical substance #4) is processed or used by its customers. However, it is typical for comparable manufacturers
to collect such information as part of their reasonable business practices. Company ABC has one major customer
and ten minor customers.
Application of KRA Reporting Standard:
If:

Then:

Company ABC asks its major customer to supply information about how
chemical substance #4 is processed and used, but that customer is
unwilling to supply this information. Company ABC reasonably expects
that the only remaining way to substantially fill this data gap would be to
send a survey to its ten minor customers. Company ABC reports that the
information is “not known or reasonably ascertainable” to it.

Duties Likely Fulfilled

Company ABC did not endeavor to obtain processing and use
information from its customers and designated the information as “not
known or reasonably ascertainable.”

Duties Not Fulfilled

4.3 Part I - Section A. Parent Company Information1
You must provide information about your parent company. A parent company is a
company that owns or controls another company (40 CFR 704.3). For purposes of CDR, report
your highest-level parent company located in the United States and, if one exists, the highestlevel foreign-based parent company (40 CFR 711.15(b)(2)(i)). For each parent company, provide
the company name, address, and D&B number following the instructions, including the naming
conventions, provided below. Table 4-2 contains examples of how to identify the parent
company(ies) in different situations.
Table 4-2. Applying Parent Company Definition in Different Situations

1

If the site is owned…

Then the U.S. and/or foreign parent company is…

(1) If the site is entirely owned by a single
U.S. company that is not owned by another
company

then that single company is the U.S. parent
company and there is no foreign parent company.

(2) If the site is entirely owned by a single
U.S. company that is, itself, owned by another
U.S.-based company (e.g., it is a division or
subsidiary of a higher-level company)

the highest-level company in the ownership
hierarchy is the U.S. parent company. If there is a
higher-level parent company that is outside of the
United States, the highest-level foreign company in
the ownership hierarchy is the foreign parent
company.

(3) If the site is owned by more than one
company (e.g., company A owns 40 percent,
company B owns 35 percent, and company C
owns 25 percent of the site)

the highest-level U.S. company with the largest
ownership interest in the site is the U.S. parent
company. Under this scenario, this would be either
company A itself (if it doesn’t have a U.S.-based
parent company), company A’s parent, or, if it
exists, a single parent company that owns both

See Sec 4.8.1 for information concerning CBI claims for Parent Company Information.

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Instructions for Completing CDR Form U
company B and company C, in which case that
single parent company would have the largest
ownership interest. If there is a higher-level foreign
company in the site’s ownership hierarchy, that
company is the foreign parent company. There may
be the situation where the highest U.S. company is
company A’s parent company but a foreign
company owns both company B and company C. In
this situation, the foreign parent company would be
the highest-level parent company that owns
companies B and C and the U.S. parent company
would be the parent company of company A.

(4a) If the site is ultimately owned by a 50:50
joint venture or a cooperative

the joint venture or cooperative is its own U.S.
parent company.

(4b) If the site is owned by a U.S. joint
venture or cooperative

the highest level of the joint venture or cooperative
is the U.S. parent company.

(4c) If the site is owned by a joint venture or
cooperative outside the United States

the highest level of the joint venture or cooperative
outside the United States is the foreign parent
company.

(5) If the site is entirely owned by a foreign
company (i.e., without a U.S.-based
subsidiary within the facility’s ownership
hierarchy)

the site is the U.S. parent company and the highestlevel foreign parent company is the foreign parent
company.

(6) If the site is a federally owned facility

the highest-level federal agency or department is the
U.S. parent company.

(7) If the site is owned by a non-federal public that entity (such as a municipality, State, or tribe) is
entity
the U.S. parent company.
Note: Information provided during CDX registration will populate your U.S. parent
company identification information in Section A. Please double check this information to
ensure all required fields are complete and accurate. If any information is incorrect or
incomplete, the authorized official can make the necessary changes within eCDRweb.
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

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4.3.1

Instructions for Completing CDR Form U

U.S. and Foreign Parent Company Name(s) (Block 1.A.1)

All sites must enter the full name of the U.S. parent company, and, if applicable, the full
name of the foreign parent company. The U.S. parent company name is the name of the highestlevel company, located in the United States, that owns the manufacturing site. If your highestlevel parent company is outside of the United States, you must also identify and report both your
highest-level foreign parent company and your U.S. parent company (40 CFR 711.15(b)(2)(i)).
EPA requires that parent companies be referenced consistently by the same name so that
CDR site-level information can be aggregated to the associated parent company (40 CFR
711.15(b)(2)(i)). This can be challenging because filers within the same parent company often
submit names with small variations (e.g., Exopack vs. Exopack Holdings Corp). When reporting
your parent company name, eliminate all periods, commas, and leading, trailing, and duplicate
spaces. Replace commonly used acronyms and corporate terms according to Table 4-3:
Table 4-3. Parent Company Name Standardization Rules
Replace AND with &
Replace LIMITED PARTNERSHIP with LP
Replace CORPORATION with CORP
Replace LIMITED with LTD
Replace ASSOCIATION with ASSOC
Replace LIMITED LIABILITY COMPANY
with LLC
Replace COMPANY with CO
Replace LIMITED LIABILITY CO. with
LLC
Replace COMPANIES with COS
Replace PARTNERSHIP with PTNR
Replace DIVISION with DIV
Replace U.S.A. with USA
Replace INCORP with INC
Replace U.S.A with USA
Replace INCORP. with INC
Replace U S A with USA
Replace INCORPORATED with INC
Replace UNITED STATES OF AMERICA
with USA
Replace INCORPERATED with INC
Replace UNITED STATES with USA
4.3.2

Parent Company Dun & Bradstreet D-U-N-S® Number (Block 1.A.2)

Enter the 9-digit Dun & Bradstreet D-U-N-S® number (D&B number) associated with
the parent company name entered in Block 1.A.1. The number may be obtained from the
treasurer or financial officer of the company.
D&B assigns separate numbers to subsidiaries and parent companies; you should make
sure that the number you provide EPA belongs to your U.S. or foreign parent company. To
verify the accuracy of your site and parent company D&B number and name, go to
www.dnb.com/product/dlw/form_cc4.htm or call 1-800-234-3867. Callers to the toll-free phone
number should understand that the D&B support representatives will need to verify that callers
requesting the D&B number are an agent of the business. D&B recommends knowing basic
information such as when the business originated, officer names, and the name, address, and
phone number for the facility.
You must obtain a D&B number for your parent company if none exists. If your parent
company does not have a D&B number, you can request one from your local office of D&B.
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There is no charge for this service and you are not required to disclose sensitive financial
information to get a number. For more information on obtaining a D&B number, see
www.dnb.com. If you are already listed with D&B, but do not know your number, you can call 1800-234-3867 for assistance.
4.3.3

Parent Company Address (Blocks 1.A.3 through 1.A.8)

Enter the mailing address of the U.S. or foreign parent company name entered in Block
1.A.1, including the appropriate county or parish, using standard addressing techniques as
established by the U.S. or international postal services. Post office box numbers should be
accompanied by a street address. If a post office box is listed, it must be entered after the street
address. Standardized conventions for listing a street address will be used to account for
common formatting discrepancies, such as punctuation, capitalization, and abbreviations (e.g.,
“St.” for “Street” or “P.O. Box” for “PO Box”, etc.) and to increase the reliability and usability
of the data.

4.4 Part I - Section B. Site Information2
EPA requires the following information to be reported for each plant site at which a
reportable chemical substance is manufactured: the site name, site D&B number, street address,
city, county (or parish), state, and zip code.
Note: Information provided during CDX registration will populate your site identification
information in Section B. Please double check this information to ensure all required fields
are complete and accurate. If any information is incorrect or incomplete, the authorized
official should make the necessary changes in CDX.
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

2

See Sec 4.8.1 for information concerning CBI claims for Site Information.

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4.4.1

Instructions for Completing CDR Form U

Special Provisions for Certain Sites

The definition of site at 40 CFR 711.3 has special provisions for the following situations:
importation, manufacturing by contract (i.e., co-manufacturing), and portable manufacturing
units sent out from a single distribution center. In some situations, these provisions have a direct
bearing on the site which must be identified in Part I, Section B of Form U.
4.4.1.1 Special Provisions for Importers
The site where you import a chemical substance is considered the site of the operating
unit within your organization that is directly responsible for importing the chemical substance
and that controls the import transaction. For CDR, all importers must provide a U.S. address for
the controlling site; this site may be your company’s headquarters in the United States. If there is
no such operating unit or headquarters in the United States, the site address for the importer is the
U.S. address of an agent acting on the importer’s behalf who is authorized to accept service of
process for the importer (40 CFR 711.3). In the event that more than one person may meet the
definition of “importer” (40 CFR 704.3), only one person should report. See 40 CFR 711.22(b).
Example 4-2. The headquarters of your company is located in New Town. Your
company owns a plant site located in Old Town, which is in a different state. A
headquarters employee purchases and arranges to have 500,000 lb of Chemical X
imported from Japan to the Old Town plant site. The headquarters site in New Town
controls the import transaction and is the site reported on Form U.

Example 4-3. The headquarters of your company is located in New Town. Your
company owns three manufacturing sites, Sites 1, 2, and 3, all located in different
states. An employee based at headquarters purchases and arranges to have 500,000
lb of Chemical X imported from Japan. The chemical is distributed as follows:
20,000 lb is delivered to Site 1; 180,000 lb is delivered to Site 2; and 300,000 lb is
delivered to Site 3. The headquarters in New Town controls the import transaction
for all three sites, and therefore is responsible for reporting all 500,000 lb of
Chemical X. The site reported on Form U is New Town.

4.4.1.2 Special Provisions for Manufacturing by Contract
For chemical substances manufactured under contract, i.e., a co-manufactured chemical,
the site is the location where the chemical substance is physically manufactured (definition of
site, 40 CFR 711.3). When a company contracts with a producing company to manufacture a
chemical substance and each party meets the definition of manufacturer as set forth in 40 CFR
711.3, the contracting company (as the primary submitter) has the responsibility to initiate a comanufacture report that triggers the reporting requirements for the producing company (as the
secondary submitter). The contracting company reports both its site information (as the site
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Instructions for Completing CDR Form U

controlling the contract) and the producing company’s site information (as the site physically
manufacturing the chemical substance). The contracting company then initiates the comanufacture report and uses e-CDRweb to send a notification to the producing company. The
producing company provides all relevant information to complete the chemical information, as
described in Section 4.10 and elsewhere in these Instructions.
Note that, in such cases, both the producing company and the contracting company are
liable if no report is made. See 40 CFR 711.22(c). Nevertheless, even if the contracting company
submits the Form U, the site is still the location where the chemical substance is physically
manufactured (i.e., the producing company’s location). On Form U, the contracting company
reports its own site in Part I and the producing company’s site in Part II. The producing company
reports its own site in Part I of its own Form U submission.
4.4.1.3 Special Provisions for Portable Manufacturing Units
Two examples of portable manufacturing units are tanks used to manufacture calcium
hydroxide slurry for use in building construction and road and highway projects, and tanks used
to mix anhydrous ammonia and water to manufacture ammonium hydroxide prior to application
on agricultural lands. EPA is interested in including chemical substance manufacturing that is,
for instance, performed by road crews or is occurring at construction sites at which chemical
substances are mixed on site to create a different chemical substance. Because the site of
physical manufacturing could change on a frequent basis, the distribution center shall be
considered the site for portable manufacturing units sent to different locations from a single
distribution center. Manufacturers would report the aggregated production volume for all of the
portable manufacturing units sent out to different locations from a single distribution center
whose address would be reported as the site location.
4.4.2

Site Name (Block 1.B.1)

Enter the full name of the site. You should include any additional identifying terms such
as Inc., Ltd., L.L.C., etc. Standardized conventions for the naming of a site will be used to
address common formatting discrepancies, such as punctuation, capitalization, and
abbreviations (e.g., “Corp” for “Corporation” or “Plant” for “PLANT”) and to increase the
reliability and usability of the data. See Section 4.3.1.
4.4.3

Site Dun & Bradstreet Number D-U-N-S® (Block 1.B.2)

D&B assigns separate numbers to subsidiaries and parent companies; make sure that the
number you provide EPA in block 1.B.2 belongs to the individual site for which you are
reporting. You must obtain a D&B number for the site, if none exists. If the site does not have a
D&B number, you can request one from your local office of D&B. Please refer to Section 4.3.2
for information on obtaining a D&B number.
4.4.4

Site Street Address (Blocks 1.B.3 through 1.B.8)

Enter your site mailing address, including the appropriate county or parish (or other
jurisdictional indicator), using standard addressing techniques as established by the U.S. Postal
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Instructions for Completing CDR Form U

Service. Post Office box numbers should be accompanied by a street address. If a Post Office
box is listed, it should be listed after the street address. Standardized conventions for listing a
street address will be used to account for common formatting discrepancies, such as
punctuation, capitalization, and abbreviations (e.g., “St.” for “Street” or “P.O. Box” for “PO
Box”, etc.) and to increase the reliability and usability of the data.
4.4.5

NAICS code (Blocks 1.B.9)

Enter the appropriate six-digit North American Industry Classification System (NAICS)
code or choose the correct code from the drop-down list for each site reported. The NAICS
code is the standard used by Federal statistical agencies in classifying business establishments
for the purpose of collecting, analyzing, and publishing statistical data related to the U.S.
business economy. Information about NAICS codes can be obtained from the U.S. Census
website at https://www.census.gov/eos/www/naics/.

4.5 Part I - Section C. Public Contact Information
This section requests, but does not require, information about the person whom the
general public may contact to ask questions about your company and the information in your
CDR submission. The public contact provides an alternate to the technical contact for those who
have more general questions, or in situations where the technical contact has been claimed as
confidential. Because the public contact is intended to be made publicly available, it is not able to
be claimed as confidential.
Note that there are key differences between the public contact and technical contact. The
public contact should be a public-facing company representative who would be available to
answer more general questions about the company or its products. The technical contact should
be a person able to answer technical questions about the reported chemical substance. Typically,
a person located at the manufacturing site is best able to answer such questions.
Companies may use their discretion in selecting a public contact, as provided by the eCDRweb tool. Submitters should consider, in selecting this contact, that members of the public
may have questions about a CDR submission, one or more years after the submission date. The
public contact need not be the person who signed the certification statement. You can select your
public contact from the drop-down list of support registrants or enter information for a new
public contact.
Note: If you select from the list of support registrants, the public contact information
provided during CDX registration will populate Section C. Please double check this
information to ensure all required fields are complete and accurate. If any information is
incorrect or incomplete, the authorized official should make the necessary changes in CDX.

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Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

4.5.1

Public Contact Name (Blocks 1.C.1 and 1.C.2)

Enter the name of the person whom the public may contact for general questions
about the company, its products, or clarification of information submitted on Form U.
4.5.2

Public Contact Telephone Number and Email Address (Blocks 1.C.3 and 1.C.4)

Enter the public contact’s telephone number, including the area code, and the contact’s
email address. If the public contact is outside of the United States, include the country code.

4.6 Part I - Section D. Technical Contact Information3
This section requests information about the person whom EPA may contact for
clarification of the information in your CDR submission. The technical contact should be a
person who can answer questions about the reported chemical substance(s). Typically, a person
located at the manufacturing site is best able to answer such questions. However, companies may
use their discretion in selecting a technical contact or multiple technical contacts, as provided by
the e-CDRweb tool. Submitters should consider, in selecting the technical contact, that EPA may
have follow-up questions about a CDR submission, one or more years after the submission date.
The technical contact need not be the person who signed the certification statement. You can
select your technical contact from the drop-down list of support registrants or enter information
for a new technical contact.
Note: This information can be manually populated or populated with your CDX
information by clicking on the ‘Copy CDX Registration’ button. Please double check this
information to ensure all required fields are complete and accurate. If any information is
incorrect or incomplete, the authorized official should make the necessary changes in CDX.
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

3

See Sec 4.8.1 for information concerning CBI claims for Technical Contact Information.
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4.6.1

Instructions for Completing CDR Form U

Technical Contact Name and Company Name (Blocks 1.D.1 and 1.D.2)

Enter the name of the person whom EPA may contact for clarification of information
submitted on Form U. Enter the name of the company employing the technical contact.
Companies may use their discretion in populating one or multiple technical contacts;
however, only one technical contact can be identified per chemical report in a single Form
U.
4.6.2

Technical Contact Telephone Number and Email Address (Blocks 1.D.3 and 1.D.4)

Enter the technical contact’s telephone number, including the area code, and the contact’s
email address. If the technical contact is outside of the United States, include the country code.
4.6.3

Technical Contact Mailing Address (Blocks 1.D.5 through 1.D.10)

Enter the technical contact’s full mailing address, using standard addressing techniques as
established by the U.S. or international postal services, as applicable. Post Office box numbers should
be accompanied by a street address. If a Post Office box is used as a mailing address, the street address
should be given in Block 1.D.5 followed by the Post Office box number in Block 1.D.6. Standardized
conventions for listing a mailing address will be used to account for common formatting discrepancies,
such as punctuation, capitalization, and abbreviations (e.g., “St.” for “Street” or “P.O. Box” for “PO
Box”, etc.) and to increase the reliability and usability of the data.

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Instructions for Completing CDR Form U

4.7 Part II - Section A. Chemical Substance Identification
You must use the Agency’s Substance Registry Services (SRS) to report the chemical
substance identification information consisting of the currently correct Chemical Abstracts (CA)
Index Name and the correct corresponding Chemical Abstracts Service (CAS) Registry Number
(CASRN), as described in Sections 4.7.2 and 4.7.4. The SRS is EPA’s central system for
information about chemical substances that are tracked or regulated by EPA or other sources. It
is the authoritative resource for basic information about chemicals, biological organisms, and
other chemical substances of interest to EPA and its state and tribal partners.
The correct CA Index Name and CASRN must be reported separately for each CDR
reportable chemical substance at your site. If you wish to report a chemical substance listed on
the confidential portion of the TSCA Inventory, you will need to report the chemical substance
using a TSCA Accession Number (the generic name corresponding to the Accession Number
will automatically be incorporated into your form). See Section 4.7.1 for details on how to report
confidential chemical substances. You may also report by Metal Compound Category Name or
Code if your substance(s) is: (1) an inorganic byproduct, (2) among the list of categories (Table
4-6), and (3) not excluded from category reporting (i.e., if subject to certain TSCA actions as
described in §711.6). See Sections 4.7.6 – 4.7.6.2 for more details on how to report by Metal
Compound Category.
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

You will be able to connect directly to the SRS database from the reporting tool to report
the correct CA Index Names and CASRNs for all of your non-confidential chemical substances
on the TSCA Inventory. TSCA Accession Numbers and generic chemical names will be listed
instead of CA Index Names and CASRNs for chemical substances on the confidential portion of
the TSCA Inventory. The use of the SRS to obtain the identities for all CDR reportable chemical
substances is a convenient way to meet the chemical nomenclature requirement and will help to
prevent errors in the reporting of chemical identification information for the CDR. Furthermore,
after choosing a chemical substance, a message will describe whether the chemical substance is
on the lists of full or partial exemption chemical substances, as well as show any regulations that
affect the reporting volume threshold, full or partial exemption eligibility, and/or small
manufacturer exemption eligibility.
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

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4.7.1

Instructions for Completing CDR Form U

Confidentiality of Chemical Substance Information (Block 2.A.1)

If you wish to report a chemical substance listed on the confidential portion of the TSCA
Inventory, you will need to report the chemical substance using a TSCA Accession Number.
The generic chemical name corresponding to the TSCA Accession Number will also be
automatically incorporated into your form.
The identities of chemical substances listed on the public version of the TSCA Inventory
are already publicly known. Therefore, claims for confidential treatment of the identity of a
chemical substance which is listed on the public section of the TSCA Inventory are not valid and
will not be allowed. In addition, metal compound categories are not specific chemical identities
and therefore cannot be claimed as confidential. (40CFR711.30(a)(2)(ii))
You may claim as confidential the identity of a chemical substance that is already listed
as confidential on the TSCA Inventory (40 CFR 711.30(b)). To do so, you must check the
appropriate CBI box in Part II, Section A and submit detailed written answers to the
substantiation questions listed in Table 4-4. The confidential claim is only applicable to the
information as it is listed on the confidential portion of the TSCA Inventory; the corresponding
accession number and generic name listed on the public portion of the TSCA Inventory is
already public and cannot be claimed as confidential.
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

CBI claims for chemical identity will be accepted only when accompanied by a separate
written substantiation for the chemical substances claimed as CBI. Clicking the checkbox next to
“CBI for Chemical Identification” triggers the substantiation questions to appear. If you fail to
substantiate the claim for confidentiality of the chemical identity in accordance with applicable
rules, EPA may make the information available to the public without further notice to you. Note
that checking this box does not protect the link between your company and the chemical
substance; it only asserts a CBI claim for the specific identity of the chemical substance as listed
on the confidential portion of the TSCA Inventory.
Table 4-4. Substantiation Questions to be Answered when Asserting Chemical Identity CBI
Claims (40 CFR 711.30(b) and (c))
No.

Question

1.

Will disclosure of the information claimed as confidential likely cause substantial harm to your business’s
competitive position? If you answered yes, explain the substantial harm.

2.

To the extent your business has disclosed the information to others (both internally and externally), has
your business taken precautions to protect the disclosed information? If yes, please explain and identify
the specific measures or internal controls your business has taken to protect the information claimed as
confidential.
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Instructions for Completing CDR Form U
Question

3.

Does any of the information claimed as confidential appear in any public documents, including (but not
limited to) safety data sheets, advertising or promotional material, professional or trade publications, or
any other media or publications available to the general public? If you answered yes, explain why the
information should be treated as confidential.

4.

Does any of the information you are claiming as confidential constitute a trade secret?

5.

Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If so,
indicate the number of years (between 1–10 years) or the specific date after which the claim is withdrawn.

6.

Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that
made the decision, and the date of the determination.

7.

Is this chemical substance publicly known to be in U.S. commerce by a specific chemical identity or name
that is consistent with its listing on the confidential portion of the TSCA Inventory? If yes, explain why
the chemical identity should still be afforded confidential status (i.e. the chemical is publicly known only
as being distributed in commerce for research and development purposes). If no, complete the certification
statement:
I certify that on the date referenced, I searched the internet for the chemical substance identity
(i.e., by both chemical substance name and CASRN). I did not find a reference to this chemical
substance which would indicate the chemical is being manufactured or imported for a commercial
purpose and is available in the United States by anyone. [provide date].

8.

Does this particular chemical substance leave the site of manufacture (including import) in any
form, e.g., as product, effluent, emission? If so, what measures have been taken to guard against the
discovery of its identity?

9.

If the chemical substance leaves the site in a product that is available to the public or your competitors, can
the chemical substance be identified by analysis of the product?

10.

Would disclosure of the specific chemical name release confidential process information? If yes, please
explain.

Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

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4.7.2

Instructions for Completing CDR Form U

Chemical Substance Identifying Number (Block 2.A.2)

Every chemical substance reported in
accordance with CDR must be accompanied by Report the correct CASRN for your chemical
substance if it is listed on the nonits correct CASRN, corresponding to the
confidential portion of the TSCA Inventory.
chemical substance’s specific chemical name
If your chemical substance is listed on the
as described in 4.7.4. (40 CFR
confidential portion of the TSCA Inventory
711.15(b)(3)(i)). You may enter either a
and you wish to continue having the chemical
CASRN (Block 2.A.2) or the specific name of
identity be confidential, report the EPAthe chemical substance (Block 2.A.4) to select
designated TSCA Accession Number. Each
the appropriate CASRN/Chemical Abstracts
TSCA Inventory chemical substance has at
(CA) Index Name combination from the SRS
least
one of these types of numbers.
database. See Section 4.7.6 for information
about the alternative method of reporting for certain inorganic byproduct chemical substances.
EPA is requiring that you report only the CASRN as a chemical identifying number,
except in the cases of confidential chemical substances or category reporting. In the case of
confidential chemical substances, EPA is requiring that you report only the TSCA Accession
Number as a chemical identifying number. If, in the past, you reported using the PMN case
number of a confidential substance, you can use the PMN case number to search the SRS to
populate the pertinent chemical identification information for the confidential chemical
substance listed on the TSCA Inventory. In the SRS, you can readily find a cross-reference list
that displays the Accession Number, generic chemical name, and the PMN case number (or for
an initial TSCA Inventory substance, the TSCA Inventory reporting form number) for any
confidential chemical substance listed on the TSCA Inventory. You can then select from the
SRS the correct Accession Number corresponding to the confidential chemical substance
intended to be reported (the generic name corresponding to the Accession Number will
automatically be incorporated into your report).
There are certain circumstances where you occasionally may not be sure of the particular
PMN case number and Accession Number the Agency has assigned to one of its confidential
chemical substances, such that you would not be able to definitely determine this solely from
searching the SRS. This could happen, for example, if the chemical substance were originally
reported as part of a consolidated PMN and you did not learn from EPA which particular case
number in the consolidated PMN number sequence corresponds to which of the several reported
confidential chemical substances. This could also happen if a certain PMN represented a mixture
of two or more confidential chemical substances, such that multiple Accession Numbers were
assigned to the different chemical substances reported in that single PMN, and you didn’t already
request the particular Accession Numbers from EPA for the individual chemical substances
comprising that multi-component type of PMN. In such circumstances, you should contact EPA
well before initiating CDR reporting to obtain the required Accession Numbers from the Agency.
Submitters who are not able to identify the Accession Number by searching the SRS
should contact EPA, in writing on company letterhead, well before initiating CDR reporting to
obtain the Accession Number assigned when the Notice of Commencement (NOC) was
submitted to the Agency. Individuals are urged to submit a complete and accurate TSCA
Inventory Correspondence at least one month before the submission deadline. Note that
incomplete and/or inaccurate requests may be rejected. The Agency will respond to such
inquiries in as timely a manner as possible. It is the responsibility of the submitter to contact the

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Instructions for Completing CDR Form U

Agency for such information in sufficient time to allow for the Agency to respond.
Please send requests for a TSCA Accession Number as soon as possible to:

4.7.3

By U.S. Postal Service:

By Hand Delivery or Courier:

U.S. Environmental Protection Agency
Office of Pollution Prevention and
Toxics 1200 Pennsylvania Ave, NW
(7407M) Room 6428
Washington, DC 20460
Attention: Industrial Chemistry Branch

U.S. Environmental Protection Agency
Office of Pollution Prevention and
Toxics Confidential Business
Information Center EPA East Building,
Room 6428
1201 Constitution Ave,
NW Washington, DC
20004
202-564-8930; 202-564-8940

ID Code (Block 2.A.3)

The code corresponding to the type of identifying number you selected in the SRS will be
entered in Block 2.A.1. See codes in Table 4-5.
Table 4-5. ID Code for Chemical Identifying Numbers
If the Number You are Reporting is a(n)
TSCA Accession Number
TSCA Metal Compound Category Code
CAS Registry Number

4.7.4

This Code Will be Entered
A
M
C

Chemical Name (Block 2.A.4)

EPA is requiring the reporting of the CA Index Name currently used to list the chemical
substance on the TSCA Inventory as the chemical name reported for CDR. You may enter either
a CASRN (Block 2.A.2) or the specific name of the chemical substance (Block 2.A.4) to select
the appropriate CASRN/Chemical Abstracts (CA) Index Name combination from the SRS
database.
In cases where a chemical substance is listed on the confidential portion of the TSCA
Inventory, you are to report the chemical substance’s Accession Number which is listed on the
non-confidential portion of the TSCA Inventory and is included in the SRS (the generic name
corresponding to the Accession Number will automatically be incorporated into your report). In
order to continue to protect the confidentiality of the underlying specific chemical identification
information (i.e., the CASRN and specific chemical name), you must claim the chemical identity
as CBI and complete the upfront substantiation. Doing so will maintain the confidentiality of the
underlying specific chemical name and CASRN of the confidential chemical substance. The
Accession Number and generic chemical name will remain non-confidential. Failure to identify
the chemical identity as CBI and complete the upfront substantiation will waive any CBI claim
to the chemical identity and will result in the transfer of the chemical substance from the
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Instructions for Completing CDR Form U

confidential portion of the TSCA Inventory to the non-confidential, publicly releasable, portion
of the TSCA Inventory.
For those who are eligible, you alternately may enter a TSCA Metal Compound Category
Name or Code. See Section 4.7.6 for additional information.
4.7.5

Special Provisions for Manufacturing by Contract

When a company contracts with a producing company to manufacture a chemical
substance and each party meets the definition of manufacturer as set forth in 40 CFR 711.3, the
contracting company (as the primary submitter) has the responsibility to initiate a co-manufacture
report that triggers the reporting requirements for the producing company (as the secondary
submitter). The contracting company completes the chemical identity fields described in Sections
4.7.1-4.7.4 of this document and may provide a trade name or other alternate identifier for
communicating with the producing company.
4.7.6

Special Optional Provision for Manufacturers of Inorganic Byproducts

Manufacturers of inorganic byproducts may choose to report an inorganic byproduct
chemical substance using a designated metal compound category instead of as a specific
chemical substance (as described in 4.7.2 – 4.7.4), unless the chemical substance is excluded
from reporting in categories (i.e., if subject to certain TSCA actions as described in §711.6).
Metal compound categories are listed in Table 4-6. For purposes of determining whether any of
the thresholds specified in §711.8 are met for a metal compound category, you must make the
threshold determination based on the total amount of all members of the metal compound
category manufactured at the site. A variety of possible reporting scenarios can be found in Fact
Sheet: Optional Reporting in Metal Categories for Inorganic Byproducts [Note: the draft version
of this fact sheet is called “CDR Support Document: Proposed Optional Reporting in Metal
Categories for Inorganic Byproducts”]. These scenarios are intended to serve as a general aid in
appropriately reporting by category rather than by individual TSCA Inventory-defined substance,
but they will not necessarily account for each potential circumstance of every particular industry
and production process.
4.7.6.1 Excluded substances
•
•
•

Substances excluded from reporting in categories include three categories of substances:
Carbonic acid, barium salt (1:1) (referred to as Barium carbonate) (CASRN 513-77-9);
Chemical substances subject to the rules, orders, or other TSCA actions described in
§711.6; and
Chemicals undergoing risk assessment or evaluation under TSCA section 6, as listed on
EPA’s CDR website at https://www.epa.gov/cdr.

4.7.6.2 Confidentiality claims when reporting in a category
You cannot claim a metal compound category as confidential because the categories are
not specific chemical identities listed on the confidential portion of the TSCA Inventory.
Table 4-6. Metal Compound Categories for Inorganic Byproduct Chemical Substances Only
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Instructions for Completing CDR Form U
Code
M01
M02
M03
M04
M05
M06
M07
M08
M09
M10
M11
M12
M13
M14
M15
M16
M17
M18

4.7.7

Category Name
Antimony and Antimony Compounds: Includes any unique chemical substance that
contains antimony as part of that chemical's structure
Arsenic and Arsenic Compounds: Includes any unique chemical substance that
contains arsenic as part of that chemical's structure
Barium and Barium Compounds: Includes any unique chemical substance that
contains barium as part of that chemical's structure
Beryllium and Beryllium Compounds: Includes any unique chemical substance that
contains beryllium as part of that chemical's structure
Cadmium and Cadmium Compounds: Includes any unique chemical substance that
contains cadmium as part of that chemical's structure
Chromium and Chromium Compounds: Includes any unique chemical substance that
contains chromium as part of that chemical's structure
Cobalt and Cobalt Compounds: Includes any unique chemical substance that
contains cobalt as part of that chemical's structure
Copper and Copper Compounds: Includes any unique chemical substance that
contains copper as part of that chemical's structure
Lead and Lead Compounds: Includes any unique chemical substance that contains
lead as part of that chemical's structure
Manganese and Manganese Compounds: Includes any unique chemical substance
that contains manganese as part of that chemical's structure
Mercury and Mercury Compounds: Includes any unique chemical substance that
contains mercury as part of that chemical's structure
Molybdenum and Molybdenum compounds. Includes any unique chemical
substance that contains molybdenum as part of that chemical's structure
Nickel and Nickel Compounds: Includes any unique chemical substance that
contains nickel as part of that chemical's structure
Selenium and Selenium Compounds: Includes any unique chemical substance that
contains selenium as part of that chemical's structure
Silver and Silver Compounds: Includes any unique chemical substance that contains
silver as part of that chemical's structure
Thallium and Thallium Compounds: Includes any unique chemical substance that
contains thallium as part of that chemical's structure
Vanadium and Vanadium compounds. Includes any unique chemical substance that
contains vanadium as part of that chemical's structure
Zinc and Zinc Compounds: Includes any unique chemical substance that contains
zinc as part of that chemical's structure

Special Provisions for Joint Submitters of Unknown Chemical Substances

You may report an alternate chemical name, and in the case of importers, a trade name, in
those instances where your supplier will not disclose to you the specific chemical name of the
imported TSCA Inventory chemical substance or a reactant used to manufacture the TSCA
Inventory chemical substance because the information is claimed confidential. In these cases,
you and the supplier may report the information required in a joint submission, which is further
discussed in Section 4.11 of this chapter. If you as the importer cannot provide the chemical
name, supply a trade name or other designation to identify the proprietary chemical substance
and provide the supplier’s (secondary submitter’s) company information. Complete as much of
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the Form U as is known to or reasonably ascertainable by you. In addition, you must use eCDRweb to ask the supplier (secondary submitter) of the confidential chemical substance to
directly provide EPA with the correct chemical identity (as described in Section 4.7.2), in a joint
submission with you. Your request to the supplier must include instructions for submitting
chemical identity information electronically, using e-CDRweb and CDX (see 40 CFR 711.35),
and for clearly referencing your submission. Contact information for the supplier, a trade name
or other designation for the chemical substance or mixture, and a copy of the request to the
supplier must be included with your submission for the chemical substance.
Similarly, in the event that you as the manufacturer cannot provide the complete
chemical identity because you manufacture the reportable chemical substance using a reactant
that has a specific chemical identity claimed as confidential by its supplier, supply a trade name
or other designation to identify the proprietary chemical substance and provide the supplier’s
(secondary submitter’s) company information. Complete as much of the Form U as you can. In
addition, you must use e-CDRweb to ask the supplier to directly provide to EPA the correct
chemical identity of the confidential reactant in a joint submission. Such request must include
instructions for submitting chemical identity information electronically using e-CDRweb and
CDX (see 40 CFR 711.35), and for clearly referencing your submission. Contact information
for the supplier, a trade name or other designation for the chemical substance, and a copy of the
request to the supplier must be included with your submission referencing the chemical
substance.
In both cases, if the secondary submitter chooses to respond to the primary submitter’s
request, the secondary submitter would use e-CDRweb to identify the chemical substance in
question and the percent composition (4.D.2.d) and the chemical-specific function (4.D.2.e) of
each component chemical substance of the trade name product or mixture.
These special provisions only apply in cases where the supplier will not reveal the
pertinent chemical identity to you because it is claimed confidential. In the event that you
actually know the chemical identity of a chemical substance subject to CDR reporting, you must
provide that information irrespective of a supplier’s confidentiality claims.
EPA will only accept joint submissions that are submitted electronically using eCDRweb and CDX (see 40 CFR 711.35) and that clearly reference the Form U submission to
which they refer. See Section 4.11 in this chapter for more information on preparing joint
submissions.

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4.8 Part II - Section B. Manufacturing Information
The following subsections describe the manufacturing information required to be
reported for each chemical substance.
Update regarding substantiation requirements for claims of confidentiality:
All claims of confidentiality, except for information exempt from substantiation under
TSCA section 14(c)(2) such as production volume information (including domestic
manufacture and import), and certain information in joint submissions, must be
substantiated at the time of submission as required by TSCA section 14(c)(3).
EPA modified the electronic reporting applications for TSCA submissions to accept CBI
substantiations for CBI claims made during the creation of electronic submissions.
Specific instructions are available in the e-CDRweb User Guides for Primary Authorized
Official, Primary Support, Secondary Authorized Official, or Secondary Support.
For information on EPA’s policy of reviewing CBI claims, visit EPA Review and
Determination of CBI Claims under TSCA on the EPA website.

4.8.1

Confidentiality of Company, Site, and Technical Contact Information (Blocks 2.B.1
through 2.B.3)

Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the link between the chemical substance and the company, site,
or technical contact identity reported in Part I. Checking the CBI box automatically triggers the
substantiation questions. See Table 4-7 for substantiation questions related to these data
elements. If you fail to substantiate your CBI claims in accordance with the statute and
applicable rules, EPA may make the information available to the public without further notice to
you.
You may claim the connection between chemical substance and company, site, or
technical contact as confidential for some chemical substances for which you are reporting, while
not making the claim for others (each chemical substance is reported separately in Form U). EPA
will not impute the existence of a CBI claim for one chemical substance from a CBI claim
associated with a different chemical substance.
EPA also has observed that submitters sometimes claim only their company identity, but
not their site identity, as confidential. EPA will not impute the existence of a CBI claim for site
identity from a CBI claim for company identity, even if the company name appears within the
site identity information. In other words, if your intent is to claim company name as confidential
you must claim all data elements that reference or allude to company name as CBI. The failure
to do this will likely result in a denial of a CBI claim for company name.

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Table 4-7. Substantiation Questions to be Answered when Asserting Company, Site, or Technical
Contact Identity CBI Claims (40 CFR 711.30(c)(1))
No.

Question

1.

Will disclosure of the information claimed as confidential likely cause substantial harm to your business’s
competitive position? If you answered yes, explain the substantial harm.

2.

To the extent your business has disclosed the information to others (both internally and externally), has your
business taken precautions to protect the disclosed information? If yes, please explain and identify the
specific measures or internal controls your business has taken to protect the information claimed as
confidential.

3.

Does any of the information claimed as confidential appear in any public documents, including (but not
limited to) safety data sheets, advertising or promotional material, professional or trade publications, or any
other media or publications available to the general public? If you answered yes, explain why the
information should be treated as confidential.

4.

Does any of the information you are claiming as confidential constitute a trade secret?

5.

Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If so,
indicate the number of years (between 1–10 years) or the specific date after which the claim is withdrawn.

6.

Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that
made the decision, and the date of the determination.
Has company, site, or technical contact identity information been linked with a reportable chemical
substance in any public document or in any other Federal, State, or local reporting scheme? For example,
is the chemical identity linked to a facility in a filing under the Emergency Planning and Community
Right-to-Know Act (EPCRA) section 311, namely through a Safety Data Sheet (SDS)? If yes, explain why
the information should be treated as confidential.

7.

Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

4.8.2

Reporting Manufacturing Information for Calendar Year 2019 (Blocks 2.B.4. through
2.B.21)

This section of the CDR describes the manufacturing data elements that should be
reported for your CDR reportable chemical substance for the calendar year 2019, the principal
reporting year for the 2020 submission period. If any information is not known or reasonably
ascertainable by you (including your company), enter or select “NKRA” for “not known or
reasonably ascertainable” in the box corresponding to that data element. You may also check the
CBI box next to each data element to claim data as confidential. However, keep in mind that you
cannot claim an “NKRA” designation as confidential.

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Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

4.8.2.1 Activity (Domestically Manufacture and/or Import) (Block 2.B.4)
The “Manufacture” and/or “Import” boxes will be automatically checked once you
enter volume information in Blocks 2.B.5 and 2.B.6.
4.8.2.2 Domestically Manufactured Production Volume (Block 2.B.5)
Report the volume of the chemical substance domestically manufactured at your site
during calendar year 2019, in pounds. Report the quantity to at least two significant figures; it
should be accurate to the extent known to or reasonably ascertainable by you. Production
volumes should be reported in numeric format, without commas (e.g., 6352000). For example,
“2 million” or “2 E6" are not acceptable, nor are production volumes with decimals or
abbreviations such as M (e.g., 12,000,000 = 12M) or K (e.g., 50,000 = 50K).
4.8.2.3 Imported Production Volume (Block 2.B.6)
Report the volume of chemical substance imported by your site in 2019, in pounds.
Report the quantity to at least two significant figures; it should be accurate to the extent known
to or reasonably ascertainable by you. You should use the same numeric format as described for
Block 2.B.5, domestically manufactured production volume. Imported and domestically
manufactured production volumes are reported separately for each chemical substance at each
site. e-CDRweb has built-in validation systems that provide automated chemical identity and
threshold checks.
Note that if you import various mixtures containing reportable chemical substances, you
should add all import volumes associated with each chemical substance. For instance, if you
import three mixtures and each mixture contains Chemical A, then you would determine the
volume of Chemical A in each mixture and report the aggregated amount.
4.8.2.4 For Imported Chemical Substances, Is the Chemical Never Physically at Site? (Block
2.B.7)
Use the drop-down box to select one of the following choices:
Y = Yes, the imported chemical substance is never physically at the reporting site (e.g., if
you ship the chemical substance from a foreign country directly to another location such
as a warehouse, a processing or use site, or a customer’s site),
N = No, the imported chemical substance is actually physically present at the site.
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NKRA = It is not known to or reasonably ascertainable by you whether the imported
chemical substance is physically present at the site.
4.8.2.5 Volume Used On-Site (Block 2.B.8)
Report the total volume of the domestically manufactured and imported chemical
substance used at the reporting site, in pounds. The number represents the volume of the
chemical substance that does not leave the manufacturing site and is consumed or chemically
reacted on-site. Do not include volumes that are only stored on-site or mixed with other chemical
substances, without reaction, and then stored on-site or moved off-site.
The volume used on-site should not exceed the sum of the domestically manufactured and
imported volumes minus the volume exported (i.e., (Block 2.B.5 + Block 2.B.6) – Block 2.B.9).
If you report “Y” in Block 2.B.7, indicating that the imported chemical substance is never
physically present at the reporting site (for example because you ship it directly from a foreign
supplier to your client’s warehouse), you would report “0” in block 2.B.8, because that volume is
not used at your site. Report the quantity to at least two significant figures; it should be accurate
to the extent known to or reasonably ascertainable by you. You should use the same numeric
format as described for Block 2.B.5, domestically manufactured production volume. e-CDRweb
has built-in validation systems that provide automated chemical identity/threshold checks.
4.8.2.6 Volume Exported (Block 2.B.9)
Report the volume directly exported and not domestically processed or used, in pounds.
The volume exported should not exceed the sum of the domestically manufactured and imported
volumes minus volume used on site (i.e., (Block 2.B.5 + Block 2.B.6 – Block 2.B.8). Note that
direct exporting includes sending a chemical substance to a distributor who then exports it
without repackaging it, even if it is relabeled. Direct exporting does not include sending a
chemical substance to a distributor who repackages and relabels it. The latter case would be
considered a processing and use activity potentially reportable under Part III of Form U. Report
the quantity to at least two significant figures; it should be accurate to the extent known to or
reasonably ascertainable by you. You should use the same numeric format as described for
Block 2.B.5, domestically manufactured production volume.
Table 4-8. Examples of Reporting Volumes for Part II
Manufacturing Information
Description

2020 Reporting Requirement

Site 1 domestically manufactures 30,000 lb
of Chemical X.

Site 1 should report 30,000 lb as domestically manufactured for
Chemical X. The total production volume (i.e., the domestically
manufactured volume) should be used to report the remaining CDR
information.

Site 2 domestically manufactures 15,000 lb
of Chemical X and directly imports 15,000
lb of Chemical X.

Site 2 should report 15,000 lb as domestically manufactured. Because Site
2 controls the import transaction, Site 2 should also report 15,000 lb as
imported for Chemical X. The total production volume (i.e., sum of the
domestically manufactured and import volumes) should be used to report
the remaining CDR information.
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Site 3 domestically manufactures 30,000 lb
of Chemical X. Of the 30,000 lb
manufactured, Site 3 directly exports
10,000 lb to a foreign customer.

Site 3 should report 30,000 lb as domestically manufactured and
10,000 lb as exported for Chemical X. The volume not directly
exported should be used to report the remaining CDR information.

Site 4 domestically manufactures 70,000 lb
and imports 30,000 lb of Chemical X. Site
4 uses 20,000 lb of Chemical X on site.

Site 4 should report 70,000 lb as domestically manufactured, 30,000 lb
as imported and 20,000 lb as used on site. The total production volume
(i.e., sum of the domestically manufactured and import volumes) should
be used to report the remaining CDR information.

In 2019, Company B coordinates the
import of 100,000 lb of Chemical X,
which is imported directly to three
different sites owned by Company B. Site
5 receives 40,000 lb and Sites 6 and 7 each
receive 30,000 lb of Chemical X.

Company B should report 100,000 lb as imported for Chemical X. The
total production volume (i.e., the imported volume) should be used to
report the remaining CDR information. Because the three sites controlled
by Company B did not control the import transaction, the sites are not
required to report the imported volumes.

Site 6 domestically manufactures 10,000
lb of Chemical X, which is not the subject
of any of the certain TSCA actions

Site 6 is not required to report because production was less than 25,000
lb. Note that if Chemical X were the subject of one of the listed TSCA
actions, reporting would be required because the production volume
exceeds the 2,500 lb threshold.

4.8.2.7 Number of Workers (Block 2.B.11)
Report the total number of workers reasonably likely to be exposed to each reportable
chemical substance at each site during calendar year 2019 (40 CFR 711.15(b)(3)(viii)). For
Block 2.B.11, use the drop-down box to select the code corresponding to the appropriate range
for the number of workers reasonably likely to be exposed to a reportable chemical substance
during manufacture. Table 4-9 shows the codes and ranges which appear in the drop-down box.
Table 4-9. Codes for Reporting Number of Workers Reasonably Likely to be Exposed
Code
W1
W2
W3
W4
W5
W6
W7
W8

Range of Workers Reasonably Likely to be Exposed
Fewer than 10 workers
At least 10 but fewer than 25 workers
At least 25 but fewer than 50 workers
At least 50 but fewer than 100 workers
At least 100 but fewer than 500 workers
At least 500 but fewer than 1,000 workers
At least 1,000 but fewer than 10,000 workers
At least 10,000 workers

“Reasonably likely to be exposed” means “an exposure to a chemical substance which,
under foreseeable conditions of manufacture, processing, distribution in commerce, or use of the
chemical substance, is more likely to occur than not to occur. Such exposures would normally
include, but would not be limited to, activities such as charging reactor vessels, drumming, bulk
loading, cleaning equipment, maintenance operations, materials handling and transfers, and
analytical operations. Covered exposures include exposures through any route of entry
(inhalation, ingestion, skin contact, absorption, etc.), but excludes accidental or theoretical
exposures” (40 CFR 711.3).
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Persons reasonably likely to be exposed to a chemical substance include workers whose
employment requires them to pass through areas where chemical substances are manufactured,
processed, or used (e.g., production workers and foremen, process engineers, and plant
managers). Workers employed to drive vehicles which transport the chemical substance should
be included in the number of workers reasonably likely to be exposed to the chemical substance
if they come into contact with the chemical substance during loading or unloading. For example,
workers engaged in the connection or disengagement of hoses used to load or unload the
chemical substance should be included. However, workers involved solely with transporting
chemical substances in sealed containers that are totally enclosed with no potential for exposure
should not be included.
In addition, when a site employs temporary, seasonal, or contract workers in the
manufacture of a reportable chemical substance, these workers should be included in the number
of workers reasonably likely to be exposed to a chemical substance if they work in areas where
the chemical substance is manufactured. The term does not include those employees whose jobs
are not associated with potential exposures to a chemical substance or mixture (e.g.,
administrative staff who never enter areas where the chemical substance is manufactured) and
who are unlikely to be exposed to a chemical substance for even a brief period of time. No
allowance is made for personal protective equipment or for engineering controls that reduce but
do not preclude exposure to a chemical substance; however, if contact between a worker and a
chemical substance is highly improbable, the worker should not be included among those
persons reasonably likely to be exposed to the chemical substance.
When there is no potential exposure to a chemical substance, the code W1 corresponding
to fewer than 10 workers would be reported. This would be the case, for instance, when a
chemical substance is imported in sealed containers and resold without repackaging or is shipped
from a foreign source directly to a customer.
4.8.2.8 Maximum Concentration (Block 2.B.12)
Report the maximum concentration, measured by percentage of weight, of your
reportable chemical substance at the time it is reacted on-site to produce a different chemical
substance (site-limited) or as it leaves the site (40 CFR 711.15(b)(3)(ix)). The concentration
must be accurate to the extent that information is known to or reasonably ascertainable by you.
In your determination of the maximum concentration, do not include concentrations of the
product sent off-site for non-commercial purposes (40 CFR 710.1(a)).
For each chemical substance, from the drop-down box, select the code which corresponds
to the appropriate maximum concentration range of the chemical substance. Table 4-10 shows
the codes and concentration ranges which appear in the drop-down box. If the maximum
concentration falls between two ranges, round your estimate to the nearest one percent using
standard rounding procedures. Report the code that corresponds to the appropriate range. Report
the maximum concentration regardless of the various physical forms in which the chemical
substance may be sent off-site or reacted on-site to produce a different chemical substance.

