EPA CDR reporting requirements, thresholds and 2028 deadlines
EPA CDR requires covered manufacturers and importers to report chemical data. Check site thresholds, exemptions, 2028 dates and public production records.
EPA CDR means the U.S. Chemical Data Reporting rule under TSCA, for manufacturers, including importers. The usual CDR reporting requirement is at least 25,000 lb of one reportable chemical at one site in any single relevant calendar year, subject to exemptions. Certain TSCA actions lower that threshold to 2,500 lb. EPA's basic information states both figures.
The next currently codified submission period is June 1 through September 30, 2028. It covers production during 2024 to 2027, with more information for 2027, the principal reporting year. §711.20 also sets later periods on that same window, every four years.
Who must report under the EPA CDR rule?
Start with commercial manufacture or import. Processing or using a chemical you only bought doesn't itself create that duty. The substance has to be on the TSCA Inventory at the start of the submission period under 40 CFR part 711, §711.5, unless §711.6 excludes it.
Apply the §711.8 volume test to each chemical and site. Add U.S. manufacture and imports for that chemical, at that site, in that year. Don't add the four years together, and don't use a company-wide total. Reaching 25,000 lb in any one relevant year can trigger reporting. A domestic manufacturing site is one the company owns or controls.
For an importer, the site is the U.S. operating unit directly responsible for the import. In some cases that unit is the organization's U.S. headquarters. It isn't automatically the port or warehouse. If there is no U.S. operating unit or headquarters, the site definition uses the U.S. address of an agent authorized to accept service of process.
When does the 2,500 lb threshold apply?
The lower figure uses the same site-and-year test. It isn't a catch-all for every chemical with some regulatory control. Section 711.8 applies 2,500 lb or more when the chemical is the subject of:
- A proposed or promulgated rule under TSCA section 5(a)(2), 5(b)(4) or 6.
- An order in effect under section 4, 5(e) or 5(f).
- Civil-action relief under section 5 or 7.
A section 4 test order is on that list. A section 4 test rule is not.
EPA's chemical-status spreadsheet is tied to the 2024 submissions. Don't treat it as the 2028 determination. EPA says it updates the spreadsheet by June 1 of each submission year, in its reporting overview.
Check exemptions before you file
Volume alone doesn't settle CDR reporting requirements. Section 711.6 fully exempts qualifying polymers, microorganisms, naturally occurring substances, water and specified natural-gas forms. A substance that occurs in nature isn't automatically exempt. The manufacturing method matters.
Specified TSCA actions can remove the polymer, microorganism, water and natural-gas, and partial exemptions. That opening override doesn't cover the naturally occurring exemption. And the override list is wider than the 2,500 lb list: it adds a proposed or promulgated section 4 rule, and an enforceable consent agreement under 40 CFR part 790.
A partial exemption drops processing and use reporting under §711.6. It doesn't drop all manufacturing reporting.
Activity exemptions include manufacture only in small quantities for research and development, import as part of an article, and narrowly conditioned byproducts. Calling a stream a byproduct, or calling it recycled, doesn't create the exemption. §711.10 has the conditions. EPA also excludes a chemical manufactured only for non-TSCA uses. If some of the volume is for a TSCA use, assess that portion under the overview.
The small-manufacturer exemption has limits
The small-manufacturer definition gives two alternative sales tests. Both combine the reporter's total annual sales with parent-company sales:
- Less than $120 million. More than 100,000 lb of that chemical at one site in a year removes this test for that chemical there, unless the $12 million test is met.
- Less than $12 million, at any volume.
Exactly 100,000 lb doesn't itself fail the first test. EPA's overview says "below" more loosely than the rule. Sales means all sales, not chemical sales alone.
§711.9 has a separate list of actions that remove this exemption. A significant new use rule under section 5(a)(2) lowers the threshold. It isn't on the §711.9 removal list.
CDR reporting dates and EPA Form U
The submission year isn't the production year. §711.15 asks for production quantities across four years, then further information for the principal year.
| Cycle | Production years | Principal year | Submission period |
|---|---|---|---|
| 2024 | 2020 to 2023 | 2023 | June 1 to November 22, 2024, the final extended deadline |
| 2028 | 2024 to 2027 | 2027 | June 1 to September 30, 2028, currently codified |
These dates come from §711.20 and EPA's overview.
The 2024 extension doesn't move the 2028 deadline.
Submit one Form U for each site in e-CDRweb, through EPA's Central Data Exchange (CDX). That site form lists the site's reportable chemicals. It isn't a separate EPA Form U for every chemical. Report what is "known to or reasonably ascertainable" by the reporter, which is the standard in §711.15. Annual volumes cover all four years. Other manufacturing, processing and use details are for the principal year, subject to exemptions.
How to find public CDR production and use data
Start at EPA's Access CDR Data page. The 2024 collection is there as Access, Excel and CSV ZIP downloads, with the collection labeled last updated April 2026. Those files cover 2020 to 2023, not 2024 production.
Pick the collection, download the public files and the database dictionary, then find the chemical with the identifiers those files document. Keep annual production quantities separate from principal-year processing and use information, which is the split in §711.15.
EPA's basic information page says public CDR data can also be searched in ChemView. The access page links ChemView under the 2020 collection, covering 2016 to 2019, and it doesn't show an equivalent link on the 2024 downloads. Use the 2024 files for that newer collection, and check which cycle an online search is actually displaying.
Public records aren't a complete U.S. market census. A blank result doesn't prove there was no U.S. manufacture or import. EPA says a substance can be in U.S. commerce and still not be reported under CDR. Confidentiality can also cover production volumes, and the link between a chemical, a company and a site. A public Inventory identity can't itself be claimed confidential. Both limits are in §711.30.
RegAffairs AI has a cited answer on who must report under EPA CDR. For a filing decision, match the chemical's current TSCA-action status and the site records to the applicable rule.