Monday, January 3, 2011

IUR Report Deadline - When Are Inventory Update Rule Reports Due?

[Note: IUR Rule has been revised in August 2011. Click here to review summary of new rule]

Calender year 2010 was a reporting year under the TSCA Inventory Update Rule (IUR), and operations subject to IUR reporting will need to submit reports in 2011. Under Section 8(a) of the Toxic Substances Control Act (TSCA), every five years companies that either manufacture or import chemicals or mixtures of chemicals on the “TSCA List” must report their activities. The reporting requirement, referred to as the “Inventory Update Rule”, or IUR, is only one of several requirements in TSCA. The IUR requirements are the most broadly applicable of all the TSCA requirements.

When are 2011 IUR reports due?

According to the Chemical Control Division at the Environmental Protection Agency the submission period for 2011 TSCA IUR reporting is from June 1 - September 1, 2011. However, there are proposed changes to what is required for submittal. These were drafted last July, but these changes have not yet been approved. EPA expects that the submittal requirements will be finalized by at least 30 days prior to the beginning of the reporting period (by May 1, 2011).

If approved as drafted, the majority of information required will be from 2010, however, there will also be additional production data required from the years 2006 - 2010.

Caltha LLP provides technical support to clients nationwide in the preparation of IUR reports, TSCA compliance procedures, and preparing cost-effective chemical tracking and reporting programs.

For further information contact Caltha LLP at or Caltha LLP Website

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