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Table 4-10. Codes for Reporting Maximum Concentration
Code

Concentration Range (weight percent)

M1

Less than 1% by weight

M2

At least 1 but less than 30% by weight

M3

At least 30 but less than 60% by weight

M4

At least 60 but less than 90% by weight

M5

At least 90% by weight

4.8.2.9 What Percentage of this Chemical Substance is Being Manufactured as a Byproduct?
(Block 2.B.13)
Estimate the percentage of total 2019 production volume that is being manufactured as a
byproduct. The percentage should be accurate to the extent that it is known to or reasonably
ascertainable by you. Round your estimates to the nearest 10 percent of production volume (40
CFR 711.15(b)(3)(vi)). If you would like to provide more specific percentages, please do so. Do
not round a particular percentage that accounts for less than five percent of the total production
volume to zero percent, but instead
How to determine your percent production volume:
report to the nearest one percent of
production volume (40 CFR
1. Determine the production volume that is
711.15(b)(3)(vi)). Table 4-11
manufactured as a byproduct.
provides examples of reporting
2. Determine your total production volume for 2019.
percentages of manufacturing as a
a. Add together the volume domestically
byproduct.
manufactured and the volume imported.
b. DO NOT subtract the volume used on-site
If you do not know or
or the volume exported
cannot reasonably ascertain
3. Divide the volume determined in step 1 by the
information about how much of
volume determined in step 2 and multiply by 100.
your production volume is
manufactured as a byproduct, you
may use the response NKRA in lieu of an estimated percentage.
4.8.2.10 Is the Chemical Substance Being Recycled? (Block 2.B.14)
Use the drop-down box to select one of the following choices:
Y = Yes, the manufactured chemical substance, such as a byproduct, is to be recycled
or otherwise used for a commercial purpose instead of being disposed of as a waste or
included in a waste stream.
N = No, the manufactured chemical substance, such as a byproduct, is not to be recycled
or otherwise used for a commercial purpose instead of being disposed of as a waste or
included in a waste stream.
NKRA = It is not known to or reasonably ascertainable by you whether the
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manufactured chemical substance, such as a byproduct, is to be recycled or otherwise
used for a commercial purpose instead of being disposed of as a waste or included in a
waste stream.
By selecting “Yes,” you indicate that the manufactured chemical substance, which otherwise would be
disposed of as a waste, is being removed from the waste stream and is being used or reused for a
commercial purpose (40 CFR 711.15(b)(3)(vii)). Table 4-11 provides examples of reporting recycling
activities.
Table 4-11. Examples of Reporting Byproduct Percentages and Recycling
Description

2020 Reporting Requirement

Site 1 manufactures 500,000 lb of Chemical X, 165,000
lbs of which (or 33%) is manufactured as a byproduct
and then recycled instead of being disposed of as a
waste. You may either report the exact percentage or
round to the nearest 10% (i.e. 30% manufactured as a
byproduct).

On line 2.B.13 of Form U, enter either 33% or 30%
for the amount of 2019 production volume
recycled. On line 2.B.14 of Form U, enter Y as the
chemical is being recycled.

Site 2 manufactures 500,000 lb of Chemical Y, 3% (15,000
lb) of which is manufactured as a byproduct.

On line 2.B.13 of Form U, enter 3% because less
than 5% of the production volume is manufactured
as a byproduct.

Site 3 manufactures 12,000,000 lb of Chemical Z for
processing for incorporation into a mixture. Of the
production volume, 92% (11,040,000 lb) is processed for
incorporation and 8% (960,000 lb) is shipped to a waste
management facility that also recycles certain materials. The
manufacturer cannot reasonably ascertain whether this
portion of Chemical Z is being recycled or disposed of as a
waste.

On line 2.B.13 of Form U, enter either 8% or 10%
for the percentage of 2019 production volume that is
a byproduct. On line 2.B.14 of Form U, enter
NKRA as the manufacturer does not know and
cannot reasonably ascertain whether Chemical Z is
being recycled or disposed of as a waste.

4.8.2.11 Physical Form and Percentage of Production Volume (Blocks 2.B.15 through 2.B.21)
Report all physical forms of the chemical substance at the time it is reacted or as it leaves
your site and the percentage of production volume (including both domestically manufactured
and imported volumes) for each physical form (40 CFR 711.15(b)(3)(x)). For each chemical
substance at each site, the submitter must report as many physical forms as applicable by
selecting the appropriate blocks which correspond to the following six physical forms:
•
•
•
•
•
•

Dry Powder
Pellets or Large Crystals
Water- or Solvent-Wet Solid
Other Solid
Gas or Vapor
Liquid

Select “Not Known or Reasonably Ascertainable (NKRA)” if the physical form of
the chemical substance is not known to or reasonably ascertainable by you.
Report the percentage of the total production volume of the chemical substance for each

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physical form reacted onsite or sent off-site rounded off to the closest 10 percent (40 CFR
711.15(b)(3)(ix)). If the chemical substance is sent off-site in more than one physical form,
report all the physical forms in which it is sent off-site. These percentages may total more or less
than 100% due to rounding.
Example 4-5. Determining Percentage of Production Volume
Company A domestically manufactures 75,000 lb and imports 25,000 lb of Chemical X, for a
total production volume of 100,000 lb. Forty-eight percent (48,000 lb) of the production
volume is produced as dry powder, 24 percent (24,000 lb) is produced as pellets, 24 percent
(24,000 lb) as a liquid solution, and 4 percent (4,000 lb) as a water-wet solid. Company A
would report the following:
Dry Powder
Pellets or Large Crystals
Water- or Solvent-Wet Solid
Other Solid
Gas or Vapor
Liquid
4.8.3

50%
20%
0%
0%
0%
20%

Reporting Past Production Volume (PV) (Block 2.B.22)

If the reporting threshold of 25,000 pounds is met or exceeded during any calendar year
since 2015 (or 2,500 lb or more for chemical substances subject to certain TSCA actions),
reporting is required for each calendar year in the CDR submission period. Report the total
volume of the chemical substance manufactured at your site (includes domestically
manufactured and imported volumes) during calendar year 2016, 2017, and 2018 in pounds.
Report the production volume to at least two significant figures; it should be accurate to the
extent known to or reasonably ascertainable by you. Production volumes should be reported in
numeric format, with or without commas (i.e., 58,000 or 6352000). For example, “2 million” or
“2 E6" are not acceptable, nor are production volumes with decimals or abbreviations such as M
(e.g., 12,000,000 = 12M) or K (e.g., 50,000 = 50K).
4.8.4

Special Provisions for Manufacturing by Contract

When a company contracts with a producing company to manufacture a chemical
substance and each party meets the definition of manufacturer as set forth in 40 CFR 711.3, the
contracting company (as the primary submitter) has the responsibility to initiate a co-manufacture
report that triggers the reporting requirements for the producing company (as the secondary
submitter). Information in Part II Section B of Form U is reported in part by the contracting
company and in part by the producing company.
If known or reasonably ascertainable, the contracting company must complete the
chemical identity field and the volume manufactured. The producing company must report the
volume manufactured and the rest of the Part II information not already reported by the
contracting company.

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4.9 Part III - Processing and Use Information
In addition to completing Parts I and II, you
Information regarding processing or use
must complete Part III of Form U for reportable
activities must be reported to the extent
chemical substances manufactured (including
that it is known to or reasonably
imported), unless the chemical substance is
ascertainable by the submitter (40 CFR
partially exempt. See Sections 2.3.2 and 2.3.3 to
711.15(b)(4)).
determine whether you qualify for a partial
exemption. You should report the processing and use activities for the total 2019 production
volume reported (both domestically manufactured (Block 2.B.5) and imported (Block 2.B.6))
in Part II.
The processing or use information should be reported to the extent that it is known to or
reasonably ascertainable by you (40 CFR 711.15). Under the “known to or reasonably
ascertainable by” standard, a submitter would therefore prepare its report about the processing
and use of a chemical substance it manufactures (including imports), without confining its
inquiry solely to what is known to managerial and supervisory employees, but would also be
expected to review information which the manufacturer (including importer) may have in their
possession or control, plus all information that a reasonable person similarly situated might be
expected to possess, control, or know. The inquiry would be as extensive as a reasonable person,
similarly situated, might be expected to perform within the organization. Information derived
from customer surveys or other customer contacts, like any other information, would be “known
to” the submitter if it is available after a reasonable inquiry within the organization. The standard
does not necessarily require that the manufacturer conduct an exhaustive survey of all
employees.
For further clarity, submitters are not required to conduct a new or additional customer
survey (i.e., to pose a comprehensive set of identical questions to multiple customers) under this
standard. If particular information cannot be derived or reasonably estimated from the
information available to the company without conducting further customer surveys, it is not
“known to or reasonably ascertainable” to the submitter for purposes of the CDR. However, to
the extent that customer surveys are already in the submitter’s possession or control, and to the
extent that reasonable efforts to analyze or derive information from already-available customer
surveys may inform processing and use information that is reported, the information is generally
“known to or reasonably ascertainable.” Section 4.2 contains additional information on the
“known to or reasonably ascertainable by” reporting standard.
If any information is not known or reasonably ascertainable by you (including your
company), enter or select “NKRA” for “not known or reasonably ascertainable” in the box
corresponding to that data element.
4.9.1

Confidentiality of Processing and Use Information

You may check the CBI box next to each data element to claim data as confidential.
However, you may not claim the following data elements as confidential:
•

Certain Industrial processing and use data elements. These data elements directly relate
to how the chemical is used or processed and cannot be claimed as confidential (Form U
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Part III - Section A):
o type of process or use (§711.15(b)(4)(i)(A));
o industrial sector (§711.15(b)(4)(i)(B)); and
o function code (§711.15(b)(4)(i)(C)).
•

Certain Consumer and Commercial use data elements. These data elements directly
relate to how the chemical is used and cannot be claimed as confidential (Form U Part III
- Section B):
o product category (§711.15(b)(4)(ii)(A));
o function of the chemical in the consumer or commercial product
(§711.15(b)(4)(ii)(B));
o whether the chemical is used in commercial or consumer products
(§711.15(b)(4)(ii)(C)); and
o whether the chemical predictably is used in children’s products
(§711.15(b)(4)(ii)(D)).

With regard to the other use and processing data elements which may be claimed as CBI,
keep in mind that you cannot claim an “NKRA” designation as confidential. Checking a CBI
box associated with a specific processing and use data element automatically triggers
substantiation questions. See Table 4-12 for substantiation questions to be answered when
asserting CBI claims for processing and use information.
Table 4-12. Substantiation Questions to be Answered when Asserting Processing and Use
Information CBI Claims (40 CFR 711.30(d)(1))
No.

Question

1.

Will disclosure of the information claimed as confidential likely cause substantial harm to your business’s
competitive position? If you answered yes, explain the substantial harm.

2.

To the extent your business has disclosed the information to others (both internally and externally), has your
business taken precautions to protect the disclosed information? If yes, please explain and identify the
specific measures or internal controls your business has taken to protect the information claimed as
confidential.

3.

Does any of the information claimed as confidential appear in any public documents, including (but not
limited to) safety data sheets, advertising or promotional material, professional or trade publications, or any
other media or publications available to the general public? If you answered yes, explain why the
information should be treated as confidential.

4.

Does any of the information you are claiming as confidential constitute a trade secret?

5.

Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If so,
indicate the number of years (between 1–10 years) or the specific date after which the claim is withdrawn.

6.

Has EPA, another federal agency, or court made any confidentiality determination regarding information
associated with this chemical substance? If yes, provide the circumstances associated with the prior
determination, whether the information was found to be entitled to confidential treatment, the entity that
made the decision, and the date of the determination.

7.

Is the information claimed as confidential publicly known? For example, is the information available in
advertisements or other marketing materials, professional journals or other similar materials, or in nonconfidential mandatory or voluntary government filings or publications? Has your company ever publicly
released this information? If yes, explain why the information should be treated as confidential.
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Instructions for Completing CDR Form U

Has your company ever provided this information on the chemical substance to any person and not asked
that it be treated as confidential? If yes, explain why the information should be treated as confidential.

Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

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4.9.2

Instructions for Completing CDR Form U

Part III - Section A. Industrial Processing and Use Data (Blocks 3.A.1 through 3.A.10)

For each CDR chemical substance manufactured (including imported), report up to ten
unique combinations of the following data elements: the Type of Process or Use Operation
(TPU) (described in Section 4.9.2.1), the Industrial Sector (IS) (described in Section 4.9.2.2), and
the Function Category (FC) (described in Section 4.9.2.3) (40 CFR 711.15(b)(4)(i)). A
combination of these three data elements defines a potential exposure scenario for risk-screening
and priority-setting purposes. For each of these unique combinations, you are also required to
report the percentage of production volume (described in Section 4.9.2.4), the number of sites
(described in Section 4.9.2.5), and the number of workers (described in Section 4.9.2.6) (40 CFR
711.15(b)(4)(i)). If more than ten unique combinations apply to a chemical substance, you need
only report the ten combinations for the chemical substance that cumulatively represent the
largest percentage of production volume, measured by weight (40 CFR 711.15(b)(4)(i)(C)). The
reporting tool will allow you to enter more than ten combinations if you choose to do so.
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

4.9.2.1 Type of Processing or Use Operation
To the extent that it is known to or reasonably ascertainable by you, use the drop-down
box to select the code which corresponds to the appropriate Type of Processing or Use Operation
(TPU) for the particular combination of IS and FC codes. Table 4-13 shows the codes and TPUs
which appear in the drop-down box. Note that if a chemical substance is fully reacted (i.e.,
reporting “PC” for the processing code), then the chemical substance is consumed and further
processing and use information for that chemical substance will not exist. In such a situation,
there is no further downstream processing and use information to be reported for that particular
type of processing or use operation under 40 CFR 711.15(b)(4). A processing or use code may be
reported more than once if more than one IS and/or FC code applies to the same processing or use
operation. Definitions for each code are provided in Appendix D, which may assist you in
determining which code to report.
Table 4-13. Codes for Reporting Type of Industrial Processing or Use Operations
Code
PC

Operation
Processing as a reactant

PF

Processing—incorporation into formulation, mixture, or reaction product

PA

Processing—incorporation into article

PK

Processing—repackaging

U

Use—non-incorporative activities

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4.9.2.2 Industrial Sectors
You must select from the dropdown box the code which corresponds to the appropriate
Industrial Sector (IS) for all sites that receive a reportable chemical substance from you either
directly or indirectly (including through a broker/distributor, from a customer of yours, etc.) and
that process and use of the reportable chemical substance to the extent that this information is
known to or reasonably ascertainable by you (40 CFR 711.15(b)(4)(i)(B)). Table 4-14 shows
the codes and sectors which appear in the drop-down box. Because an industrial sector may
apply to more than one processing and use scenario for a chemical substance, the same IS code
may be reported with different combinations of FC and TPU codes.
A listing identifying the correspondence between NAICS codes and IS codes is
provided in Appendix D. Additional, more detailed information can be found on the CDR
website at www.epa.gov/chemical-data-reporting/replacement-5-digit-naics-codes-industrialsector-codes.
When you chose the IS “Other,” you also need to provide a written description of the
use of the chemical substance. The written description should be used to provide a description
at a comparable level of specificity as found with the current codes. It should not be used to add
additional, more specific detail. Your description may include the NAICS code.
Table 4-14. Industrial Sectors (IS)
Code

Sector Description

IS1
IS2
IS3
IS4
IS5
IS6
IS7
IS8
IS9
IS10
IS11
IS12

Agriculture, forestry, fishing and hunting
Oil and gas drilling, extraction, and support activities
Mining (except oil and gas) and support activities
Utilities
Construction
Food, beverage, and tobacco product manufacturing
Textiles, apparel, and leather manufacturing
Wood product manufacturing
Paper manufacturing
Printing and related support activities
Petroleum refineries
Asphalt paving, roofing, and coating materials manufacturing

IS13
IS14
IS15
IS16
IS17
IS18
IS19
IS20
IS21
IS22

Petroleum lubricating oil and grease manufacturing
All other petroleum and coal products manufacturing
Petrochemical manufacturing
Industrial gas manufacturing
Synthetic dye and pigment manufacturing
Carbon black manufacturing
All other basic inorganic chemical manufacturing
Cyclic crude and intermediate manufacturing
All other basic organic chemical manufacturing
Plastic material and resin manufacturing
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Instructions for Completing CDR Form U
Code
IS23
IS24
IS25
IS26
IS27
IS28
IS29
IS30
IS31
IS32
IS33
IS34
IS35
IS36
IS37
IS38
IS39
IS40
IS41
IS42
IS43
IS44
IS45
IS46
IS47
IS48

Sector Description
Synthetic rubber manufacturing
Organic fiber manufacturing
Pesticide, fertilizer, and other agricultural chemical manufacturing
Pharmaceutical and medicine manufacturing
Paint and coating manufacturing
Adhesive manufacturing
Soap, cleaning compound, and toilet preparation manufacturing
Printing ink manufacturing
Explosives manufacturing
Custom compounding of purchased resin
Photographic film paper, plate, and chemical manufacturing
All other chemical product and preparation manufacturing
Plastics product manufacturing
Rubber product manufacturing
Nonmetallic mineral product manufacturing (includes clay, glass,
cement, concrete, lime, gypsum, and other nonmetallic mineral product
manufacturing.
Primary metal manufacturing
Fabricated metal product manufacturing
Machinery manufacturing
Computer and electronic product manufacturing
Electrical equipment, appliance, and component manufacturing
Transportation equipment manufacturing
Furniture and related product manufacturing
Miscellaneous manufacturing
Wholesale and retail trade
Services
Other (requires additional information)

4.9.2.3 Function Category
Select from the drop-down box the code that corresponds to the appropriate Industrial
Function Category (FC) for each particular combination of TPU and IS that you report (40 CFR
711.15(b)(4)(i)(C)). Table 4-15 shows the codes and FCs that appear in the drop-down box.
Descriptions for each FC are provided in Appendix D. If you select U999A (Other), you must
provide a description of the function of the chemical substance. The written description should
be used to provide a description at a comparable level of specificity as found with the current
codes. It should not be used to add additional, more specific detail.
Function codes are based on the intended physical or chemical characteristic for when a
chemical substance or mixture is consumed as a reactant; incorporated into a formulation,
mixture, reaction product, or article; repackaged; or used (e.g., as an abrasive, a catalyst, or an
elasticizer). However, the functional use categories cover the life cycle and describe the specific
function that a chemical provides when used in the formulation of a product or article, or when
used within an industrial process. While the function of a chemical may be the same across its
life cycle, certain functions may only be appropriate for consideration in an industrial setting,
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while others may be relevant for a consumer or commercial setting. For more information on
reporting consumer and commercial use data, see Section 4.9.3 (Part III – Section B of the Form
U) below.
Table 4-15. Codes for Reporting Function Categories (FCs)
Code

Category

U001A

Abrasives

U001B

Etching agent

U002A

Adhesion/cohesion promoter

U002B

Binder

U002C

Flux agent

U002D

Sealant (barrier)

U003A

Absorbent

U003B

Adsorbent

U003C

Dehydrating agent (desiccant)

U003D

Drier

U003E

Humectant

U004A

Soil amendments (fertilizers)

U005A

Anti-adhesive/cohesive

U005B

Dusting agent

U006A

Bleaching agent

U006B

Brightener

U007A

Anti-scaling agent

U007B

Corrosion inhibitor

U008A

Dye

U008B

Fixing agent (mordant)

U009A

Hardener

U009B

Filler

U010A

Anti-static agent

U010B

Softener and conditioner

U010C

Swelling agent

U010D

Tanning agents not otherwise specified

U010E

Waterproofing agent

U010F

Wrinkle resisting agent

U011A

Flame retardant

U012A

Fuel agents

U012B

Fuel

U013A

Heat transferring agent

U013B

Hydraulic fluids

U013C

Insulators

U013D

Refrigerants

U014A

Anti-freeze agent
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Instructions for Completing CDR Form U

Code

Category

U015A

Intermediate

U015B

Monomers

U016A

Ion exchange agent

U017A

Anti-slip agent

U017B

Lubricating agent

U018A

Deodorizer

U018B

Fragrance

U019A

Oxidizing agent

U019B

Reducing agent

U020A

Photosensitive agent

U020B

Photosensitizers

U020C

Semiconductor and photovoltaic agent

U020D

UV stabilizer

U021A

Opacifer

U021B

Pigment

U022A

Plasticizer

U023A

Plating agent

U024A

Catalyst

U024B

Chain transfer agent

U024C

Chemical reaction regulator

U024D

Crystal growth modifiers (nucleating agents)

U024E

Polymerization promoter

U024F

Terminator/Blocker

U025A

Processing aids, specific to petroleum production

U026A

Antioxidant

U026B

Chelating agent

U026C

Defoamer

U026D

pH regulating agent

U026E

Processing aids not otherwise specified

U027A

Energy Releasers (explosives, motive propellant)

U027B

Foamant

U027C

Propellants, non-motive (blowing agents)

U028A

Cloud-point depressant

U028B

Flocculating agent

U028C

Flotation agent

U028D

Solids separation (precipitating) agent, not otherwise specified

U029A

Cleaning agent

U030A

Diluent

U030B

Solvent

U031A

Surfactant (surface active agent)

U031B

Emulsifier
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Instructions for Completing CDR Form U

Code

Category

U032A

Thickening agent

U032B

Viscosity modifiers

U033A

Laboratory chemicals

U034A

Dispersing agent

U034B

Freeze-thaw additive

U034C

Surface modifier

U034D

Wetting agent (non-aqueous)

U035A

Aerating and deaerating agents

U035B

Explosion inhibitor

U035C

Fire extinguishing agent

U035D

Flavoring and nutrient

U036A

Anti-redeposition agent

U036B

Anti-stain agent

U036C

Anti-streaking agent

U037A

Conductive agent

U037B

Incandescent agent

U037C

Magnetic element

U038A

Anti-condensation agent

U038B

Coalescing agent

U038C

Film former

U039A

Demulsifier

U039B

Stabilizing agent

U040A

Alloying element

U040B

Density modifier

U040C

Elasticizer

U040D

Flow promoter

U040E

Sizing agent

U040F

Solubility enhancer

U040G

Vapor pressure modifiers

U041A

Embalming agent

U041B

Heat stabilizer

U041C

Preservative

U042A

Anti-caking agent

U042B

Deflocculant

U042C

Dust suppressant

U042D

Impregnation agent

U042E

Leaching agent

U043A

Tracer

U044A

X-ray absorber

U999A

Other

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Instructions for Completing CDR Form U

4.9.2.4 Percentage of Production Volume
Estimate the percentage of total 2019 production volume that is attributable to each
unique combination of TPU, IS, and FC. The percentage should be accurate to the extent that it
is known to or reasonably ascertainable by you. Round your estimates to the nearest 10 percent
of production volume (40 CFR 711.15(b)(4)(i)(D)). If you would like to provide more specific
percentages, please do so. Do not round a particular combination that accounts for less than five
percent of the total production volume to zero percent if the production volume attributable to
that combination is greater than or equal to 25,000 lb. In such cases, you must report the
percentage of production volume attributable to that combination to the nearest one percent of
production volume (40 CFR 711.15(b)(4)(i)(D)).
The total percentage of
production volumes associated
with the TPU, IS, and FC
combinations may add up to more
than 100 percent, given that you
are reporting on distribution of a
chemical substance to sites in
your control as well as
downstream sites, some of which
are not immediate purchasers
from your original manufacturing
site. Additionally, the total
percentage of production volume
may add up to less than 100
percent if, for example:

How to determine your percent production volume:
1. Determine the production volume that is attributable
to each unique combination of TPU, IS, and FC.
2. Determine your total production volume for 2015.
a. Add together the volume domestically
manufactured and the volume imported.
b. DO NOT subtract the volume used on-site
or the volume exported
3. Divide the volume determined in step 1 by the
volume determined in step 2 and multiply by 100.

• You do not know or cannot reasonably ascertain information about how all of your
production volume is processed or used;
• More than 10 combinations of codes are applicable to your chemical substance; or
• You export a portion of the production volume.
Table 4-16 provides examples of reporting industrial processing and use data.

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Instructions for Completing CDR Form U
Table 4-16. Examples of Reporting Industrial Processing and Use Information
Description

2020 Reporting Requirement

Site 1 manufactures 500,000 lb of Chemical X for
processing for incorporation into a mixture. All of the
production is for use in industrial sector IS17 (Synthetic
Dye and Pigment Manufacturing). Of the production
volume, 67% (335,000 lb) is used as a dye and 33%
(165,000 lb) is used as a pigment.

On line 3.A.1 of Form U, enter PF for type of
process or use, IS17 for industrial sector, U008A
for FC, and 70% for production volume. On line
3.A.2 of Form U, enter PF for type of process or
use, IS17 for industrial sector, U021B for FC, and
30% for production volume.

Site 1 manufactures 500,000 lb of Chemical X for
processing for incorporation into a mixture. All of the
production is for use under industrial sector IS17 (Synthetic
Dye and Pigment Manufacturing). Of the production
volume, 97% (485,000 lb) is used as a coloring agent for
dyes and 3% (15,000 lb) is used as a coloring agent for
pigments.

On line 3.A.1 of Form U, enter PF for type of
process or use, IS17 for industrial sector, U008A
for FC, and 100% for production volume. On line
3.A.2 of Form U, enter PF for type of process or
use, IS14 for industrial sector, and U021B for FC.
Because less than 25,000 lb is used for pigments,
enter 0% for production volume.

