Wednesday, August 3, 2011

Final IUR - Chemical Data Reporting Rule - IUR Reporting Restarted

The U.S. Environmental Protection Agency has finalized the revised rule for reporting the manufacture and import of chemical substances under the Toxic Substances Control Act (TSCA), as required under 40 CFR 710 and Section 8(a) of TSCA. This rule has commonly refereed to as the Inventory Update Reporting rule, or IUR. The revised rule, known as the Chemical Data Reporting Rule (CDR), also requires that companies submit the information electronically to EPA, rather than on paper, and limits confidentiality claims by companies. Reporting for 2010 under the IUR was originally required to be submitted between June – September 2011; however, because the revised rule had not been completed, EPA temporarily suspended reporting requirement.

The CDR Rule, which falls under the Toxic Substances Control Act Inventory Update Rule (IUR), requires more frequent reporting of critical information on chemicals and requires the submission of new and updated information relating to potential chemical exposures, current production volume, manufacturing site-related data, and processing and use-related data for a larger number of chemicals. EPA is requiring companies to submit the information through the Internet, using EPA’s electronic reporting tool.

Companies will be required to start following the new reporting requirements in the next data submission period, which will occur February 1, 2012 to June 30, 2012.

[Read a Regulatory Briefing on the new TSCA Chemical Data Reporting Rule]

Notice: For many companies that manufacture chemicals, or that import chemicals for their own use or for further distribution, the IUR (now CDR) reporting requirements are the most significant compliance requirement under TSCA affecting their operations. Because the IUR reporting requirements cycle every five years, many companies need to “relearn” the reporting requirements in advance of a reporting year.

Caltha LLP will be conducting a TSCA Compliance Training Session, with an emphasis on the new Chemical Data Reporting Rule, in October 2011. This TSCA training is intended for corporate and facility environmental compliance staff, product responsibility/product stewardship coordinators, and staff involved in purchasing or arranging imports of chemicals from foreign suppliers, and other staff involved in TSCA compliance.

If you would like to receive further information on the TSCA Compliance Training Session, once scheduled, email Caltha at

For further information contact Caltha LLP at or Caltha LLP Website

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