Between February 1 and August 13, 2012, chemical manufacturers, companies that process chemicals, and companies that import chemicals evaluated their production and/or import quantities and if they exceeded thresholds they submited their inventory data to US EPA using Form U under the new Chemical Data Reporting (CDR)Rule. This CDR is required under the Toxic Substances Control Act, or TSCA.
Although new for 2012, the CDR is a revising to reporting rules that have existed for a number of years under the name “Inventory Update Reporting” or IUR. IUR reporting was required every 4-5 years, with the last reporting year being 2006.
Since the August 13, 2012 deadline for subitting Form U, some companies have determined that they exceeded reporting thresholds and did not submit their 2012 CDR report and/or their 2006 IUR report.
Under the new CDR, companies who missed their reporting requirements have an opportunity to use the new CDR tools to assemble a report and submit it as a paper copy. However, in order to comply with the Agency’s self-disclosure policy, once a violation has been discovered, a company has 21 days from the time of that discovery to disclose the violation in writing to EPA.