Site 1 manufactures 12,000,000 lb of Chemical X for
processing for incorporation into a mixture. All of the
production is for use under industrial sector IS17 (Synthetic
Dye and Pigment Manufacturing). Of the production
volume, 97% (11,640,000 lb) is used as a coloring agent for
dyes and 3% (360,000 lb) is used as a coloring agent for
pigments.

On line 3.A.1 of Form U, enter PF for type of
process or use, IS17 for industrial sector, U008A
for IFC, and 100% for production volume. Because
the use in pigments, FC U021B, accounts for
100,000 lb or more, on line 3.A.2 of Form U,
enter PF for type of process or use, IS17 for
industrial sector, U021 for FC, and 3% for
production volume.

4.9.2.5 Number of Sites Code
For each unique combination of Type of Process or Use Operation, Industrial Sector, and
Function Category, select from the drop-down box the code which corresponds to the
appropriate number range for the total number of industrial sites, including those not under your
control, that process or use each reported chemical substance to the extent that such information
is known or reasonable ascertainable by you (40 CFR 711.15(b)(4)(i)I). In the event you both
manufacture (including import) and process or use the same reportable chemical substance at the
reporting plant site, your site would be counted as both a manufacturing site in Part II of Form U
and a processing or use site reported in Part III of Form U (40 CFR 711.15(b)(4)). Table 4-17
shows the codes and site number ranges which appear in the drop-down box.
Table 4-17. Codes for Reporting Numbers of Sites
Code

Range

S1

Fewer than 10 sites

S2

At least 10 but fewer than 25 sites

S3

At least 25 but fewer than 100 sites

S4

At least 100 but fewer than 250 sites

S5

At least 250 but fewer than 1,000 sites

S6

At least 1,000 but fewer than 10,000 sites

S7

At least 10,000 sites
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Instructions for Completing CDR Form U

4.9.2.6 Number of Workers Code
For each unique combination of Type of Process or Use Operation, Industrial Sector, and
Function Category, estimate the total number of workers that are reasonably likely to be exposed
to the chemical substance at sites that process or use the chemical substance (40 CFR
711.15(b)(4)(i)(F)). Include workers at sites that are not under your control as well as those sites
you control. For each chemical substance, select from the drop-down box the code that
corresponds to the estimated range of the number of workers reasonably likely to be exposed. To
claim this information as confidential, check the box adjacent to the reported information. Table
4-18 shows the codes and worker ranges which appear in the drop-down box.
Table 4-18. Codes for Reporting Number of Workers Reasonably Likely to
be Exposed During Processing and Use
Code

Range of Workers Reasonably Likely to be Exposed

W1

Fewer than 10 workers

W2

At least 10 but fewer than 25 workers

W3

At least 25 but fewer than 50 workers

W4

At least 50 but fewer than 100 workers

W5

At least 100 but fewer than 500 workers

W6

At least 500 but fewer than 1,000 workers

W7

At least 1,000 but fewer than 10,000 workers

W8

At least 10,000 workers

“Reasonably likely to be exposed” means “an exposure to a chemical substance which,
under foreseeable conditions of manufacture (including import), processing, distribution in
commerce, or use of the chemical substance, is more likely to occur than not to occur. Such
exposures would normally include, but would not be limited to, activities such as charging
reactor vessels, drumming, bulk loading, cleaning equipment, maintenance operations, materials
handling and transfers, and analytical operations. Covered exposures include exposures through
any route of entry (inhalation, ingestion, skin contact, absorption, etc.), but excludes accidental
or theoretical exposures” (40 CFR 711.3).
Persons reasonably likely to be exposed to a chemical substance include workers whose
employment requires them to pass through areas where chemical substances are manufactured,
processed, or used (e.g., production workers and foremen, process engineers, and plant
managers). Workers employed to drive vehicles that transport the chemical substances should be
included in the number of workers reasonably likely to be exposed to the chemical substance if
they come into contact with the chemical substance during loading or unloading. For example,
workers engaged in the connection or disengagement of hoses used to load or unload the
chemical substance should be included. However, workers involved solely with transporting
chemical substances in sealed (totally enclosed with no potential for exposure) containers should
not be included.
In addition, when a site employs temporary, seasonal, or contract workers in the
manufacture of a reportable chemical substance, these workers should be included in the number
of workers reasonably likely to be exposed to a chemical substance if they work in areas where
the chemical substance is manufactured. The term does not include those employees whose jobs

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are unassociated with potential exposures to a chemical substance or mixture (e.g.,
administrative staff who never enter areas where the chemical substance is manufactured) and
who are unlikely to be exposed to a chemical substance for even a brief period of time. No
allowance is made for personal protective equipment or for engineering controls that reduce but
do not preclude exposure to a chemical substance; however, if contact between a worker and a
chemical substance is highly improbable, the worker should not be included among those
persons reasonably likely to be exposed to the chemical substance.
4.9.3

Part III - Section B. Consumer and Commercial Use Data (Blocks 3.B.1 through 3.B.10)

For purposes of CDR reporting, a commercial use means the use of a chemical substance
or a mixture (including as part of an article) in a commercial enterprise providing saleable goods
or a service (40 CFR 711.3). A consumer use, on the other hand, means the use of a chemical
substance or a mixture (including as part of an article) when sold to or made available to
consumers for their use (40 CFR 711.3).
You are required to report information that is known to or reasonably ascertainable by
you concerning the consumer and commercial end uses of each chemical substance
manufactured (including imported) at sites you control and at sites controlled by people to whom
you have either directly or indirectly (including through a broker/distributor, from a customer,
etc.) distributed the reportable chemical substance (40 CFR 711.15(b)(4)).
Future e-CDRweb reporting tool screen shot to be added.
See mock-up document for draft versions of the 2020 reporting tool
affected by the proposed changes.

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4.9.3.1 Product Category
You must designate up to ten product categories which correspond to the actual use of
the chemical substance by selecting from the drop-down box the codes which correspond to the
appropriate product categories (40 CFR 711.15(b)(4)(ii)(A)). The reporting tool will allow you
to enter more than ten categories if you choose to do so. Table 4-19 shows the codes and product
categories which appear in the drop-down box.
If you select C909A (Other), you must provide a description of the product category. The
written description should be used to provide a description at a comparable level of specificity as
found with the current codes. It should not be used to add additional, more specific detail. If
more than ten codes apply, you need report only the ten codes for the chemical substance that
cumulatively represent the largest percentage of production volume, measured by weight (40
CFR 711.15(b)(4)(ii)(A)).
Table 4-19. Product Category Codes
Code

Category

Chemical Substances in Furnishing, Cleaning, Treatment Care Products
C101A

Construction and building materials covering large surface areas including stone, plaster, cement,
glass and ceramic articles; fabrics, textiles, and apparel

C102A

Furniture & furnishings including plastic articles (soft); leather articles

C103A

Furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal
articles; or rubber articles

C104A

Leather conditioner

C104B

Leather tanning, dye, finishing, impregnation and care products

C104C

Textile (fabric) dyes

C104D

Textile finishing and impregnating/surface treatment products

C105A

All-purpose foam spray cleaner

C105B

All-purpose liquid cleaner/polish

C105C

All-purpose liquid spray cleaner

C105D

All-purpose waxes and polishes

C105E

Appliance cleaners

C105F

Drain and toilet cleaners (liquid)

C105G

Powder cleaners (floors)

C105H

Powder cleaners (porcelain)

C106A

Dishwashing detergent (liquid/gel)

C106B

Dishwashing detergent (unit dose/granule)

C106C

Dishwashing detergent liquid (hand-wash)

C106D

Dry cleaning and associated products

C106E

Fabric enhancers

C106F

Laundry detergent (unit-dose/granule)

C106G

Laundry detergent (liquid)

C106H

Stain removers
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Code

Category

C107A

Ion exchangers

C107B

Liquid water treatment products

C107C

Solid/Powder water treatment products

C108A

Liquid body soap

C108B

Liquid hand soap

C108C

Solid bar soap

C109A

Air fresheners for motor vehicles

C109B

Continuous action air fresheners

C109C

Instant action air fresheners

C110A

Anti-static spray

C110B

Apparel finishing, and impregnating/surface treatment products

C110C

Insect repellent treatment

C110D

Pre-market waxes, stains, and polishes applied to footwear

C110E

Post-market waxes, and polishes applied to footwear (shoe polish)

C110F

Waterproofing and water-resistant sprays

Chemical Substances in Construction, Paint, Electrical, and Metal Products
C201A

Fillers and putties

C201B

Hot-melt adhesives

C201C

One component caulks

C201D

Solder

C201E

Single component glues and adhesives

C201F

Two component caulks

C201G

Two-component glues and adhesives

C202A

Adhesive/Caulk removers

C202B

Aerosol spray paints

C202C

Lacquers, stains, varnishes and floor finishes

C202D

Paint strippers/removers

C202E

Powder coatings

C202F

Radiation curable coatings

C202G

Solvent-based paint

C202H

Thinners

C202I

Water-based paint

C203A

Construction and building materials covering large surface areas, including wood articles

C204A

Construction and building materials covering large surface areas, including paper articles; metal
articles; stone, plaster, cement, glass and ceramic articles

C205A

Machinery, mechanical appliances, electrical/electronic articles

C205B

Other machinery, mechanical appliances, electronic/electronic articles

C206A

Articles intended for food contact, including metal articles

C206B

Construction and building materials covering large surface areas, including metal articles

C207A

Electrical batteries and accumulators
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Code

Category

Chemical Substances in Packaging, Paper, Plastic, Toys, Hobby Products
C301A

Articles intended for food contact including paper articles; plastic articles (soft); plastic articles
(hard); rubber articles; metal articles; fabrics, textiles, and apparel

C302A

Packaging (excluding food packaging), including paper articles

C302B

Other articles with routine direct contact during normal use, including paper articles

C303A
C303B
C304A

Packaging (excluding food packaging), including rubber articles; plastic articles (hard); plastic
articles (soft)
Other articles with routine direct contact during normal use including rubber articles; plastic
articles (hard)
Toys intended for children’s use (and child dedicated articles), including fabrics, textiles, and
apparel; or plastic articles (hard)

C305A

Adhesives applied at elevated temperatures

C305B

Cement/concrete

C305C

Crafting glue

C305D

Crafting paint (applied to body)

C305E

Crafting paint (applied to craft)

C305F

Fixatives and finishing spray coatings

C305G

Modelling clay

C306A

Correction fluid/tape

C306B

Inks in writing equipment (liquid)

C306C

Inks used for stamps

C306D

Toner/Printer cartridge

C307A

Liquid photographic processing solutions

Chemical Substances in Automotive, Fuel, Agriculture, Outdoor Use Products
C401A

Exterior car washes and soaps

C401B

Exterior car waxes, polishes, and coatings

C401C

Interior car care

C401D

Touch up auto paint

C402A

Degreasers

C402B

Liquid lubricants and greases

C402C

Paste lubricants and greases

C402D

Spray lubricants and greases

C403A

Anti-freeze liquids

C403B

De-icing liquids

C403C

De-icing solids

C403D

Lock de-icers/releasers

C404A

Cooking and heating fuels

C404B

Fuel additives

C404C

Vehicular or appliance fuels

C405A

Explosive materials

C406A

Agricultural non-pesticidal products
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Code
C407A

Category
Lawn and garden care products

Chemical Substances in Products not Described by Other Codes
C980A

Non-TSCA use

C909A

Other (specify)

4.9.3.2 Functional Use for Consumer and/or Commercial Products
For each consumer and/or commercial product category reported, select from the dropdown box in the “Function Category” column in Part III.B of the Form U the code(s) that
designates the function category(ies) that best represents the specific manner in which the
chemical substance is used (40 CFR 711.(b)(4)(ii)(B)). These codes are the same as those used
above in Table 4-15 to report the appropriate Function Category for industrial processing and
use. A particular function category may need to be reported more than once, to the extent that a
submitter reports more than one consumer or commercial product category that applies to a
given function category under this paragraph. If none of the listed function categories accurately
describes a use of a chemical substance, the category “Other” may be used, and must include a
description of the use. The written description should be used to provide a description at a
comparable level of specificity as found with the current codes. It should not be used to add
additional, more specific detail.
4.9.3.3 Consumer and/or Commercial Use
For each Product Category reported, select from the drop-down box in the “Consumer
and/or Commercial” column in Part III.B of Form U the options to indicate whether the use is a
consumer use or a commercial use (40 CFR 711.15b)(4)(ii)(C). If the product has both consumer
and commercial uses, select both options.
4.9.3.4 Use in Product(s) Intended for Use by Children
Within each consumer product category reported, you must determine whether any
amount of each reportable chemical substance manufactured (including imported) by you is
present in or on any consumer product(s) intended for use by children age 14 or younger,
regardless of the concentration of the chemical substance remaining in or on the product (40
CFR 711.15(b)(4)(ii)(D)). If you determine that your chemical substance or mixture is used in a
consumer product intended for use by children, select “Yes” from the drop-down box in the
“Used in Product(s) Intended for Children” column in Part III.B of Form U. If you determine
that your chemical substance or mixture is not used in a consumer product intended for use by
children, select “No” from the drop-down box. If information as to whether the chemical
substance is used in or on any consumer products intended for use by children is not known to
or reasonably ascertainable by you, select “NKRA” from the drop-down box. If your chemical
substance is not used in products intended for use by children (i.e., you answered ‘No’ in Part
III.B), you are encouraged not to claim the information as confidential.
EPA defines “intended for use by children” to mean the chemical substance or mixture is
used in or on a product that is specifically intended for use by children age 14 or younger (40
CFR 711.3). Your chemical substance or mixture is intended for use by children if you answer
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“yes” to at least one of the following questions about the product into which your chemical
substance or mixture is incorporated:
•

Is the product commonly recognized (i.e., by a reasonable person) as being intended for
use by children age 14 or younger?

•

Does the manufacturer of the product state through product labeling or other written
materials that the product is intended or will be used by children age 14 or
younger?

•

Is the advertising, promotion, or marketing of the product aimed at children age 14 or
younger?

Table 4-20 illustrates some examples of “Use in Product(s) Intended for Use by
Children.” For example, certain products (e.g., crayons, coloring books, diapers, and toy cars)
are typically used by children age 14 or younger. If you determine that your chemical substance
or mixture is used in crayons, for example, you would report “Y” for children’s use for C305.
Certain products, such as household cleaning products, automotive supplies, and
lubricants, typically are not intended to be used by children age 14 or younger. As such, if you
determine that your chemical substance or mixture is used in automotive care products and
lubricants, for example, you would report “no” for children’s use for categories C401 and C402.
Table 4-20. Examples of Products Intended for Use by Children
Codes
Category
Chemical Substances in Furnishings, Cleanings, Treatment Care Products

Examples

C102A

Furniture & furnishings including Plastic
articles (soft); Leather articles

Child’s car seat, children’s sheets

C103A

Furniture & furnishings including Stone,
plaster, cement, glass and ceramic articles;
Metal articles; or Rubber articles

Baby cribs, changing tables

C104C
C104D

Textile (fabric) dyes
Textile finishing and impregnating/surface
treatment products

Children’s clothing
Children’s clothing, children’s sheets, child’s car
seat

C108A

Liquid Body Soap

Baby shampoo, children’s bubble bath

Chemical Substances in Construction, Paint, Electrical and Metal Products
C205A
Machinery, mechanical appliances,
Electronic games, remote control cars
electrical/electronic articles
C207A

Batteries

Batteries used in toys

Chemical Substances in Packaging, Paper, Plastic, Hobby Products
C302B
Other articles with routine direct contact
Diapers, baby wipes, coloring books
during normal use, including paper articles

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C304A

Toys intended for children’s use (and child
dedicated articles), including Fabrics, textiles,
and apparel; or Plastic articles (hard)

Pacifiers, toy trucks, dolls, toy cars, wagons, action
figures, balls, swing sets, slides, skates, baseball
gloves, kid’s rake

C305A

Adhesives applied at elevated temperatures

Craft glue for a hot glue gun

C305C

Crafting glue

Craft glue

C305D

Crafting Paint (applied to body)

Chemicals used to add color to body paint, finger
paints

4.9.3.5 Percentage of Production Volume
Estimate the percentage of your production volume that is attributable to each specific
consumer and commercial end use carried out at sites under your control, as well as at sites that
receive a reportable chemical substance from you either directly or indirectly (including through
a broker/distributor, from a customer, etc.), to the extent that such information is known to or
reasonably ascertainable to you (40 CFR 711.15(b)(4)(ii)(E)). You should round estimates to the
nearest ten percent of production volume (40 CFR 711.15(b)(4)(ii)(E)). If you would like to
provide more specific percentages, please do so. You may not round a consumer and
commercial product category that accounts for five percent or less of the total production volume
attributable to that consumer and commercial product category is greater than or equal to 25,000
lb. (40 CFR 711.15(b)(4)(ii)(E). In such cases, you must report the percentage of production
volume attributable to that consumer and commercial product category to the nearest one percent
of the production volume (40 CFR 711.15(b)(4)(ii)(E).
Note that the total
percentage of production
volumes reported may add up
to more or less than 100
percent. Rounding to the
nearest ten percent can result in
summed percentages either
above or below 100 percent.
Additionally, the total
percentage of production
volume may add up to less than
100 percent if, for example:
•
•
•

How to determine your percent production volume:
1. Determine the production volume that is attributable to
each consumer and commercial end use.
2. Determine your total production volume for 2015.
a. Add together the volume domestically
manufactured and the volume imported.
b. DO NOT subtract the volume used on-site or the
volume exported
3. Divide the volume determined in step 1 by the volume
determined in step 2 and multiply by 100.

You do not know or cannot reasonably ascertain information about how all your
production volume is used in consumer and commercial products;
More than ten commercial or consumer product categories are applicable to your
chemical substance; or
A portion of your production is consumed in industrial uses or exported.

4.9.3.6 Maximum Concentration Code
When the chemical substance you manufacture (including import) is used in commercial
or consumer products, you are required to report the estimated typical maximum concentration
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(measured by weight) of each chemical substance in each commercial or consumer product
category reported in Part III of Form U (40 CFR 711.15(b)(4)(ii)(F)). For each chemical
substance used in a reported commercial or consumer product, select from the drop-down box
the code that corresponds to the appropriate concentration range. Table 4-10 shows the codes
and concentration ranges which appear in the drop-down box.
4.9.3.7 Number of Commercial Workers Code
Report the total number of commercial workers, including those at sites not under your
control that are reasonably likely to be exposed while using the reportable chemical substance,
with respect to each commercial use (40 CFR 711.15(B)(4)(II)(G)). For each chemical substance
with a commercial use reported in Part III, select code which corresponds to the appropriate
range of commercial workers reasonably likely to be exposed. Table 4-18 shows the code and
worker ranges which appear in the drop-down box.
“Reasonably likely to be exposed” means “an exposure to a chemical substance which,
under foreseeable conditions of manufacture (including import), processing, distribution in
commerce, or use of the chemical substance, is more likely to occur than not to occur. Such
exposures would normally include, but would not be limited to, activities such as charging
reactor vessels, drumming, bulk loading, cleaning equipment, maintenance operations, materials
handling and transfers, and analytical operations. Such exposures also include commercial
worker exposure during the use phase which could include but is not limited to using cleaning
products, paints, dry cleaning solvents, and adhesives. Covered exposures include exposures
through any route of entry (inhalation, ingestion, skin contact, absorption, etc.), but excludes
accidental or theoretical exposures” (40 CFR 711.3).
Persons reasonably likely to be exposed to a chemical substance include workers whose
employment requires them to pass through areas where chemical substances are processed or
used (e.g., production workers and foremen, process engineers, and plant managers). Workers
employed to drive vehicles that transport the chemical substances should be included in the
number of workers reasonably likely to be exposed to the chemical substance if they come into
contact with the chemical substance during loading or unloading. For example, workers engaged
in the connection or disengagement of hoses used to load or unload the chemical substance
should be included. However, workers involved solely with transporting chemical substances in
sealed (totally enclosed with no potential for exposure) containers should not be included.
Similarly, workers employed during the use phase at sites not under your control such as
workers that provide commercial cleaning services, painting, dry cleaning, and repairs should be
included in the number of workers reasonably likely to be exposed to the chemical substance.
In addition, when a site employs temporary, seasonal, or contract workers in the
processing or use of a reportable chemical substance, these workers should be included in the
number of workers reasonably likely to be exposed to a chemical substance if they work in areas
where the chemical substance is processed or used. The term does not include those employees
whose jobs are unassociated with potential exposures to a chemical substance or mixture (e.g.,
administrative staff who never enter areas where the chemical substance is manufactured) and
who are unlikely to be exposed to a chemical substance for even a brief period of time. No
allowance is made for personal protective equipment or for engineering controls that reduce but
do not preclude exposure to a chemical substance; however, if contact between a worker and a
chemical substance is highly improbable, the worker should not be included among those

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persons reasonably likely to be exposed to the chemical substance.
4.9.4

Special Provisions for Manufacturing by Contract

When a company contracts with a producing company to manufacture a chemical
substance and each party meets the definition of manufacturer as set forth in 40 CFR 711.3, the
contracting company (as the primary submitter) has the responsibility to initiate a co-manufacture
report that triggers the reporting requirements for the producing company (as the secondary
submitter). The contracting company completes the processing and use-related information
described in Sections 4.9.1 to 4.9.3 of this document.
4.9.5

Special Provisions for Joint Submitters of Unknown Chemical Substances

In the situation where a primary submitter, such as an importer, has sent a request to a
secondary submitter, such as a foreign supplier, to provide the chemical composition of an
imported product or mixture, the secondary submitter must also provide the chemical-specific
function of each constituent substance along with information on chemical composition of the
imported product or mixture. See Section 4.9.2.3 for additional information about reporting the
function of a chemical substance.

4.10 Manufacturing by Contract: Co-manufacture Report
4.10.1 Determining the Need for a Co-manufacture Report when Manufacturing by Contract
A manufacturing by contract (co-manufacturing) relationship occurs when a chemical
substance, manufactured other than by import, is produced exclusively for another person who
contracts for such production. To be considered a co-manufacture situation, the producing company
produces the chemical substance exclusively for another person (the contracting manufacturer) under
contract for that production. If the chemical substance is produced for other purposes, then the situation
fails this first test of “co-manufacturing.” In addition, the other person contracting the manufacture
(i.e., the contracting company) specifies the identity of the chemical substance, the total amount
produced, and the basic technology for the plant process. This is the second test of “co-manufacturing.”
To be considered co-manufacturers, both of these tests must be met. See Appendix A for the definition
of “manufacture” (40 CFR 711.3).
Companies that are co-manufacturing a chemical substance each contribute to completing the
required CDR report for that chemical substance. In this type of multi-reporter submission, the
contracting company is the primary submitter and the producing company is the secondary submitter.
As the primary submitter, the contracting company is responsible for initiating a co-manufacture report
that prompts the reporting requirements for the producing company (as the secondary submitter).
This reporting process helps to protect the confidentiality of both the producing company and
contracting company by ensuring that the contracting company would not require any potentially
confidential information from the producing company. This method also eliminates confusion between
the two involved parties by designating the contracting company as the primary submitter responsible
for initiating the reporting process. As with past reporting under CDR, both parties are liable for
reporting the co-manufactured chemical under CDR.
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NOTE: In the event that the contracting company knows or can reasonably ascertain the
information that would otherwise be reported by the producing company, the contracting
company may instead solely report and not initiate a co-manufacture report. In this
situation, the contracting company must still provide the producing company’s site address
as the site of manufacture.
4.10.2 The Primary Report is Completed by the Contracting Company
The contracting company, as the primary submitter, is responsible for initiating the comanufacture report, uses e-CDRweb to notify the producing company of its need to complete the
secondary portion of the co-manufacture report, and completes the primary portion of the
manufacturing-related section (Form U Part II) (40 CFR 711.15(b)(3)) and the processing and userelated section (Form U Part III) (40 CFR 711.15(b)(4)).
Identifying the manufacturing site for the co-manufactured chemical substance
In its portion of the co-manufacture report, the primary submitter identifies the site of
manufacture of the co-manufactured chemical substance, which is always the producing company’s
site. See Section 4.4.1.2 for additional information.
Notifying the producing company about the co-manufacture report
Using the e-CDRweb reporting tool, the contracting company enters the email address of the
producing company, and any necessary instruction for the producing company to complete its part of
the co-manufacture report, into a system generated email. Also contained within the email is the
unique identifier. The primary submitter may send the email before it has completed its part of the comanufacture report.
Completing the primary portion of the co-manufacture report
The contracting company is responsible for completing portions of Part II (manufacturingrelated) and all of Part III (processing- and use-related) of Form U. Specifically, in Part II the
contracting company provides the chemical identity and the volume manufactured. See Sections 4.7.5
and 4.8.4 of this document for additional information about Part II and Section 4.9.4 for additional
information about Part III.
The contracting company completes any other chemical reports as part of its overall Form U
submission and submits one Form U, including any co-manufacture reports, for its site. For specific
instructions on how to report using the e-CDRweb reporting tool, see the appropriate e-CDRweb User
Guide, available at https://www.epa.gov/chemical-data-reporting/how-report-under-chemical-datareporting.

4.10.3 The Secondary Report is Completed by the Producing Company
The producing company, as the secondary submitter, is responsible for identifying that it is
providing information for the co-manufacture report using the information (e.g., identification number)
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provided by the primary submitter and completes the secondary portion of the manufacturing-related
section (Form U Part II) (40 CFR 711.15(b)(3)).
Receiving notification from the contract company about the co-manufacture report
The producing company receives an email from the contractor identifying that a comanufacture report has been initiated and providing unique identification number needed for the
producing company to complete its part of the co-manufacture report.
Identifying the manufacturing site for the co-manufactured chemical substance
In its portion of the co-manufacture report, the secondary submitter confirms that its site is the
site of manufacture of the co-manufactured chemical substance. See Section 4.4.1.2 for additional
information.
Completing the secondary portion of the co-manufacture report
The producing company is responsible for completing portions of Part II (manufacturingrelated) of Form U that were not completed by the contractor. Specifically, in Part II the producing
manufacturer provides the volume manufactured and the rest of the Part II information except for the
chemical identification, which is reported by the contracting company. See Sections 4.7.5 and 4.8.4 of
this document for additional information about Part II.
The producing company completes any other chemical reports as part of its overall Form U
submission and submits one Form U, including any co-manufacture reports, for its site. For specific
instructions on how to report using the e-CDRweb reporting tool, see the appropriate e-CDRweb User
Guide, available at https://www.epa.gov/chemical-data-reporting/how-report-under-chemical-datareporting.

4.10.4 Confidentiality of Information on a Co-manufacture Report
All of the confidentiality requirements discussed earlier in these Instructions apply to
information submitted jointly. However, multi-reporter submissions include information required to
connect the two reports and their related data. For example, a manufacturing by contract comanufacture report requires that the primary submitter provide their producing company identity. As
the primary submitter you are required to report your producing company’s identity, which you may
claim as confidential without providing substantiation at the time your claim is made, because your
producing company is considered your supplier (40 CFR 711.30(a)(3)(ii)).
Because signatures are required by each party of a multi-reporter submission, they must
each register with CDX, and complete their own sections of the overall Form U report. (See
separate CDR registration and e-CDRweb User Guides). The reporting tool will match the two
portions of a multi-reporter chemical report based upon the unique ID number sent by the
contracting company to notify the producing company of the partial CDR submission. Producing
companies do not have access to any of the information submitted to EPA by the contracting
company. Likewise, contracting companies cannot see the information that the producing
company reports to EPA. This way, the confidentiality of information for all submitters is
protected. The information provided by both submitters will be combined and processed as one
co-manufacture report once they are received by EPA.

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4.11 Joint Submissions using Part IV – Unknown Chemical Identity
4.11.1 Determining the Need for a Joint Submission using Part IV
Joint submissions are allowed in those instances where a supplier will not disclose to the
manufacturer (including importer) the specific chemical name of the imported chemical substance
or of a reactant used to manufacture a chemical substance, because the supplier claims the
specific chemical name is confidential.
This may happen, for instance, when a company is importing a mixture under a trade
name, and the foreign manufacturer refuses to reveal the chemical identity of a confidential
component of the mixture. In this case, the importer and the supplier can jointly report the
information through a joint submission. The importer must ask the supplier of the confidential
chemical substance to directly provide EPA with the correct chemical identity in Part IV of Form
U (see 40 CFR 711.15(b)(3)(i)(A)).
This may also happen in the event a manufacturer cannot provide the entire chemical
identity of a chemical substance it manufactures because the chemical substance is manufactured
using a reactant having a specific chemical identity that the reactant supplier claims as
confidential and will not reveal to the manufacturer. In this case, the manufacturer and the
supplier of the reactant can jointly report the information through a joint submission. The
manufacturer must submit a report directly to EPA containing all information he or she knows or
can reasonably ascertain about the chemical identity, including the chemical-specific function
along with information on chemical composition. Furthermore, the manufacturer must also ask
the reactant supplier to directly provide to EPA the correct chemical identity of the confidential
reactant in Part IV of Form U (see 40 CFR 711.15(b)(3)(i)(B)). More detailed instructions for
completing a joint submission can be found in the e-CDRweb user guides.
A manufacturer (including importer) can identify, on a chemical-by-chemical basis, the
supplier for a chemical substance. A site may have different suppliers for different chemical
substances in its overall Form U submission. The e-CDRweb tool will generate a unique ID
number for each chemical substance (identified by a trade name). Therefore, a supplier may
receive multiple ID numbers from a manufacturer (including importer). A supplier may also
report multiple chemical substances under one ID number in the case that the ID number refers
to a mixture. In that situation, the supplier will be identifying the chemical substances that
comprise the mixture.
It is the responsibility of the primary submitter to ask their supplier, or secondary
submitter, to complete Part IV of Form U and send the information to EPA by the end of the
submission period. The e-CDRweb electronic reporting tool leads the primary submitter through
this notification process.
If the secondary submitter decides to provide you directly with the required trade name
product information, you should change your submission type and submit a single submission.
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4.11.2 The Primary Submission is Completed by the Importer or Reactant User
The primary submitter for a joint submission is either an importer or a manufacturer using a
reactant of unknown chemical identity. For ease of presentation, both types of primary submitters will
be referred to as “importer.” The importer, as the primary submitter, is responsible for initiating the
joint submission, uses e-CDRweb to notify its supplier of the need to complete the secondary portion
of the joint submission, and completes the manufacturing-related section (Form U Part II) (40 CFR
711.15(b)(3)) and the processing and use-related section (Form U Part III) (40 CFR 711.15(b)(4)) for
the imported substance.
Identifying the chemical identity of the unknown chemical substance and its supplier
In its portion of the joint submission, the primary submitter identifies the proprietary substance
or mixture using the trade name or another name, additional information as needed to help the supplier
correctly identify the substance, and the identity and contact information for the supplier. See Section
4.4.1.1 and 4.7.7 for additional information.
Notifying the supplier about the joint submission
Using the e-CDRweb reporting tool, the importer enters the email address of the supplier, and
any necessary instruction for the supplier to complete its part of the joint submission, into a system
generated email. Also contained within the email is the unique identifier. The primary submitter may
send the email before it has completed its part of the joint submission.
Completing the primary portion of the joint submission
The importer is responsible for completing the rest of Part II (manufacturing-related) and Part
III (processing- and use-related) of Form U as it relates to the proprietary substance or mixture. See
Sections 4.8 and 4.9 of this document for additional information about completing Part II and Part III.
The importer completes any other chemical reports as part of its overall Form U submission and
submits one Form U, including any joint submission, for its site. For specific instructions on how to
report using the e-CDRweb reporting tool, see the appropriate e-CDRweb User Guide, available at
https://www.epa.gov/chemical-data-reporting/how-report-under-chemical-data-reporting.

4.11.3 The Secondary Submission is Completed by the Supplier (Foreign or Reactant)
The supplier, as the secondary submitter, is responsible for identifying that it is providing
information for the joint submission using the information (e.g., identification number) provided by the
primary submitter and completing Part IV of Form U.
Receiving notification from the importer about the joint submission
The supplier receives an email from the importer identifying that a joint submission has been
initiated and providing unique identification number needed for the supplier to complete its part of the
joint submission.
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Completing Form U Part IV, the secondary portion of the joint submission
The supplier is responsible for completing Part IV of the joint submission, which includes its
company identity, a technical contact, identification of its customer (e.g., the primary submitter), the
product trade name, and the unique identifier supplied by the primary submitter. The supplier then
provides the chemical identity and composition of the product and the function of each chemical in the
product. Additional information is provided elsewhere in this document. Specifically, see Section 4.7
for information about chemical identity and 4.9.5 for information about chemical function.
For specific instructions on how to report using the e-CDRweb reporting tool, see the
appropriate e-CDRweb User Guide, available at https://www.epa.gov/chemical-data-reporting/howreport-under-chemical-data-reporting.
When the supplier doesn’t know the identity
There may be instances where a foreign supplier purchases a mixture, under a trade
name, from another company (tertiary company) and does not know the chemical components
of the mixture. The foreign supplier can ask the company manufacturing the trade secret
mixture or chemical substance to directly provide EPA with the correct chemical identity in
Part IV of Form U. In this case, the tertiary company would register with CDX and use the
Unique Identifier for Joint Submissions, sent to the foreign supplier by the manufacturer
(including importer), to complete Part IV of Form U.
Under this scenario, the foreign supplier does not have access to any of the information
submitted to EPA by the tertiary company. Likewise, the tertiary company cannot see the
information the foreign supplier reports to EPA. This way, the confidentiality of information for
both the foreign supplier and tertiary company is protected.
4.11.4 Confidentiality of Information Jointly Submitted
All of the confidentiality requirements discussed earlier in these Instructions apply to
information submitted jointly. However, joint submissions include information required to connect the
two reports and their related data. For example, a joint submission requires that the primary submitter
provide its trade name and supplier identity. A secondary submitter would provide the composition of
its product.
These data elements specific to joint submissions do require that claims of confidentiality be
made, but do not require upfront substantiation:
•
•

Joint submission information from the primary submitter including trade name and supplier
identification required pursuant to § 711.15(b)(3)(i)(A), (B), and (C).
Joint submission information from the secondary submitter including the percentage of
formulation required pursuant to § 711.15(b)(3)(i)(A), (B), and (C). (40 CFR 711.30(a)(3))

Because signatures are required by each party of a joint submission, they must each
register with CDX, and complete their own sections of the same Form U report. (See separate
CDR registration and e-CDRweb User Guides). The reporting tool will match both submissions
based upon the unique ID number sent by the manufacturer (including importer) to notify the
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supplier of the partial CDR submission. Suppliers do not have access to any of the information
submitted to EPA by the manufacturer. Likewise, manufacturers cannot see the information that
the supplier reports to EPA. This way, the confidentiality of information for all submitters is
protected. The information provided by both submitters will be combined and processed as one
joint submission once they are received by EPA.
NOTE: In the event that a manufacturer (including importer) actually knows or can
reasonably ascertain the chemical identity (e.g., the CASRN or Accession Number) of a
chemical substance subject to CDR reporting, the manufacturer (including importer) must
provide that information irrespective of a supplier’s confidentiality claims. If such a
primary submitter wishes to claim the chemical identity as confidential, to do so they must
check the CBI box and provide upfront substantiation as described in 4.7.1 of this chapter.

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Chapter 5

How to Obtain Copies of Documents Cited in This Instructions Document

5. How to Obtain Copies of Documents Cited in
This Instructions Document
5.1 Obtaining Copies of the TSCA Rules
The CDR rule, 40 CFR Part 711, is available on the U.S. Government Publishing
Office website, www.ecfr.gov.
You may also contact the TSCA Hotline by telephone at (202) 554-1404 or by email
[email protected] for assistance.

5.2 Obtaining Copies of the Public Portion of the TSCA Inventory
Information on how to access the non-confidential version of the TSCA Inventory and
help using the files is available on EPA’s website at www.epa.gov/tsca-inventory.

5.3 Obtaining Copies of Other Information Materials for the 2020
CDR
EPA has developed documents to provide additional information on submitting
information for the 2020 CDR. All materials are available on the “How To Report Under
Chemical Data Reporting” page of the CDR website at www.epa.gov/chemical-datareporting/how-report-under-chemical-data-reporting.
Reporting Electronically: [note: these documents have not yet been updated, but will be prior
to the start of the 2020 submission period]
• Instructions on CDX registration
• e-CDRweb user guides
• Schemas and Schema guides
2020 Chemical Data Reporting Frequent Questions
Fact Sheets: [note: these documents have not yet been updated, but will be prior to the start of
the 2020 submission period]
• Reporting Thresholds for 2020
• Chemical Substances which are the Subject of Certain TSCA Actions
• Reporting After Changes to Company Ownership or Legal Identity
• Importers
• Imported Articles
• Co-Manufacturing
• Byproducts Reporting for the Printed Circuit Board Industry
Webinars and Training:
• 2020 CDR Reporting Requirements Presentations

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Appendix A

Glossary

Appendix A
Glossary
The definitions and descriptions of terms used in CDR reporting provided below are
taken from 40 CFR Part 711 unless otherwise noted.
Act means the Toxic Substances Control Act, as amended, 15 U.S.C. 2601 et seq.
Administrator means the Administrator of the Environmental Protection Agency. (See
TSCA 3(1))
Article means a manufactured item (1) which is formed to a specific shape or design
during manufacture, (2) which has end-use function(s) dependent in whole or in part upon its
shape or design during end use, and (3) which has either no change of chemical composition
during its end use or only those changes of composition which have no commercial purpose
separate from that of the article, and that result from a chemical reaction that occurs upon end
use of other chemical substances, mixtures, or articles; except that fluids and particles are not
considered articles regardless of shape or design. (40 CFR 704.3)
Byproduct means a chemical substance produced without separate commercial intent
during the manufacture, processing, use, or disposal of another chemical substance(s) or
mixture(s). (40 CFR 704.3)
Central Data Exchange (CDX) means EPA's centralized electronic document receiving
system, or its successors, including associated instructions for registering to submit electronic
documents.
Chemical substance means any organic or inorganic substance of a particular molecular
identity, including any combination of such substances occurring in whole or in part as a result
of a chemical reaction or occurring in nature, and any element or uncombined radical.
“Chemical substance” does not include:
(1) Any mixture;
(2) Any pesticide (as defined in the Federal Insecticide, Fungicide, and Rodenticide Act)
when manufactured, processed, or distributed in commerce for use as a pesticide;
(3) Tobacco or any tobacco product;
(4) Any source material, special nuclear material, or byproduct material (as such terms
are defined in the Atomic Energy Act of 1954 [42 U.S.C. 2011 et seq.] and the
regulations issued under such Act);
(5) Any article the sale of which is the subject to the tax imposed by section 4181 of the
Internal Revenue Code of 1986 [26 U.S.C. 4181] (determined without regard to any
exemptions from such tax provided by section 4182 or 4221 or any other provision of
such Code) and any component of such an article (limited to shot shells, cartridges, and
components of shot shells and cartridges); and
(6) Any food, food additive, drug, cosmetic, or device (as such terms are defined in
section 201 of the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 321]) when
manufactured, processed, or distributed in commerce for use as a food, food additive,
drug, cosmetic, or device. (See TSCA 3(2))
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Appendix A

Glossary

Commerce means trade, traffic, transportation, or other commerce: (A) between a place
in a State and any place outside of such State, or (B) which affects trade, traffic, transportation,
or commerce described in clause (A). (TSCA 3(3))
Commercial use means the use of a chemical substance or a mixture containing a
chemical substance (including as part of an article) in a commercial enterprise providing saleable
goods or services.
Consumer use means the use of a chemical substance or a mixture containing a chemical
substance (including as part of an article) when sold to or made available to consumers for their
use.
Customs territory of the United States, as referenced in TSCA section 3 and defined in
general note 2 of the Harmonized Tariff Schedule of the United States, includes only the States,
the District of Columbia, and Puerto Rico.
Distribute in commerce and distribution in commerce, when used to describe an
action taken with respect to a chemical substance or mixture or article containing a substance or
mixture mean to sell, or the sale of, the substance, mixture, or article in commerce; to introduce
or deliver for introduction into commerce, or the introduction or delivery for introduction into
commerce of, the substance, mixture, or article; or to hold, or the holding of, the substance,
mixture, or article after its introduction into commerce. (TSCA 3(5))
e-CDRweb means the electronic, web-based tool provided by EPA for the completion
of Form U and submission of the CDR data.
EPA means the United States Environmental Protection Agency. (40 CFR 704.3)
Importer means
(1) any person who imports any chemical substance or any chemical substance as part of a
mixture or article into the customs territory of the United States, and includes:
(i) the person primarily liable for the payment of any duties on the merchandise, or
(ii) an authorized agent acting on his/her behalf.
(2) Importer also includes, as appropriate:
(i) The consignee.
(ii) The importer of record.
(iii) The actual owner if an actual owner's declaration and superseding bond have been
filed in accordance with 19 CFR 141.20.
(iv) The transferee, if the right to draw merchandise in a bonded warehouse has been
transferred in accordance with subpart C of 19 CFR part 144.
(3) For the purposes of this definition, the customs territory of the United States consists of the
50 States, Puerto Rico, and the District of Columbia. (40 CFR 704.3)
Impurity means a chemical substance which is unintentionally present with another
chemical substance. (40 CFR 704.3)
Industrial function means the intended physical or chemical characteristic for which a
chemical substance or mixture is consumed as a reactant; incorporated into a formulation,
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Appendix A

Glossary

mixture, reaction product, or article; repackaged; or used.
Industrial use means use at a site at which one or more chemical substances or mixtures
are manufactured (including imported) or processed.
Inorganic chemical substance means any chemical substance which does not contain
carbon or contains carbon only in the form of carbonato [=CO3], cyano [-CN], cyanato [-OCN],
isocyano [-NC], or isocyanato [-NCO] groups, or the chalcogen analogues of such groups.
Intended for use by children means the chemical substance or mixture is used in a
product that is specifically intended for use by children age 14 or younger. A chemical substance
or mixture is intended for use by children when the submitter answers “yes” to at least one of the
following questions for the product into which the submitter’s chemical substance or mixture is
incorporated:
(1) Is the product commonly recognized (i.e., by a reasonable person) as being intended
for children age 14 or younger?
(2) Does the manufacturer of the product state through product labeling or other written
materials that the product is intended or will be used by children age 14 or younger?
(3) Is the advertising, promotion, or marketing of the product aimed at children age 14 or
younger?
Intermediate means any chemical substance that is consumed, in whole or in part, in
chemical reactions used for the intentional manufacture of other chemical substances or
mixtures, or that is intentionally present for the purpose of altering the rates of such chemical
reactions. (40 CFR 704.3)
Known to or reasonably ascertainable by means all information in a person’s
possession or control, plus all information that a reasonable person similarly situated might be
expected to possess, control, or know. (40 CFR 704.3)
Manufacture means to manufacture, produce, or import for commercial purposes.
Manufacture includes the extraction, for commercial purposes, of a component chemical
substance from a previously existing chemical substance or complex combination of substances.
A chemical substance is co-manufactured by the person who physically does the manufacturing
and the person contracting for such production when that chemical substance, manufactured
other than by import, is: (1) produced exclusively for another person who contracts for such
production, and (2) that other person dictates the specific identity of the chemical substance and
controls the total amount produced and the basic technology for the manufacturing process.
Manufacturer means a person who manufactures a chemical substance.
Manufacture for commercial purposes means: (1) to import, produce, or manufacture
with the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer, and includes among other things, such “manufacture” of any amount of a chemical
substance or mixture:
(i)
For commercial distribution, including for test marketing.
(ii)
For use by the manufacturer, including use for product research and
development, or as an intermediate.
(2) Manufacture for commercial purposes also applies to substances that are produced
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Appendix A

Glossary

coincidentally during the manufacture, processing, use, or disposal of another substance or
mixture, including both byproducts that are separated from that other substance or mixture
and impurities that remain in that substance or mixture. Such byproducts and impurities
may, or may not, in themselves have commercial value. They are nonetheless produced for
the purpose of obtaining a commercial advantage since they are part of the manufacture of
a chemical product for a commercial purpose. (40 CFR 704.3)
Master Inventory File means EPA's comprehensive list of chemical substances which
constitute the Chemical Substances Inventory compiled under section 8(b) of the Act. It includes
substances reported under 40 CFR Part 710 and substances reported under Part 720 for which a
Notice of Commencement of Manufacture or Import has been received under §720.120.
Microorganism means any combination of chemical substances that is a living organism
and that meets the definition of microorganism at 40 CFR 725.3. Any chemical substance
produced from a living microorganism is reportable under the CDR regulation unless otherwise
excluded.
Mixture means any combination of two or more chemical substances if the combination
does not occur in nature and is not, in whole or in part, the result of a chemical reaction; except
that such term does include any combination which occurs, in whole or in part, as a result of a
chemical reaction if none of the chemical substances comprising the combination is a new
chemical substance and if the combination could have been manufactured for commercial
purposes without a chemical reaction at the time the chemical substances comprising the
combination were combined. (TSCA 3(10))
Naturally occurring substance is any chemical substance which is naturally occurring
and: (1) which is (i) unprocessed or (ii) processed only by manual, mechanical, or gravitational
means, by dissolution in water, by flotation, or by heating solely to remove water; or (2) which is
extracted from air by any means. (40 CFR 710.4(b))
Non-isolated intermediate means any intermediate that is not intentionally removed
from the equipment in which it is manufactured, including the reaction vessel in which it is
manufactured, equipment which is ancillary to the reaction vessel, and any equipment through
which the substance passes during a continuous flow process, but not including tanks or other
vessels in which the substance is stored after its manufacture. (40 CFR 704.3)
Parent Company means the highest-level company(s) of the site’s ownership hierarchy
as of the start of the submission period during which data are being reported according to the
following instructions. The U.S. parent company is located within the United States while the
foreign parent company is located outside the United States:
(1) If the site is entirely owned by a single U.S. company that is not owned by another
company, that single company is the U.S. parent company.
(2) If the site is entirely owned by a single U.S. company that is, itself, owned by
another U.S.-based company (e.g., it is a division or subsidiary of a higher-level
company), the highest-level company in the ownership hierarchy is the United States
parent company. If there is a higher-level parent company that is outside of the United
States, the highest-level foreign company in the ownership hierarchy is the foreign
parent company.
(3) If the site is owned by more than one company (e.g., company A owns 40 percent,
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Appendix A

Glossary

company B owns 35 percent, and company C owns 25 percent), the highest-level U.S.
company with the largest ownership interest in the site is the U.S. parent company. If
there is a higher-level foreign company in the ownership hierarchy, that company is the
foreign parent company.
(4) If the site is owned by a 50:50 joint venture or a cooperative, the joint venture or
cooperative is its own parent company. If the site is owned by a U.S. joint venture or
cooperative, the highest level of the joint venture or cooperative is the U.S. parent
company. If the site is owned by a joint venture or cooperative outside the United States,
the highest level of the joint venture or cooperative outside the United States is the
foreign parent company.
(5) If the site is entirely owned by a foreign company (i.e., without a U.S.-based
subsidiary within the site’s ownership hierarchy), the highest-level foreign parent
company is the facility’s foreign parent company.
(6) If the site is federally owned, the highest-level federal agency or department is the
U.S. parent company.
(7) If the site is owned by a non-federal public entity, that entity (such as a municipality,
State, or tribe) is the U.S. parent company.
Person means any individual, firm, company, corporation, joint venture, partnership, sole
proprietorship, association, or any other business entity; any State or political subdivision
thereof, or any municipality; any interstate body; and any department, agency, or instrumentality
of the Federal government. (40 CFR 704.3)
Polymer means any chemical substance described with the word fragments “*polym*”,
“*alkyd”, or “oxylated” in the Chemical Abstracts (CA) Index Name in the Master Inventory
File, where the asterisk (*) in the listed word fragments indicates that any sets of characters may
precede, or follow, the character string defined. Polymers also include any chemical substance
which is identified in the Master Inventory File as siloxane(s) and silicone(s), silsesquioxane(s),
a protein (albumin, casein, gelatin, gluten, hemoglobin), an enzyme, a polysaccharide (starch,
cellulose, or gum), rubber, or lignin. The polymer exclusion does not apply to a polymeric
substance that has been hydrolyzed, depolymerized, or otherwise chemically modified, except in
cases where the intended product of this reaction is totally polymeric in structure.
Principal reporting year means the latest complete calendar year preceding the
submission period.
Process means to process for commercial purposes. (40 CFR 704.3)
Process for commercial purposes means the preparation of a chemical substance or
mixture after its manufacture for distribution in commerce with the purpose of obtaining an
immediate or eventual commercial advantage for the processor. Processing of any amount of a
chemical substance or mixture is included in this definition. If a chemical substance or mixture
containing impurities is processed for commercial purposes, then the impurities also are
processed for commercial purposes. (40 CFR 704.3)
704.3)

Processor means any person who processes a chemical substance or mixture. (40 CFR
Reasonably likely to be exposed means an exposure to a chemical substance which,

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Appendix A

Glossary

under foreseeable conditions of manufacture (including import), processing, distribution in
commerce, or use of the chemical substance, is more likely to occur than not to occur. Such
exposures would normally include, but would not be limited to, activities such as charging
reactor vessels, drumming, bulk loading, cleaning equipment, maintenance operations, materials
handling and transfers, and analytical operations. Covered exposures include exposures through
any route of entry (inhalation, ingestion, skin contact, absorption, etc.), but excludes accidental
or theoretical exposures.
Repackaging means the physical transfer of a chemical substance or mixture, as is, from
one container to another container or containers in preparation for distribution of the chemical
substance or mixture in commerce.
Reportable chemical substance means a chemical substance described in §711.5.
Site means a contiguous property unit. Property divided only by a public right-of-way
shall be considered one site. More than one plant may be located on a single site.
(a) For chemical substances manufactured under contract, i.e., by a co-manufacturer, the
site is the location where the chemical substance is physically manufactured.
(b) The site for an importer who imports a chemical substance described in §711.5 is the
U.S. site of the operating unit within the person's organization that is directly responsible
for importing the substance. The import site, in some instances, may be the organization's
headquarters in the United States. If there is no such operating unit or headquarters in the
United States, the site address for the importer is the United States address of an agent
acting on behalf of the importer who is authorized to accept service of process for the
importer.
(c) For portable manufacturing units sent out to different locations from a single
distribution center, the distribution center shall be considered the site.
Site-limited means a chemical substance is manufactured and processed only within a
site and is not distributed for commercial purposes as a substance or as part of a mixture or
article outside the site. Imported substances are never site-limited. Although a site-limited
chemical substance is not distributed for commercial purposes outside the site at which it is
manufactured and processed, the substance is considered to have been manufactured and
processed for commercial purposes.
Small government means the government of a city, county, town, township, village,
school district, or special district with a population of less than 50,000. 40 CFR 704.3)
Small manufacturer means a manufacturer (including importer) that meets either of
the following standards:
(1) First standard. A manufacturer (including importer) of a substance is small if its
total annual sales, when combined with those of its parent company (if any), are less
than $110 million. However, if the annual production or importation volume of a
particular substance at any individual site owned or controlled by the manufacturer or
importer is greater than 45,400 kilograms (100,000 lbs), the manufacturer (including
importer) will not qualify as small for purposes of reporting on the production or
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Appendix A

Glossary

importation of that substance at that site, unless the manufacturer (including importer)
qualifies as small under standard (2) of this definition.
(2) Second standard. A manufacturer (including importer) of a substance is small if its
total annual sales, when combined with those of its parent company (if any), are less
than $11 million, regardless of the quantity of substances produced or imported by that
manufacturer (including importer). (40 CFR 704.3)
Small quantities solely for research and development (or “small quantities solely for
purposes of scientific experimentation or analysis or chemical research on, or analysis of, such
substance or another substance, including such research or analysis for the development of a
product”) means quantities of a chemical substance manufactured, imported, or processed or
proposed to be manufactured, imported, or processed solely for research and development that
are no greater than reasonably necessary for such purposes. (40 CFR 704.3)
State means any State of the United States, the District of Columbia, the Commonwealth
of Puerto Rico, the Virgin Islands, Guam, the Canal Zone, American Samoa, the Northern
Mariana Islands, or any other territory or possession of the United States. (TSCA 3(16))
Submission period means the period in which manufacturing, processing, and use data
are submitted to EPA.
Test marketing means the distribution in commerce of no more than a predetermined
amount of chemical substance, mixture, or article containing that chemical substance or mixture,
or a mixture containing that substance, by a manufacturer or processor, to no more than a defined
number of potential customers to explore market capability in a competitive situation during a
predetermined testing period prior to the broader distribution of that chemical substance,
mixture, or article in commerce. (40 CFR 704.3)
United States, when used in the geographic sense, means all of the States. (TSCA 3(17))
Use means any utilization of a chemical substance or mixture that is not otherwise
covered by the terms manufacture or process. Relabeling or redistributing a container holding a
chemical substance or mixture where no repackaging of the chemical substance or mixture
occurs does not constitute use or processing of the chemical substance or mixture.

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Appendix B

Chemical Substances That Are the Subject of Certain TSCA Actions

Appendix B
Chemical Substances That Are the Subject of Certain TSCA Actions
This appendix provides assistance in determining whether your chemical substance is the
subject of certain TSCA actions that affect your ability to use the exemptions allowed for in the
CDR rule. Certain chemical substances, such as polymers, microorganisms, naturally occurring
substances, certain natural gases, and water, generally are exempted from reporting under CDR (see
40 CFR 711.6). Small manufactures as described in 40 CFR 711.9 also generally are exempted
from reporting under CDR. Table B-1 provides a brief description of these two provisions. If,
however, a chemical substance is the subject of certain TSCA actions, the exemption may no longer
be applicable. Table B-2 provides a comparison of the effects of TSCA actions on different CDR
requirements or exemptions. See Sections 2.1.4 and 2.2.4 for further discussion.
You can access a list of the chemical substances using EPA’s Substance Registry Services
(SRS) at www.epa.gov/srs. In SRS, you can search for either a specific chemical or you can search
for a complete list of chemicals related to a type of regulation or other characteristic that affects the
status of a chemical related to CDR. Note that CDR submitters are ultimately responsible for
adhering to a chemical’s reporting requirements that are based upon the status of the chemical in
SRS on June 1, 2020, which is the first day of the CDR submission period.
To search for a specific chemical, visit the SRS “Search and Retrieve” webpage, type in a
substance name in the “Synonym” field or a CASRN in the “Substance Identifier” field, and select
“Search”. Link to the chemical result that most closely meets your search needs. Select “Program
and Regulatory Information.” You can see the “Statutes/Regulations” and other characteristics that
apply to the chemical.
To search for a list of chemicals that are related to a regulation or other CDR-related
characteristic, visit the SRS “Search and Retrieve” webpage and select “Search by List”. Select the
chemical list that you would like to view and select “Search.” To see only 2020 CDR-specific lists,
type “2020 CDR” in the “Filter” box and select “Filter.”
For more detailed instructions, view How to Search for Chemicals that are the Subject of Certain TSCA
Actions on the CDR website.

B-1

Appendix B

Chemical Substances That Are the Subject of Certain TSCA Actions

Table B-1. Explanation of Reporting Requirements
40 CFR
711

Reporting Requirements

Explanation of Reporting
Requirements

§ 711.6

Some groups or categories of chemical substances are
exempted from some or all of the reporting
requirements of this part, with the following
exception: A chemical substance described in
paragraph (a)(1), (a)(2), or (a)(4), or (b) of this section
is not exempted from any of the reporting
requirements of this part if that chemical substance is
the subject of a rule proposed or promulgated under
TSCA section 4, 5(a)(2), 5(b)(4), or 6, or is the subject
of a consent agreement developed under the
procedures of 40 CFR part 790, or is the subject of an
order issued under TSCA section 4, 5(e), or 5(f), or is
the subject of relief that has been granted under a civil
action under TSCA section 5 or 7.
Any person who manufactured (including imported)
for commercial purposes any chemical substance that
is the subject of a rule proposed or promulgated under
TSCA section 5(a)(2), 5(b)(4), or 6, or is the subject
of an order in effect under TSCA section 4, 5(e) or
5(f), or is the subject of relief that has been granted
under a civil action under TSCA section 5 or 7 is
subject to reporting as described in §711.8(a), except
that the applicable production volume threshold is
2,500 lb (1,134 kg).

Information must be reported
for chemical substances that
would otherwise be wholly
or partially exempted from
CDR requirements because
they are the subject of certain
TSCA actions.

A person described in § 711.8 is not subject to the
requirements of this part if that person qualifies as a
small manufacturer as that term is defined in 40 CFR
704.3. Notwithstanding this exclusion, a person who
qualifies as a small manufacturer is subject to this
part with respect to any chemical substance that is the
subject of a rule proposed or promulgated under
TSCA section 4, 5(b)(4), or 6, or is the subject of an
order in effect under TSCA section 4 or 5(e), or is the
subject of relief that has been granted under a civil
action under TSCA section 5 or 7.

The exemption for small
businesses does not apply to
persons who manufacture
(including import) a
chemical substance that is the
subject of certain TSCA
actions. Even in such
circumstances, however, the
volume thresholds for
reporting found in §711.8
still apply.

§ 711.8

§ 711.9

Chemical substances that are
the subject of certain TSCA
actions are to be reported
based on a lower threshold of
2,500 lbs.

B-2

Appendix B

Chemical Substances That Are the Subject of Certain TSCA Actions

Table B-2. Comparison of the effects of TSCA actions on different CDR requirements or
exemptions
CDR requirement
TSCA action

Subject to 2,500
lb reporting
threshold

TSCA section 4 rules
(proposed or promulgated)
TSCA section 4 orders



Enforceable Consent Agreements
(ECAs)

Not eligible for
certain full or
partial
exemptions from
reporting

Not eligible for
small
manufacturer
exemption











TSCA section 5(a)(2) SNURs
(proposed or promulgated)





TSCA section 5(b)(4) rules
(proposed or promulgated)







TSCA section 6 rules
(proposed or promulgated)







TSCA section 5(e) orders







TSCA section 5(f) orders





TSCA section 5 civil actions







TSCA section 7 civil actions







B-3

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

Appendix C
Chemical Substances Partially Exempt from Reporting in 2020
Chemical substances that are partially exempt from reporting requirements under the
CDR rule in 2020 are listed in 40 CFR 711.6(b)(1) and 711.6(b)(2); these lists are included
below. Note that inorganic chemical substances are no longer partially exempt from
reporting requirements in 2020, so submitters should report complete information on
inorganic chemical substances, including processing and use information.
IMPORTANT: This document is intended to be an information resource. While EPA
has tried to provide an accurate list of chemical substances, the list may contain errors and
omissions. This list should not be relied upon in lieu of the Code of Federal Rules. In the
event of a conflict between this list and the Code of Federal Rules, this list will not be
considered controlling.
Table C-1. Partially Exempt Chemical Substances Termed “Petroleum Process
Streams” Under 40 CFR 711.6(b)(1)
CAS Registry Number

Product

8002–05–9

Petroleum

8002–74–2

Paraffin waxes and hydrocarbon waxes

8006–20–0

Fuel gases, low and medium B.T.U.

8008–20–6

Kerosine (petroleum)

8009–03–8

Petrolatum

8012–95–1

Paraffin oils

8030–30–6

Naphtha

8032–32–4

Ligroine

8042–47–5

White mineral oil (petroleum)

8052–41–3

Stoddard solvent

8052–42–4

Asphalt

61789-60-4

Pitch

63231–60–7

Paraffin waxes and hydrocarbon waxes, microcryst.

64741–41–9

Naphtha (petroleum), heavy straight-run

64741–42–0

Naphtha (petroleum), full-range straight-run

64741–43–1

Gas oils (petroleum), straight-run

64741–44–2

Distillates (petroleum), straight-run middle

64741–45–3

Residues (petroleum), atm. Tower

64741–46–4

Naphtha (petroleum), light straight-run

64741–47–5

Natural gas condensates (petroleum)

64741–49–7

Condensates (petroleum), vacuum tower

64741–50–0

Distillates (petroleum), light paraffinic
C-1

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

64741–51–1

Distillates (petroleum), heavy paraffinic

64741–52–2

Distillates (petroleum), light naphthenic

64741–53–3

Distillates (petroleum), heavy naphthenic

64741–54–4

Naphtha (petroleum), heavy catalytic cracked

64741–55–5

Naphtha (petroleum), light catalytic cracked

64741–56–6

Residues (petroleum), vacuum

64741–57–7

Gas oils (petroleum), heavy vacuum

64741–58–8

Gas oils (petroleum), light vacuum

64741–59–9

Distillates (petroleum), light catalytic cracked

64741–60–2

Distillates (petroleum), intermediate catalytic cracked

64741–61–3

Distillates (petroleum), heavy catalytic cracked

64741–62–4

Clarified oils (petroleum), catalytic cracked

64741–63–5

Naphtha (petroleum), light catalytic reformed

64741–64–6

Naphtha (petroleum), full-range alkylate

64741–65–7

Naphtha (petroleum), heavy alkylate

64741–66–8

Naphtha (petroleum), light alkylate

64741–67–9

Residues (petroleum), catalytic reformer fractionator

64741–68–0

Naphtha (petroleum), heavy catalytic reformed

64741–69–1

Naphtha (petroleum), light hydrocracked

64741–70–4

Naphtha (petroleum), isomerization

64741–73–7

Distillates (petroleum), alkylate

64741–74–8

Naphtha (petroleum), light thermal cracked

64741–75–9

Residues (petroleum), hydrocracked

64741–76–0

Distillates (petroleum), heavy hydrocracked

64741–77–1

Distillates (petroleum), light hydrocracked

64741–78–2

Naphtha (petroleum), heavy hydrocracked

64741–79–3

Coke (petroleum)

64741–80–6

Residues (petroleum), thermal cracked

64741–81–7

Distillates (petroleum), heavy thermal cracked

64741–82–8

Distillates (petroleum), light thermal cracked

64741–83–9

Naphtha (petroleum), heavy thermal cracked

64741–84–0

Naphtha (petroleum), solvent-refined light

64741–85–1

Raffinates (petroleum), sorption process

64741–86–2

Distillates (petroleum), sweetened middle

64741–87–3

Naphtha (petroleum), sweetened

64741–88–4

Distillates (petroleum), solvent-refined heavy paraffinic

64741–89–5

Distillates (petroleum), solvent-refined light paraffinic

64741–90–8

Gas oils (petroleum), solvent-refined
C-2

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

64741–91–9

Distillates (petroleum), solvent-refined middle

64741–92–0

Naphtha (petroleum), solvent-refined heavy

64741–95–3

Residual oils (petroleum), solvent deasphalted

64741–96–4

Distillates (petroleum), solvent-refined heavy naphthenic

64741–97–5

Distillates (petroleum), solvent-refined light naphthenic

64741–98–6

Extracts (petroleum), heavy naphtha solvent

64741–99–7

Extracts (petroleum), light naphtha solvent

64742–01–4

Residual oils (petroleum), solvent-refined

64742–03–6

Extracts (petroleum), light naphthenic distillate solvent

64742–04–7

Extracts (petroleum), heavy paraffinic distillate solvent

64742–05–8

Extracts (petroleum), light paraffinic distillate solvent

64742–06–9

Extracts (petroleum), middle distillate solvent

64742–07–0

Raffinates (petroleum), residual oil decarbonization

64742–08–1

Raffinates (petroleum), heavy naphthenic distillate decarbonization

64742–09–2

Raffinates (petroleum), heavy paraffinic distillate decarbonization

64742–10–5

Extracts (petroleum), residual oil solvent

64742–11–6

Extracts (petroleum), heavy naphthenic distillate solvent

64742–12–7

Gas oils (petroleum), acid-treated

64742–13–8

Distillates (petroleum), acid-treated middle

64742–14–9

Distillates (petroleum), acid-treated light

64742–15–0

Naphtha (petroleum), acid-treated

64742–16–1

Petroleum resins

64742–18–3

Distillates (petroleum), acid-treated heavy naphthenic

64742–19–4

Distillates (petroleum), acid-treated light naphthenic

64742–20–7

Distillates (petroleum), acid-treated heavy paraffinic

64742–21–8

Distillates (petroleum), acid-treated light paraffinic

64742–22–9

Naphtha (petroleum), chemically neutralized heavy

64742–23–0

Naphtha (petroleum), chemically neutralized light

64742–24–1

Sludges (petroleum), acid

64742–25–2

Lubricating oils (petroleum), acid-treated spent

64742–26–3

Hydrocarbon waxes (petroleum), acid-treated

64742–27–4

Distillates (petroleum), chemically neutralized heavy paraffinic

64742–28–5

Distillates (petroleum), chemically neutralized light paraffinic

64742–29–6

Gas oils (petroleum), chemically neutralized

64742–30–9

Distillates (petroleum), chemically neutralized middle

64742–31–0

Distillates (petroleum), chemically neutralized light

64742–32–1

Lubricating oils (petroleum), chemically neutralized spent

64742–33–2

Hydrocarbon waxes (petroleum), chemically neutralized
C-3

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

64742–34–3

Distillates (petroleum), chemically neutralized heavy naphthenic

64742–35–4

Distillates (petroleum), chemically neutralized light naphthenic

64742–36–5

Distillates (petroleum), clay-treated heavy paraffinic

64742–37–6

Distillates (petroleum), clay-treated light paraffinic

64742–38–7

Distillates (petroleum), clay-treated middle

64742–39–8

Neutralizing agents (petroleum), spent sodium carbonate

64742–40–1

Neutralizing agents (petroleum), spent sodium hydroxide

64742–41–2

Residual oils (petroleum), clay-treated

64742–42–3

Hydrocarbon waxes (petroleum), clay-treated microcryst.

64742–43–4

Paraffin waxes (petroleum), clay-treated

64742–44–5

Distillates (petroleum), clay-treated heavy naphthenic

64742–45–6

Distillates (petroleum), clay-treated light naphthenic

64742–46–7

Distillates (petroleum), hydrotreated middle

64742–47–8

Distillates (petroleum), hydrotreated light

64742–48–9

Naphtha (petroleum), hydrotreated heavy

64742–49–0

Naphtha (petroleum), hydrotreated light

64742–50–3

Lubricating oils (petroleum), clay-treated spent

64742–51–4

Paraffin waxes (petroleum), hydrotreated

64742–52–5

Distillates (petroleum), hydrotreated heavy naphthenic

64742–53–6

Distillates (petroleum), hydrotreated light naphthenic

64742–54–7

Distillates (petroleum), hydrotreated heavy paraffinic

64742–55–8

Distillates (petroleum), hydrotreated light paraffinic

64742–56–9

Distillates (petroleum), solvent-dewaxed light paraffinic

64742–57–0

Residual oils (petroleum), hydrotreated

64742–58–1

Lubricating oils (petroleum), hydrotreated spent

64742–59–2

Gas oils (petroleum), hydrotreated vacuum

64742–60–5

Hydrocarbon waxes (petroleum), hydrotreated microcryst.

64742–61–6

Slack wax (petroleum)

64742–62–7

Residual oils (petroleum), solvent-dewaxed

64742–63–8

Distillates (petroleum), solvent-dewaxed heavy naphthenic

64742–64–9

Distillates (petroleum), solvent-dewaxed light naphthenic

64742–65–0

Distillates (petroleum), solvent-dewaxed heavy paraffinic

64742–67–2

Foots oil (petroleum)

64742–68–3

Naphthenic oils (petroleum), catalytic dewaxed heavy

64742–69–4

Naphthenic oils (petroleum), catalytic dewaxed light

64742–70–7

Paraffin oils (petroleum), catalytic dewaxed heavy

64742–71–8

Paraffin oils (petroleum), catalytic dewaxed light

64742–72–9

Distillates (petroleum), catalytic dewaxed middle
C-4

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

64742–73–0

Naphtha (petroleum), hydrodesulfurized light

64742–75–2

Naphthenic oils (petroleum), complex dewaxed heavy

64742–76–3

Naphthenic oils (petroleum), complex dewaxed light

64742–78–5

Residues (petroleum), hydrodesulfurized atmospheric tower

64742–79–6

Gas oils (petroleum), hydrodesulfurized

64742–80–9

Distillates (petroleum), hydrodesulfurized middle

64742–81–0

Kerosine (petroleum), hydrodesulfurized

64742–82–1

Naphtha (petroleum), hydrodesulfurized heavy

64742–83–2

Naphtha (petroleum), light steam-cracked

64742–85–4

Residues (petroleum), hydrodesulfurized vacuum

64742–86–5

Gas oils (petroleum), hydrodesulfurized heavy vacuum

64742–87–6

Gas oils (petroleum), hydrodesulfurized light vacuum

64742–88–7

Solvent naphtha (petroleum), medium aliph.

64742–89–8

Solvent naphtha (petroleum), light aliph.

64742–90–1

Residues (petroleum), steam-cracked

64742–91–2

Distillates (petroleum), steam-cracked

64742–92–3

Petroleum resins, oxidized

64742–93–4

Asphalt, oxidized

64742–94–5

Solvent naphtha (petroleum), heavy arom.

64742–95–6

Solvent naphtha (petroleum), light arom.

64742–96–7

Solvent naphtha (petroleum), heavy aliph.

64742–97–8

Distillates (petroleum), oxidized heavy

64742–98–9

Distillates (petroleum), oxidized light

64742–99–0

Residual oils (petroleum), oxidized

64743–00–6

Hydrocarbon waxes (petroleum), oxidized

64743–01–7

Petrolatum (petroleum), oxidized

64743–02–8

Alkenes, C>10 .alpha.-

64743–03–9

Phenols (petroleum)

64743–04–0

Coke (petroleum), recovery

64743–05–1

Coke (petroleum), calcined

64743–06–2

Extracts (petroleum), gas oil solvent

64743–07–3

Sludges (petroleum), chemically neutralized

64754–89–8

Naphthenic acids (petroleum), crude

64771–71–7

Paraffins (petroleum), normal C>10

64771–72–8

Paraffins (petroleum), normal C5-20

67254-74-4

Naphthenic oils

67674–12–8

Residual oils (petroleum), oxidized, compounds with triethanolamine

67674–13–9

Petrolatum (petroleum), oxidized, partially deacidified
C-5

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

67674–15–1

Petrolatum (petroleum), oxidized, Me ester

67674–16–2

Hydrocarbon waxes (petroleum), oxidized, partially deacidified

67674–17–3

Distillates (petroleum), oxidized light, compounds with triethanolamine

67674–18–4

Distillates (petroleum), oxidized light, Bu esters

67891–79–6

Distillates (petroleum), heavy arom.

67891–80–9

Distillates (petroleum), light arom.

67891-81-0

Distillates (petroleum), oxidized light, potassium salts

67891–82–1

Hydrocarbon waxes (petroleum), oxidized, compounds with ethanolamine

67891–83–2

Hydrocarbon waxes (petroleum), oxidized, compounds with isopropanolamine

67891–85–4

Hydrocarbon waxes (petroleum), oxidized, compounds with triisopropanolamine

67891-86-5

Hydrocarbon waxes (petroleum), oxidized, compounds with diisopropanolamine

68131–05–5

Hydrocarbon oils, process blends

68131–49–7

Aromatic hydrocarbons, C6-10, acid-treated, neutralized

68131–75–9

Gases (petroleum), C3-4

68153–22–0

Paraffin waxes and Hydrocarbon waxes, oxidized

68187–57–5

Pitch, coal tar-petroleum

68187–58–6

Pitch, petroleum, arom.

68187–60–0

Hydrocarbons, C4, ethane-propane-cracked

68307–98–2

Tail gas (petroleum), catalytic cracked distillate and catalytic cracked naphtha fractionation
absorber

68307–99–3

Tail gas (petroleum), catalytic polymn. naphtha fractionation stabilizer

68308–00–9

Tail gas (petroleum), catalytic reformed naphtha fractionation stabilizer, hydrogen sulfidefree

68308–01–0

Tail gas (petroleum), cracked distillate hydrotreater stripper

68308–02–1

Tail gas (petroleum), distn., hydrogen sulfide-free

68308–03–2

Tail gas (petroleum), gas oil catalytic cracking absorber

68308–04–3

Tail gas (petroleum), gas recovery plant

68308–05–4

Tail gas (petroleum), gas recovery plant deethanizer

68308–06–5

Tail gas (petroleum), hydrodesulfurized distillate and hydrodesulfurized naphtha fractionator,
acid-free

68308–07–6

Tail gas (petroleum), hydrodesulfurized vacuum gas oil stripper, hydrogen sulfide-free

68308–08–7

Tail gas (petroleum), isomerized naphtha fractionation stabilizer

68308–09–8

Tail gas (petroleum), light straight-run naphtha stabilizer, hydrogen sulfide-free

68308–10–1

Tail gas (petroleum), straight-run distillate hydrodesulfurizer, hydrogen sulfide-free

68308–11–2

Tail gas (petroleum), propane-propylene alkylation feed prep deethanizer

68308–12–3

Tail gas (petroleum), vacuum gas oil hydrodesulfurizer, hydrogen sulfide-free

68308–27–0

Fuel gases, refinery

68333–22–2

Residues (petroleum), atmospheric

68333–23–3

Naphtha (petroleum), heavy coker
C-6

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68333–24–4

Hydrocarbon waxes (petroleum), oxidized, compds. with triethanolamine

68333–25–5

Distillates (petroleum), hydrodesulfurized light catalytic cracked

68333–26–6

Clarified oils (petroleum), hydrodesulfurized catalytic cracked

68333–27–7

Distillates (petroleum), hydrodesulfurized intermediate catalytic cracked

68333–28–8

Distillates (petroleum), hydrodesulfurized heavy catalytic cracked

68333–29–9

Residues (petroleum), light naphtha solvent extracts

68333–30–2

Distillates (petroleum), oxidized heavy thermal cracked

68333–81–3

Alkanes, C4-12

68333–88–0

Aromatic hydrocarbons, C9-17

68334–30–5

Fuels, diesel

68409–99–4

Gases (petroleum), catalytic cracked overheads

68410–00–4

Distillates (petroleum), crude oil

68410–05–9

Distillates (petroleum), straight-run light

68410–12–8

Distillates (petroleum), steam-cracked, C5-10 fraction, high-temp. stripping products with
light steamcracked petroleum naphtha C5 fraction polymers

68410–71–9

Raffinates (petroleum), catalytic reformer ethylene glycol-water countercurrent exts.

68410–96–8

Distillates (petroleum), hydrotreated middle, intermediate boiling

68410–97–9

Distillates (petroleum), light distillate hydrotreating process, low-boiling

68410–98–0

Distillates (petroleum), hydrotreated heavy naphtha, deisohexanizer overheads

68411–00–7

Alkenes, C>8

68425–29–6

Distillates (petroleum), naphtha-raffinate pyrolyzate-derived, gasoline-blending

68425–33–2

Petrolatum (petroleum), oxidized, barium salt

68425–34–3

Petrolatum (petroleum), oxidized, calcium salt

68425–35–4

Raffinates (petroleum), reformer, Lurgi unit-sepd.

68425–39–8

Alkenes, C>10 .alpha.-, oxidized

68441–09–8

Hydrocarbon waxes (petroleum), clay-treated microcryst, contg. polyethylene, oxidized

68459–78–9

Alkenes, C18-24 .alpha.-, dimers

68475–57–0

Alkanes, C1-2

68475–58–1

Alkanes, C2-3

68475–59–2

Alkanes, C3-4

68475–60–5

Alkanes, C4-5

68475–61–6

Alkenes, C5, naphtha-raffinate pyrolyzate-derived

68475–70–7

Aromatic hydrocarbons, C6-8, naphtha-raffinate pyrolyzate-derived

68475–79–6

Distillates (petroleum), catalytic reformed depentanizer

68475–80–9

Distillates (petroleum), light steam-cracked naphtha

68476–26–6

Fuel gases

68476-27-7

Fuel gases, amine system residues

68476–28–8

Fuel gases, C6-8 catalytic reformer
C-7

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68476–29–9

Fuel gases, crude oil distillates

68476–30–2

Fuel oil, no. 2

68476–31–3

Fuel oil, no. 4

68476–32–4

Fuel oil, residues-straight-run gas oils, high-sulfur

68476–33–5

Fuel oil, residual

68476–34–6

Fuels, diesel, no. 2

68476–39–1

Hydrocarbons, aliph.-arom.-C4-5-olefinic

68476–40–4

Hydrocarbons, C3-4

68476–42–6

Hydrocarbons, C4-5

68476–43–7

Hydrocarbons, C4-6, C5-rich

68476–44–8

Hydrocarbons, C>3

68476–45–9

Hydrocarbons, C5-10 arom. conc., ethylene-manuf.-by-product

68476–46–0

Hydrocarbons, C3-11, catalytic cracker distillates

68476–47–1

Hydrocarbons, C2-6, C6-8 catalytic reformer

68476–49–3

Hydrocarbons, C2-4, C3-rich

68476–50–6

Hydrocarbons, C>5, C5-6-rich

68476–52–8

Hydrocarbons, C4, ethylene-manuf.-by-product

68476–53–9

Hydrocarbons, C>20, petroleum wastes

68476–54–0

Hydrocarbons, C3-5, polymn. unit feed

68476–55–1

Hydrocarbons, C5-rich

68476–56–2

Hydrocarbons, cyclic C5 and C6

68476–77–7

Lubricating oils, refined used

68476–81–3

Paraffin waxes and Hydrocarbon waxes, oxidized, calcium salts

68476–84–6

Petroleum products, gases, inorg.

68476–85–7

Petroleum gases, liquefied

68476–86–8

Petroleum gases, liquefied, sweetened

68477–25–8

Waste gases, vent gas, C1-6

68477–26–9

Wastes, petroleum

68477–29–2

Distillates (petroleum), catalytic reformer fractionator residue, high-boiling

68477–30–5

Distillates (petroleum), catalytic reformer fractionator residue, intermediate-boiling

68477–31–6

Distillates (petroleum), catalytic reformer fractionator residue, low-boiling

68477–33–8

Gases (petroleum), C3-4, isobutane-rich

68477–34–9

Distillates (petroleum), C3-5, 2-methyl-2-butene-rich

68477–35–0

Distillates (petroleum), C3-6, piperylene-rich

68477–36–1

Distillates (petroleum), cracked steam-cracked, C5-18 fraction

68477–38–3

Distillates (petroleum), cracked steam-cracked petroleum distillates

68477–39–4

Distillates (petroleum), cracked stripped steam-cracked petroleum distillates, C8-10 fraction

68477–40–7

Distillates (petroleum), cracked stripped steam-cracked petroleum distillates, C10-12 fraction
C-8

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68477–41–8

Gases (petroleum), extractive, C3-5, butadiene-butene-rich

68477–42–9

Gases (petroleum), extractive, C3-5, butene-isobutylene-rich

68477–44–1

Distillates (petroleum), heavy naphthenic, mixed with steam-cracked petroleum distillates
C5-12 fraction

68477–47–4

Distillates (petroleum), mixed heavy olefin vacuum, heart-cut

68477–48–5

Distillates (petroleum), mixed heavy olefin vacuum, low-boiling

68477–53–2

Distillates (petroleum), steam-cracked, C5-12 fraction

68477–54–3

Distillates (petroleum), steam-cracked, C8-12 fraction

68477–55–4

Distillates (petroleum), steam-cracked, C5-10 fraction, mixed with light steam-cracked
petroleum naphtha C5 fraction

68477–58–7

Distillates (petroleum), steam-cracked petroleum distillates, C5-18 fraction

68477–59–8

Distillates (petroleum), steam-cracked petroleum distillates cyclopentadiene conc.

68477–60–1

Extracts (petroleum), cold-acid

68477–61–2

Extracts (petroleum), cold-acid, C4-6

68477–62–3

Extracts (petroleum), cold-acid, C3-5, butene-rich

68477–63–4

Extracts (petroleum), reformer recycle

68477–64–5

Gases (petroleum), acetylene manuf. off

68477–65–6

Gases (petroleum), amine system feed

68477–66–7

Gases (petroleum), benzene unit hydrodesulfurizer off

68477–67–8

Gases (petroleum), benzene unit recycle, hydrogen-rich

68477–68–9

Gases (petroleum), blend oil, hydrogen-nitrogen-rich

68477–69–0

Gases (petroleum), butane splitter overheads

68477–70–3

Gases (petroleum), C2-3

68477–71–4

Gases (petroleum), catalytic-cracked gas oil depropanizer bottoms, C4-rich acid-free

68477–72–5

Gases (petroleum), catalytic-cracked naphtha debutanizer bottoms, C3-5-rich

68477–73–6

Gases (petroleum), catalytic cracked naphtha depropanizer overhead, C3-rich acid-free

68477–74–7

Gases (petroleum), catalytic cracker

68477–75–8

Gases (petroleum), catalytic cracker, C1-5-rich

68477–76–9

Gases (petroleum), catalytic polymd. naphtha stabilizer overhead, C2-4-rich

68477–77–0

Gases (petroleum), catalytic reformed naphtha stripper overheads

68477–79–2

Gases (petroleum), catalytic reformer, C1-4-rich

68477–80–5

Gases (petroleum), C6-8 catalytic reformer recycle

68477–81–6

Gases (petroleum), C6-8 catalytic reformer

68477–82–7

Gases (petroleum), C6-8 catalytic reformer recycle, hydrogen-rich

68477–83–8

Gases (petroleum), C3-5 olefinic-paraffinic alkylation feed

68477–84–9

Gases (petroleum), C2-return stream

68477–85–0

Gases (petroleum), C4-rich

68477–86–1

Gases (petroleum), deethanizer overheads

68477–87–2

Gases (petroleum), deisobutanizer tower overheads
C-9

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68477–88–3

Gases (petroleum), deethanizer overheads, C3-rich

68477–89–4

Distillates (petroleum), depentanizer overheads

68477–90–7

Gases (petroleum), depropanizer dry, propene-rich

68477–91–8

Gases (petroleum), depropanizer overheads

68477–92–9

Gases (petroleum), dry sour, gas-concn.-unit-off

68477–93–0

Gases (petroleum), gas concn. reabsorber distn.

68477–94–1

Gases (petroleum), gas recovery plant depropanizer overheads

68477–95–2

Gases (petroleum), Girbatol unit feed

68477–96–3

Gases (petroleum), hydrogen absorber off

68477–97–4

Gases (petroleum), hydrogen-rich

68477–98–5

Gases (petroleum), hydrotreater blend oil recycle, hydrogen-nitrogen rich

68477–99–6

Gases (petroleum), isomerized naphtha fractionater, C4-rich, hydrogen sulfide-free

68478–00–2

Gases (petroleum), recycle, hydrogen-rich

68478–01–3

Gases (petroleum), reformer make-up, hydrogen-rich

68478–02–4

Gases (petroleum), reforming hydrotreater

68478–03–5

Gases (petroleum), reforming hydrotreater, hydrogen-methane-rich

68478–04–6

Gases (petroleum), reforming hydrotreater make-up, hydrogen-rich

68478–05–7

Gases (petroleum), thermal cracking distn.

68478–08–0

Naphtha (petroleum), light steam-cracked, C5-fraction, oligomer conc.

68478–10–4

Naphtha (petroleum), light steam-cracked, debenzenized, C8-16-cycloalkadiene conc.

68478–12–6

Residues (petroleum), butane splitter bottoms

68478–13–7

Residues (petroleum), catalytic reformer fractionator residue distn.

68478–15–9

Residues (petroleum), C6-8 catalytic reformer

68478–16–0

Residual oils (petroleum), deisobutanizer tower

68478–17–1

Residues (petroleum), heavy coker gas oil and vacuum gas oil

68478–18–2

Residues (petroleum), heavy olefin vacuum

68478–19–3

Residual oils (petroleum), propene purifn. splitter

68478–20–6

Residues (petroleum), steam-cracked petroleum distillates cyclopentadiene conc., C4
cyclopentadiene free

68478–22–8

Tail gas (petroleum), catalytic cracked naphtha stabilization absorber

68478–24–0

Tail gas (petroleum), catalytic cracker, catalytic reformer and hydrodesulfurizer combined
fractionater

68478–25–1

Tail gas (petroleum), catalytic cracker refractionation absorber

68478–26–2

Tail gas (petroleum), catalytic reformed naphtha fractionation stabilizer

68478–27–3

Tail gas (petroleum), catalytic reformed naphtha separator

68478–28–4

Tail gas (petroleum), catalytic reformed naphtha stabilizer

68478–29–5

Tail gas (petroleum), cracked distillate hydrotreater separator

68478–30–8

Tail gas (petroleum), hydrodesulfurized straight-run naphtha separator

68478-31-9

Tail gas (petroleum), isomerized naphtha fractionates, hydrogen sulfide-free
C-10

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68478–32–0

Tail gas (petroleum), saturate gas plant mixed stream, C4-rich

68478–33–1

Tail gas (petroleum), saturate gas recovery plant, C1-2-rich

68478–34–2

Tail gas (petroleum), vacuum residues thermal cracker

68512–61–8

Residues (petroleum), heavy coker and light vacuum

68512–62–9

Residues (petroleum), light vacuum

68512–78–7

Solvent naphtha (petroleum), light arom., hydrotreated

68512–91–4

Hydrocarbons, C3-4-rich, petroleum distillates

68513–02–0

Naphtha (petroleum), full-range coker

68513–03–1

Naphtha (petroleum), light catalytic reformed, aromatic-free

68513–11–1

Fuel gases, hydrotreater fractionation, scrubbed

68513–12–2

Fuel gases, saturate gas unit fractionater-absorber overheads

68513–13–3

Fuel gases, thermal cracked catalytic cracking residue

68513–14–4

Gases (petroleum), catalytic reformed straight-run naphtha stabilizer overheads

68513–15–5

Gases (petroleum), full-range straight-run naphtha dehexanizer off

68513–16–6

Gases (petroleum), hydrocracking depropanizer off, hydrocarbon-rich

68513–17–7

Gases (petroleum), light straight-run naphtha stabilizer off

68513–18–8

Gases (petroleum), reformer effluent high-pressure flash drum off

68513–19–9

Gases (petroleum), reformer effluent low-pressure flash drum off

68513–62–2

Disulfides, C5-12-alkyl

68513–63–3

Distillates (petroleum), catalytic reformed straight-run naphtha overheads

68513–65–5

Butane, branched and linear

68513–66–6

Residues (petroleum), alkylation splitter, C4-rich

68513–67–7

Residues (petroleum), cyclooctadiene bottoms

68513–68–8

Residues (petroleum), deethanizer tower

68513–69–9

Residues (petroleum), steam-cracked light

68513–74–6

Waste gases, ethylene oxide absorber-reactor

68514–15–8

Gasoline, vapor-recovery

68514–29–4

Hydrocarbons, amylene feed debutanizer overheads nonextractable raffinates

68514–31–8

Hydrocarbons, C1-4

68514–32–9

Hydrocarbons, C10 and C12, olefin-rich

68514–33–0

Hydrocarbons, C12 and C14, olefin-rich

68514–34–1

Hydrocarbons, C9-14, ethylene-manuf.-by-product

68514–35–2

Hydrocarbons, C14-30, olefin-rich

68514–36–3

Hydrocarbons, C1-4, sweetened

68514–37–4

Hydrocarbons, C4-5-unsatd.

68514–38–5

Hydrocarbons, C4-10-unsatd.

68514-39-6

Naphtha (petroleum), light steam-cracked, isoprene-rich

68514–79–4

Petroleum products, hydrofiner-powerformer reformates
C-11

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68515–25–3

Benzene, C1-9-alkyl derivs.

68515–26–4

Benzene, di-C12-14-alkyl derivs.

68515–27–5

Benzene, di-C10-14-alkyl derivs., fractionation overheads, heavy ends

68515–28–6

Benzene, di-C10-14-alkyl derivs., fractionation overheads, light ends

68515–29–7

Benzene, di-C10-14-alkyl derivs., fractionation overheads, middle cut

68515–30–0

Benzene, mono-C20-48-alkyl derivs.

68515–32–2

Benzene, mono-C12-14-alkyl derivs., fractionation bottoms

68515–33–3

Benzene, mono-C10-12-alkyl derivs., fractionation bottoms, heavy ends

68515–34–4

Benzene, mono-C12-14-alkyl derivs., fractionation bottoms, heavy ends

68515–35–5

Benzene, mono-C10-12-alkyl derivs., fractionation bottoms, light ends

68515–36–6

Benzene, mono-C12-14-alkyl derivs., fractionation bottoms, light ends

68516–20–1

Naphtha (petroleum), steam-cracked middle arom.

68526–52–3

Alkenes, C6

68526–53–4

Alkenes, C6-8, C7-rich

68526–54–5

Alkenes, C7-9, C8-rich

68526–55–6

Alkenes, C8-10, C9-rich

68526–56–7

Alkenes, C9-11, C10-rich

68526–57–8

Alkenes, C10-12, C11-rich

68526–58–9

Alkenes, C11-13, C12-rich

68526–77–2

Aromatic hydrocarbons, ethane cracking scrubber effluent and flare drum

68526–99–8

Alkenes, C6-9 .alpha.-

68527–00–4

Alkenes, C8-9 .alpha.-

68527–11–7

Alkenes, C5

68527–13–9

Gases (petroleum), acid, ethanolamine scrubber

68527–14–0

Gases (petroleum), methane-rich off

68527–15–1

Gases (petroleum), oil refinery gas distn. off

68527–16–2

Hydrocarbons, C1-3

68527–18–4

Gas oils (petroleum), steam-cracked

68527–19–5

Hydrocarbons, C1-4, debutanizer fraction

68527–21–9

Naphtha (petroleum), clay-treated full-range straight-run

68527–22–0

Naphtha (petroleum), clay-treated light straight-run

68527–23–1

Naphtha (petroleum), light steam-cracked arom.

68527–26–4

Naphtha (petroleum), light steam-cracked, debenzenized

68527–27–5

Naphtha (petroleum), full-range alkylate, butane-contg.

68553–00–4

Fuel oil, no. 6

68553–14–0

Hydrocarbons, C8-11

68602–79–9

Distillates (petroleum), benzene unit hydrotreater dipentanizer overheads

68602–81–3

Distillates, hydrocarbon resin prodn. higher boiling
C-12

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68602–82–4

Gases (petroleum), benzene unit hydrotreater depentenizer overheads

68602–83–5

Gases (petroleum), C1-5, wet

68602–84–6

Gases (petroleum), secondary absorber off, fluidized catalytic cracker overheads fractionater

68602–96–0

Distillates (petroleum), oxidized light, strong acid components, compds. with diethanolamine

68602–97–1

Distillates (petroleum), oxidized light, strong acid components, sodium salts

68602–98–2

Distillates (petroleum), oxidized light, strong acid components

68602–99–3

Distillates (petroleum), oxidized light, strong acid-free

68603–00–9

Distillates (petroleum), thermal cracked naphtha and gas oil

68603–01–0

Distillates (petroleum), thermal cracked naphtha and gas oil, C5-dimer-contg.

68603–02–1

Distillates (petroleum), thermal cracked naphtha and gas oil, dimerized

68603–03–2

Distillates (petroleum), thermal cracked naphtha and gas oil, extractive

68603–08–7

Naphtha (petroleum), arom.-contg.

68603–09–8

Hydrocarbon waxes (petroleum), oxidized, calcium salts

68603–10–1

Hydrocarbon waxes (petroleum), oxidized, Me esters, barium salts

68603–11–2

Hydrocarbon waxes (petroleum), oxidized, Me esters, calcium salts

68603–12–3

Hydrocarbon waxes (petroleum), oxidized, Me esters, sodium salts

68603–13–4

Petrolatum (petroleum), oxidized, ester with sorbitol

68603–14–5

Residual oils (petroleum), oxidized, calcium salts

68603–31–6

Alkenes, C10, tert-amylene concentrator by-product

68603–32–7

Alkenes, C15-20 .alpha.-, isomerized

68606–09–7

Fuel gases, expander off

68606–10–0

Gasoline, pyrolysis, debutanizer bottoms

68606–11–1

Gasoline, straight–run, topping-plant

68606–24–6

Hydrocarbons, C4, butene concentrator by-product

68606–25–7

Hydrocarbons, C2-4

68606–26–8

Hydrocarbons, C3

68606–27–9

Gases (petroleum), alkylation feed

68606–28–0

Hydrocarbons, C5 and C10-aliph. and C6-8-arom.

68606–31–5

Hydrocarbons, C3-5, butadiene purifn. by-product

68606–34–8

Gases (petroleum), depropanizer bottoms fractionation off

68606–36–0

Hydrocarbons, C5-unsatd. rich, isoprene purifn. by-product

68607–11–4

Petroleum products, refinery gases

68607–30–7

Residues (petroleum), topping plant, low-sulfur

68608–56–0

Waste gases, from carbon black manuf.

68647-60–9

Hydrocarbons, C>4

68647–61–0

Hydrocarbons, C4-5, tert-amylene concentrator by-product

68647–62–1

Hydrocarbons, C4-5, butene concentrator by-product, sour

68650–36–2

Aromatic hydrocarbons, C8, o-xylene-lean
C-13

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68650–37–3

Paraffin waxes (petroleum), oxidized, sodium salts

68782–97–8

Distillates (petroleum), hydrofined lubricating-oil

68782–98–9

Extracts (petroleum), clarified oil solvent, condensed-ring-arom.-contg.

68782–99–0

Extracts (petroleum), heavy clarified oil solvent, condensed-ring-arom.-contg.

68783–00–6

Extracts (petroleum), heavy naphthenic distillate solvent, arom. conc.

68783–01–7

Extracts (petroleum), heavy naphthenic distillate solvent, paraffinic conc.

68783–02–8

Extracts (petroleum), intermediate clarified oil solvent, condensed-ring-arom.-contg.

68783–04–0

Extracts (petroleum), solvent-refined heavy paraffinic distillate solvent

68783–05–1

Gases (petroleum), ammonia-hydrogen sulfide, water-satd.

68783–06–2

Gases (petroleum), hydrocracking low-pressure separator

68783–07–3

Gases (petroleum), refinery blend

68783–08–4

Gas oils (petroleum), heavy atmospheric

68783–09–5

Naphtha (petroleum), catalytic cracked light distd.

68783–12–0

Naphtha (petroleum), unsweetened

68783–13–1

Residues (petroleum), coker scrubber, condensed-ring-arom.-contg.

68783–15–3

Alkenes, C6-7 .alpha.-

68783–61–9

Fuel gases, refinery, sweetened

68783–62–0

Fuel gases, refinery, unsweetened

68783–64–2

Gases (petroleum), catalytic cracking

68783–65–3

Gases (petroleum), C2-4, sweetened

68783–66–4

Naphtha (petroleum), light, sweetened

68814–47–1

Waste gases, refinery vent

68814–67–5

Gases (petroleum), refinery

68814–89–1

Extracts (petroleum), heavy paraffinic distillates, solvent-deasphalted

68814–87–9

Distillates (petroleum), full-range straight-run middle

68814–90–4

Gases (petroleum), platformer products separator off

68814–91–5

Alkenes, C5-9 .alpha.-

68855–57–2

Alkenes, C6-12 .alpha.-

68855–58–3

Alkenes, C10-16 .alpha.-

68855–59–4

Alkenes, C14-18 .alpha.-

68855–60–7

Alkenes, C14-20 .alpha.-

68911–58–0

Gases (petroleum), hydrotreated sour kerosine depentanizer stabilizer off

68911–59–1

Gases (petroleum), hydrotreated sour kerosine flash drum

68915–96–8

Distillates (petroleum), heavy straight-run

68915–97–9

Gas oils (petroleum), straight-run, high-boiling

68918–69–4

Petrolatum (petroleum), oxidized, zinc salt

68918–73–0

Residues (petroleum), clay-treating filter wash

68918–93–4

Paraffin waxes and Hydrocarbon waxes, oxidized, alkali metal salts
C-14

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68918–98–9

Fuel gases, refinery, hydrogen sulfide-free

68918–99–0

Gases (petroleum), crude oil fractionation off

68919–00–6

Gases (petroleum), dehexanizer off

68919–01–7

Gases (petroleum), distillate unifiner desulfurization stripper off

68919–02–8

Gases (petroleum), fluidized catalytic cracker fractionation off

68919–03–9

Gases (petroleum), fluidized catalytic cracker scrubbing secondary absorber off

68919–04–0

Gases (petroleum), heavy distillate hydrotreater desulfurization stripper off

68919–05–1

Gases (petroleum), light straight run gasoline fractionation stabilizer off

68919–06–2

Gases (petroleum), naphtha unifiner desulfurization stripper off

68919–07–3

Gases (petroleum), platformer stabilizer off, light ends fractionation

68919–08–4

Gases (petroleum), preflash tower off, crude distn.

68919–09–5

Gases (petroleum), straight-run naphtha catalytic reforming off

68919–10–8

Gases (petroleum), straight-run stabilizer off

68919–11–9

Gases (petroleum), tar stripper off

68919–12–0

Gases (petroleum), unifiner stripper off

68919–15–3

Hydrocarbons, C6-12, benzene-recovery

68919-16-4

Hydrocarbons, catalytic alkylation, by-products, C3-6

68919–17–5

Hydrocarbons, C12-20, catalytic alkylation by-products

68919–19–7

Gases (petroleum), fluidized catalytic cracker splitter residues

68919–20–0

Gases (petroleum), fluidized catalytic cracker splitter overheads

68919–37–9

Naphtha (petroleum), full-range reformed

68920–06–9

Hydrocarbons, C7-9

68920–07–0

Hydrocarbons, C<10-linear

68920–64–9

Disulfides, di-C1-2-alkyl

68921–07–3

Distillates (petroleum), hydrotreated light catalytic cracked

68921–09–5\

Distillates (petroleum), naphtha unifiner stripper

68921–08–4

Distillates (petroleum), light straight-run gasoline fractionation stabilizer overheads

68921–67–5

Hydrocarbons, ethylene-manuf.-by-product distn. residues

68952–76–1

Gases (petroleum), catalytic cracked naphtha debutanizer

68952–77–2

Tail gas (petroleum), catalytic cracked distillate and naphtha stabilizer

68952–78–3

Tail gas (petroleum), catalytic hydrodesulfurized distillate fractionation stabilizer, hydrogen
sulfide-free

68952–79–4

Tail gas (petroleum), catalytic hydrodesulfurized naphtha separator

68952–80–7

Tail gas (petroleum), straight-run naphtha hydrodesulfurizer

68952–81–8

Tail gas (petroleum), thermal-cracked distillate, gas oil and naphtha absorber

68952–82–9

Tail gas (petroleum), thermal cracked hydrocarbon fractionation stabilizer, petroleum coking

68953–80–0

Benzene, mixed with toluene, dealkylation product

68955–27–1

Distillates (petroleum), petroleum residues vacuum
C-15

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

68955–28–2

Gases (petroleum), light steam-cracked, butadiene conc.

68955–31–7

Gases (petroleum), butadiene process, inorg.

68955–32–8

Natural gas, substitute, steam-reformed desulfurized naphtha

68955–33–9

Gases (petroleum), sponge absorber off, fluidized catalytic cracker and gas oil desulfurizer
overhead fractionation

68955–34–0

Gases (petroleum), straight-run naphtha catalytic reformer stabilizer overhead

68955–35–1

Naphtha (petroleum), catalytic reformed

68955–36–2

Residues (petroleum), steam-cracked, resinous

68955–76–0

Aromatic hydrocarbons, C9-16, biphenyl deriv.-rich

68955–96–4

Disulfides, dialkyl and di-Ph, naphtha sweetening

68956–47–8

Fuel oil, isoprene reject absorption

68956–48–9

Fuel oil, residual, wastewater skimmings

68956–52–5

Hydrocarbons, C4-8

68956–54–7

Hydrocarbons, C4-unsatd.

68956–55–8

Hydrocarbons, C5-unsatd.

68956–70–7

Petroleum products, C5-12, reclaimed, wastewater treatment

68988–79–4

Benzene, C10-12-alkyl derivs., distn. residues

68988–99–8

Phenols, sodium salts, mixed with sulfur compounds, gasoline alk. scrubber residues

68989–88–8

Gases (petroleum), crude distn. and catalytic cracking

68990–35–2

Distillates (petroleum), arom., hydrotreated, dicyclopentadiene-rich

68991–49–1

Alkanes, C10-13, arom.-free desulfurized

68991–50–4

Alkanes, C14-17, arom.-free desulfurized

68991–51–5

Alkanes, C10-13, desulfurized

68991–52–6

Alkenes, C10-16

69013–21–4

Fuel oil, pyrolysis

69029–75–0

Oils, reclaimed

69430–33–7

Hydrocarbons, C6-30

70024–88–3

Ethene, thermal cracking products

70528–71–1

Distillates (petroleum), heavy distillate solvent ext. heart-cut

70528–72–2

Distillates (petroleum), heavy distillate solvent ext. vacuum overheads

70528–73–3

Residues (petroleum), heavy distillate solvent ext. vacuum

70592–76–6

Distillates (petroleum), intermediate vacuum

70592–77–7

Distillates (petroleum), light vacuum

70592–78–8

Distillates (petroleum), vacuum

70592–79–9

Residues (petroleum), atm. tower, light

70693–00–4

Hydrocarbon waxes (petroleum), oxidized, sodium salts

70693–06–0

Aromatic hydrocarbons, C9-11

70913–85–8

Residues (petroleum), solvent-extd. vacuum distilled atm. residuum
C-16

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Product

70913–86–9

Alkanes, C18-70

70955–08–7

Alkanes, C4-6

70955–09–8

Alkenes, C13-14 .alpha.-

70955–10–1

Alkenes, C15-18 .alpha.-

70955–17–8

Aromatic hydrocarbons, C12-20

71243–66–8

Hydrocarbon waxes (petroleum), clay-treated, microcryst., oxidized, potassium salts

71302–82–4

Hydrocarbons, C5-8, Houdry butadiene manuf. by-product

71329–37–8

Residues (petroleum), catalytic cracking depropanizer, C4-rich

71808–30–5

Tail gas (petroleum), thermal cracking absorber

72230–71–8

Distillates (petroleum), cracked steam-cracked, C5-17 fraction

72623–83–7

Lubricating oils (petroleum), C>25, hydrotreated bright stock-based

72623–84–8

Lubricating oils (petroleum), C15-30, hydrotreated neutral oil-based, contg. solvent
deasphalted residual oil

72623–85–9

Lubricating oils (petroleum), C20-50, hydrotreated neutral oil-based, high-viscosity

72623–86–0

Lubricating oils (petroleum), C15-30, hydrotreated neutral oil-based

72623–87–1

Lubricating oils (petroleum), C20-50, hydrotreated neutral oil-based

73138-65-5

Hydrocarbon waxes (petroleum), oxidized, magnesium salts

92045-43-7

Lubricating oils (petroleum) hydrocracked nonaromatic solvent deparaffined

92045-58-4

Naphtha (petroleum), isomerization, C6-fration

92062-09-4

Slack wax (petroleum), hydrotreated

93762–80–2

Alkenes, C15-18

98859-55-3

Distillates (petroleum), oxidized heavy, compounds with diethanolamine

98859-56-4

Distillates (petroleum), oxidized heavy, sodium salts

101316-73-8

Lubricating oils (petroleum), used, noncatalytically refined

164907-78-2

Extracts (petroleum), asphaltene-low vacuum residue solvent

164907-79-3

Residues (petroleum), vacuum, asphaltene-low

178603-63-9

Gas oils (petroleum), vacuum, hydrocracked, hydroisomerized, hydrogenated, C10-25

178603-64-0

Gas oils (petroleum), vacuum, hydrocracked, hydroisomerized, hydrogenated, C15-30,
branched and cyclic

178603-65-1

Gas oils (petroleum), vacuum, hydrocracked, hydroisomerized, hydrogenated, C20-40,
branched and cyclic

178603-66-2

Gas oils (petroleum), vacuum, hydrocracked, hydroisomerized, hydrogenated, C25-55,
branched and cyclic

212210-93-0

Solvent naphtha (petroleum), heavy aromatic, distillation residues

221120-39-4

Distillates (petroleum), cracked steam-cracked, C5-12 fraction

445411-73-4

Gas oils (petroleum), vacuum, hydrocracked, hydroisomerized, hydrogenated, C10-25,
branched and cyclic

C-17

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

Table C-2. Partially Exempt Chemical Substances Under 40 CFR 711.6(b)(2)
CAS Registry Number

Chemical Name

50-70-4

D-glucitol.

50-81-7

L-ascorbic acid.

50-99-7

D-glucose.

56-81-5

1,2,3-Propanetriol.

56-87-1

L-lysine.

57-48-7

D-fructose.

57-50-1

.alpha.-D-Glucopyranoside, .beta.-D-fructofuranosyl.

58-95-7

2H-1-Benzopyran-6-ol, 3,4-dihydro-2,5,7,8-tetramethyl-2-[(4R,8R)4,8,12- trimethyltridecyl]-, acetate, (2R)-.

59-02-9
59-51-8

2H-1-Benzopyran-6-ol, 3,4-dihydro-2,5,7,8-tetramethyl-2-[(4R,8R)4,8,12- trimethyltridecyl]-, (2R)-.
Methionine.

68-04-2

1,2,3-Propanetricarboxylic acid, 2-hydroxy-, sodium salt (1:3).

69-65-8

D-mannitol.

77-92-9

1,2,3-Propanetricarboxylic acid, 2-hydroxy-.

87-79-6

L-sorbose.

87-99-0

Xylitol.

96-10-6

Aluminum, chlorodiethyl-.

97-93-8

Aluminum, triethyl-.

100-99-2

Aluminum, tris(2-methylpropyl)-.

123-94-4

Octadecanoic acid, 2,3-dihydroxypropyl ester.

124-38-9

Carbon dioxide.

137-08-6

.beta.-Alanine, N-[(2R)-2,4-dihydroxy-3,3-dimethyl-1-oxobutyl]-, calcium alt (2:1).

142-47-2

L-glutamic acid, monosodium salt.

150-30-1

Phenylalanine.

504-63-2

1,3-Propanediol.

563-43-9

Aluminum, dichloroethyl-.

866-84-2

1,2,3-Propanetricarboxylic acid, 2-hydroxy-, potassium salt (1:3).

1070-00-4

Aluminum, trioctyl-.

1116-70-7

Aluminum, tributyl-.

1116-73-0

Aluminum, trihexyl-.

1191-15-7

Aluminum, hydrobis(2-methylpropyl)-.

1317-65-3

Limestone.

1333-74-0

Hydrogen.

1592-23-0

Octadecanoic acid, calcium salt.

7440-37-1

Argon.

7440-44-0

Carbon.

7727-37-9

Nitrogen.

7782-42-5

Graphite.

7782-44-7

Oxygen.

8001-21-6

Sunflower oil.
C-18

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number

Chemical Name

8001-22-7

Soybean oil.

8001-23-8

Safflower oil.

8001-26-1

Linseed oil.

8001-29-4

Cottonseed oil.

8001-30-7

Corn oil.

8001-31-8

Coconut oil.

8001-78-3

Castor oil, hydrogenated.

8001-79-4

Castor oil.

8002-03-7

Peanut oil.

8002-13-9

Rape oil.

8002-43-5

Lecithins.

8002-75-3

Palm oil.

8006-54-0

Lanolin.

8013-07-8

Soybean oil, epoxidized.

8016-28-2

Lard, oil.

8016-70-4

Soybean oil, hydrogenated.

8021-99-6

Charcoal, bone.

8023-79-8

Oils, palm kernel.

8029-43-4

Syrups, hydrolyzed starch.

11103-57-4

Vitamin A.

12075-68-2

Aluminum, di-.mu.-chlorochlorotriethyldi-.

12542-85-7

Aluminum, trichlorotrimethyldi-.

16291-96-6

Charcoal.

26836-47-5

D-glucitol, monooctadecanoate.

61788-61-2

Fatty acids, tallow, methyl esters.

61789-44-4

Fatty acids, castor-oil.

61789-97-7

Tallow.

61789-99-9

Lard.

64147-40-6

Castor oil, dehydrated.

64755-01-7

Fatty acids, tallow, calcium salts.

65996-63-6

Starch, acid-hydrolyzed.

65996-64-7

Starch, enzyme-hydrolyzed.

66071-94-1

Corn, steep liquor.

67701-01-3

Fatty acids, C12-18.

67762-26-9

Fatty acids, C14-18 and C16-18 unsaturated, methyl esters.

67762-38-3

Fatty acids, C16-18 and C-18 unsaturated, methyl esters.

67784-80-9

Soybean oil, methyl esters.

68002-85-7

Fatty acids, C14-22 and C16-22-unsatd.

68131-37-3

Syrups, hydrolyzed starch, dehydrated.

68188-81-8

Grease, poultry.

68308-36-1

Soybean meal.

68308-54-3

Glycerides, tallow mono-, di- and tri-, hydrogenated.
C-19

Appendix C

Chemical Substances Partially Exempt from Reporting in 2020

CAS Registry Number
68334-00-9

Chemical Name
Cottonseed oil, hydrogenated.

68334-28-1

Fats and glyceridic oils, vegetable, hydrogenated.

68409-76-7

Bone meal, steamed.

68424-45-3

Fatty acids, linseed-oil.

68424-61-3

Glycerides, C16-18 and C18-unsatd. mono- and di-.

68425-17-2

Syrups, hydrolyzed starch, hydrogenated

68439-86-1

Bone, ash.

68442-69-3

Benzene, mono-C10-14-alkyl derivs.

68476-78-8

Molasses.

68514-27-2

Grease, catch basin.

68514-74-9

Palm oil, hydrogenated.

68525-87-1

Corn oil, hydrogenated.

68648-87-3

Benzene, C10-16-alkyl derivs.

68918-42-3

Soaps, stocks, soya.

68952-94-3

Soaps, stocks, vegetable-oil.

68956-68-3

Fats and glyceridic oils, vegetable.

68989-98-0

Fats and glyceridic oils, vegetable, residues.

70131-50-9

Bentonite, acid-leached.

73138-67-7

Lard, hydrogenated.

120962-03-0

Canola oil.

129813-58-7

Benzene, mono-C10-13-alkyl derivs.

129813-59-8

Benzene, mono-C12-14-alkyl derivs.

129813-60-1

Benzene, mono-C14-16-alkyl derivs.

129828-16-6

Fatty acids, canola oil, methyl esters.

515152-40-6

Fatty acids, corn oil, methyl esters.

C-20

Appendix D

Descriptions of Processing and Use Codes

Appendix D
Descriptions of Codes for Reporting Processing or Use Operations,
Industrial Sectors, Function Categories, and Consumer and Commercial
Product Categories
The following descriptions were developed by EPA to assist persons submitting information
in response to 40 CFR 711.15(b)(4) and reported in Part III of CDR Form U. For more information,
see the Technical Support Document: “Harmonizing CDR Functional and Product codes with OECD
Functional, Product, and Article Codes,” located in the rulemaking record (EPA-HQ-OPPT-20180321).
Table D-1. Processing or Use Operation Descriptions
Code

Operation

Description

PC

Processing as a reactant

Chemical substance is used in chemical reactions for the
manufacturing of another chemical substance or product.

PF

Processing—incorporation into
formulation, mixture, or reaction product

Chemical substance is added to a product (or product
mixture) prior to further distribution of the product.

PA

Processing—incorporation into article

Chemical substance becomes an integral component of an
article distributed for industrial, trade, or consumer use.

PK

Processing—repackaging

Preparation of a chemical substance for distribution in
commerce in a different form, state, or quantity. This includes
transferring the chemical substance from a bulk container into
smaller containers. This definition does not apply to sites that
only relabel or redistribute the reportable chemical substance
without removing the chemical substance from the container
in which it is received or purchased.

U

Use—non-incorporative activities

Chemical substance is otherwise used (e.g., as a chemical
processing or manufacturing aid).

Table D-2. Industrial Sector (IS) Code Descriptions
NAICS
11
211
213
212
22
23
311
312
313
314
315
316

IS Code
IS1

IS Title
Agriculture, Forestry, Fishing and Hunting

IS2

Oil and Gas Drilling, Extraction, and Support Activities

IS3
IS4
IS5

Mining (except Oil and Gas) and Support Activities
Utilities
Construction

IS6

Food, beverage, and tobacco product manufacturing

IS7

Textiles, apparel, and leather manufacturing

D-1

Appendix D

Descriptions of Processing and Use Codes

321
322
323
32411
32412
324191
324199
32511
32512
32513
325182
32518
325192
32519
325211
325212
32522
3253
3254
32551
32552
3256
32591
32592
325991
325992
325998
3261
3262

IS8
IS9
IS10
IS11
IS12
IS13
IS14
IS15
IS16
IS17
IS18
IS19
IS20
IS21
IS22
IS23
IS24
IS25
IS26
IS27
IS28
IS29
IS30
IS31
IS32
IS33
IS34
IS35
IS36

Wood Product Manufacturing
Paper Manufacturing
Printing and Related Support Activities
Petroleum Refineries
Asphalt Paving, Roofing, and Coating Materials Manufacturing
Petroleum Lubricating Oil and Grease Manufacturing
All Other Petroleum and Coal Products Manufacturing
Petrochemical Manufacturing
Industrial Gas Manufacturing
Synthetic Dye and Pigment Manufacturing
Carbon Black Manufacturing
All Other Basic Inorganic Chemical Manufacturing
Cyclic Crude and Intermediate Manufacturing
All Other Basic Organic Chemical Manufacturing
Plastic Material and Resin Manufacturing
Synthetic Rubber Manufacturing
Organic Fiber Manufacturing
Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing
Pharmaceutical and Medicine Manufacturing
Paint and Coating Manufacturing
Adhesive Manufacturing
Soap, Cleaning Compound, and Toilet Preparation Manufacturing
Printing Ink Manufacturing
Explosives Manufacturing
Custom Compounding of Purchased Resin
Photographic Film Paper, Plate, and Chemical Manufacturing
All Other Chemical Product and Preparation Manufacturing
Plastics Product Manufacturing
Rubber Product Manufacturing

327

IS37

Nonmetallic Mineral Product Manufacturing (includes clay, glass, cement, concrete,
lime, gypsum, and other nonmetallic mineral product manufacturing.

D-2

Appendix D
NAICS
331
332
333
334
335
336
337
339
42
44
45
48
49
51
52
53
54
55
56
61
62
71
72
81
92

Descriptions of Processing and Use Codes
IS Code
IS38
IS39
IS40
IS41
IS42
IS43
IS44
IS45

IS Title
Primary Metal Manufacturing
Fabricated Metal Product Manufacturing
Machinery Manufacturing
Computer and Electronic Product Manufacturing
Electrical Equipment, Appliance, and Component Manufacturing
Transportation Equipment Manufacturing
Furniture and Related Product Manufacturing
Miscellaneous Manufacturing

IS46

Wholesale and Retail Trade

IS47

Services

IS48

Other (requires additional information)

D-3

Appendix D

Descriptions of Processing and Use Codes
Table D-3. Function Category Descriptions

Code

-

Category

U001A

Abrasives

U001B

Etching agent

U002A

Adhesion/cohesion promoter

U002B

Binder

U002C

Flux agent

U002D

Sealant (barrier)

U003A

Absorbent

U003B

Adsorbent

U003C

Dehydrating agent (desiccant)

U003D

Drier

U003E

Humectant

U004A

Soil amendments (fertilizers)

U005A

Anti-adhesive/cohesive

U005B

Dusting agent

U006A

Bleaching agent

U006B

Brightener

U007A

Anti-scaling agent

U007B

Corrosion inhibitor

U008A

Dye

U008B

Fixing agent (mordant)

U009A

Hardener

U009B

Filler

U010A

Anti-static agent

U010B

Softener and conditioner

U010C

Swelling agent

U010D

Tanning agents not otherwise specified

U010E

Waterproofing agent

U010F

Wrinkle resisting agent

U011A

Flame retardant

U012A

Fuel agents

U012B

Fuel

U013A

Heat transferring agent

U013B

Hydraulic fluids

U013C

Insulators
D-4

Appendix D

Descriptions of Processing and Use Codes

Code

Category

U013D

Refrigerants

U014A

Anti-freeze agent

U015A

Intermediate

U015B

Monomers

U016A

Ion exchange agent

U017A

Anti-slip agent

U017B

Lubricating agent

U018A

Deodorizer

U018B

Fragrance

U019A

Oxidizing agent

U019B

Reducing agent

U020A

Photosensitive agent

U020B

Photosensitizers

U020C

Semiconductor and photovoltaic agent

U020D

UV stabilizer

U021A

Opacifer

U021B

Pigment

U022A

Plasticizer

U023A

Plating agent

U024A

Catalyst

U024B

Chain transfer agent

U024C

Chemical reaction regulator

U024D

Crystal growth modifiers (nucleating agents)

U024E

Polymerization promoter

U024F

Terminator/Blocker

U025A

Processing aids, specific to petroleum production

U026A

Antioxidant

U026B

Chelating agent

U026C

Defoamer

U026D

pH regulating agent

U026E

Processing aids not otherwise specified

U027A

Energy Releasers (explosives, motive propellant)

U027B

Foamant

U027C

Propellants, non-motive (blowing agents)

U028A

Cloud-point depressant

U028B

Flocculating agent
D-5

Appendix D
Code

Descriptions of Processing and Use Codes
Category

U028C

Flotation agent

U028D

Solids separation (precipitating) agent, not otherwise specified

U029A

Cleaning agent

U030A

Diluent

U030B

Solvent

U031A

Surfactant (surface active agent)

U031B

Emulsifier

U032A

Thickening agent

U032B

Viscosity modifiers

U033A

Laboratory chemicals

U034A

Dispersing agent

U034B

Freeze-thaw additive

U034C

Surface modifier

U034D

Wetting agent (non-aqueous)

U035A

Aerating and deaerating agents

U035B

Explosion inhibitor

U035C

Fire extinguishing agent

U035D

Flavoring and nutrient

U036A

Anti-redeposition agent

U036B

Anti-stain agent

U036C

Anti-streaking agent

U037A

Conductive agent

U037B

Incandescent agent

U037C

Magnetic element

U038A

Anti-condensation agent

U038B

Coalescing agent

U038C

Film former

U039A

Demulsifier

U039B

Stabilizing agent

U040A

Alloying element

U040B

Density modifier

U040C

Elasticizer

U040D

Flow promoter

U040E

Sizing agent

U040F

Solubility enhancer

U040G

Vapor pressure modifiers
D-6

Appendix D
Code

Descriptions of Processing and Use Codes
Category

U041A

Embalming agent

U041B

Heat stabilizer

U041C

Preservative

U042A

Anti-caking agent

U042B

Deflocculant

U042C

Dust suppressant

U042D

Impregnation agent

U042E

Leaching agent

U043A

Tracer

U044A

X-ray absorber

U999A

Other

D-7

Appendix D

Descriptions of Processing and Use Codes
Table D-4. Consumer and Commercial Product Category Descriptions

Code

Category

Chemical Substances in Furnishing, Cleaning, Treatment Care Products
C101A

Construction and building materials covering large surface areas including stone, plaster, cement, glass and ceramic
articles; fabrics, textiles, and apparel

C102A

Furniture & furnishings including plastic articles (soft); leather articles

C103A

Furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or rubber articles

C104A

Leather conditioner

C104B

Leather tanning, dye, finishing, impregnation and care products

C104C

Textile (fabric) dyes

C104D

Textile finishing and impregnating/surface treatment products

C105A

All-purpose foam spray cleaner

C105B

All-purpose liquid cleaner/polish

C105C

All-purpose liquid spray cleaner

C105D

All-purpose waxes and polishes

C105E

Appliance cleaners

C105F

Drain and toilet cleaners (liquid)

C105G

Powder cleaners (floors)

C105H

Powder cleaners (porcelain)

C106A

Dishwashing detergent (liquid/gel)

C106B

Dishwashing detergent (unit dose/granule)

C106C

Dishwashing detergent liquid (hand-wash)

C106D

Dry cleaning and associated products

C106E

Fabric enhancers

C106F

Laundry detergent (unit-dose/granule)

C106G

Laundry detergent (liquid)

C106H

Stain removers

C107A

Ion exchangers

C107B

Liquid water treatment products

C107C

Solid/Powder water treatment products

C108A

Liquid body soap

C108B

Liquid hand soap

C108C

Solid bar soap

C109A

Air fresheners for motor vehicles

C109B

Continuous action air fresheners

C109C

Instant action air fresheners

C110A

Anti-static spray

C110B

Apparel finishing, and impregnating/surface treatment products

C110C

Insect repellent treatment

C110D

Pre-market waxes, stains, and polishes applied to footwear

C110E

Post-market waxes, and polishes applied to footwear (shoe polish)

C110F

Waterproofing and water-resistant sprays

Chemical Substances in Construction, Paint, Electrical, and Metal Products
D-8

Appendix D

Descriptions of Processing and Use Codes

Code

Category

C201A

Fillers and putties

C201B

Hot-melt adhesives

C201C

One component caulks

C201D

Solder

C201E

Single component glues and adhesives

C201F

Two component caulks

C201G

Two-component glues and adhesives

C202A

Adhesive/Caulk removers

C202B

Aerosol spray paints

C202C

Lacquers, stains, varnishes and floor finishes

C202D

Paint strippers/removers

C202E

Powder coatings

C202F

Radiation curable coatings

C202G

Solvent-based paint

C202H

Thinners

C202I

Water-based paint

C203A

Construction and building materials covering large surface areas, including wood articles

C204A

Construction and building materials covering large surface areas, including paper articles; metal articles; stone,
plaster, cement, glass and ceramic articles

C205A

Machinery, mechanical appliances, electrical/electronic articles

C205B

Other machinery, mechanical appliances, electronic/electronic articles

C206A

Articles intended for food contact, including metal articles

C206B

Construction and building materials covering large surface areas, including metal articles

C207A

Electrical batteries and accumulators

Chemical Substances in Packaging, Paper, Plastic, Toys, Hobby Products
C301A

Articles intended for food contact including paper articles; plastic articles (soft); plastic articles (hard); rubber
articles; metal articles; fabrics, textiles, and apparel

C302A

Packaging (excluding food packaging), including paper articles

C302B

Other articles with routine direct contact during normal use, including paper articles

C303A

Packaging (excluding food packaging), including rubber articles; plastic articles (hard); plastic articles (soft)

C303B

Other articles with routine direct contact during normal use including rubber articles; plastic articles (hard)

C304A

Toys intended for children’s use (and child dedicated articles), including fabrics, textiles, and apparel; or plastic
articles (hard)

C305A

Adhesives applied at elevated temperatures

C305B

Cement/concrete

C305C

Crafting glue

C305D

Crafting paint (applied to body)

C305E

Crafting paint (applied to craft)

C305F

Fixatives and finishing spray coatings

C305G

Modelling clay

C306A

Correction fluid/tape

C306B

Inks in writing equipment (liquid)

C306C

Inks used for stamps
D-9

Appendix D
Code

Category

C306D

Toner/Printer cartridge

C307A

Liquid photographic processing solutions

Descriptions of Processing and Use Codes

Chemical Substances in Automotive, Fuel, Agriculture, Outdoor Use Products
C401A

Exterior car washes and soaps

C401B

Exterior car waxes, polishes, and coatings

C401C

Interior car care

C401D

Touch up auto paint

C402A

Degreasers

C402B

Liquid lubricants and greases

C402C

Paste lubricants and greases

C402D

Spray lubricants and greases

C403A

Anti-freeze liquids

C403B

De-icing liquids

C403C

De-icing solids

C403D

Lock de-icers/releasers

C404A

Cooking and heating fuels

C404B

Fuel additives

C404C

Vehicular or appliance fuels

C405A

Explosive materials

C406A

Agricultural non-pesticidal products

C407A

Lawn and garden care products

Chemical Substances in Products not Described by Other Codes
C980A

Non-TSCA use

C909A

Other (specify)

D-10