40 CFR 711: EPA TSCA Chemical Data Reporting

Regulatory citation: 40 CFR Part 711, TSCA Chemical Data Reporting Requirements

What Is TSCA Chemical Data Reporting?

Chemical Data Reporting (CDR) is EPA's periodic collection of information on chemicals made or imported in the United States, under section 8(a) of the Toxic Substances Control Act (TSCA). Part 711 requires manufacturers, including importers, to report production volumes and processing and use information for chemical substances on the TSCA Inventory.

Reporting happens in submission periods every four years. Each report covers the principal reporting year, which is the latest complete calendar year before the submission period, plus annual volumes for the other years since the last principal reporting year.

Why Chemical Data Reporting Matters

EPA uses CDR data to screen chemicals, set priorities for risk evaluation and understand how workers and consumers may be exposed. Missing or late reports are TSCA violations.

Core Requirements

1. Check the Production Volume Threshold (711.8(a))

You must report if you manufactured or imported 25,000 lb (11,340 kg) or more of a reportable chemical substance at any single site you own or control during any calendar year since the last principal reporting year. The test applies site by site and chemical by chemical.

2. Apply the Lower Threshold Where Required (711.8(b))

The threshold drops to 2,500 lb (1,134 kg) for chemicals subject to certain TSCA actions. These include a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4) or 6, an order in effect under section 4, 5(e) or 5(f), or relief granted in a civil action under section 5 or 7.

3. Confirm Any Exemptions (711.9 and 711.10)

Small manufacturers and small governments, as defined in 40 CFR 704.3, are generally exempt. That exemption does not apply to chemicals that are the subject of certain TSCA section 4, 5(b)(4) or 6 rules, section 4 or 5(e) orders, or civil action relief. Other exempt activities include chemicals made solely in small quantities for research and development, chemicals imported as part of an article and certain listed byproducts.

4. Report the Required Data on Form U (711.15)

Each site needs its own Form U. Reports include company and site details, chemical identity, domestic production and import volumes, volume used on site and exported, and worker numbers by range code. Processing and use information covers industrial operations, sectors, functions, numbers of sites and workers, and consumer and commercial product categories. Information must be reported to the extent it is known or reasonably ascertainable.

5. Submit Electronically During the Window (711.20 and 711.35)

The 2024 submission period ran from June 1, 2024, to November 22, 2024. Later periods run from June 1 to September 30 at 4-year intervals, beginning in 2028. Form U must be completed in e-CDRweb and submitted through EPA's Central Data Exchange (CDX). No other submission method is allowed.

6. Substantiate Confidentiality Claims Up Front (711.30)

Confidential business information claims must be made and substantiated when the report is submitted, and signed by an authorized official. Some data elements cannot be claimed, such as chemical identities on the public Inventory. Information not claimed may be made public without further notice.

7. Keep Records for 5 Years (711.25)

Keep records that document the information you reported for 5 years, starting on the last day of the submission period. EPA encourages keeping them longer to help with the next cycle.

Common Compliance Approaches

Track Volumes Every Year

Pull annual production and import totals by site and chemical, so you can test every year in the four-year lookback, not just the principal year.

Screen for Lower-Threshold Chemicals

Compare your chemical list against current TSCA section 4, 5 and 6 actions before each cycle to catch the 2,500 lb threshold.

Register in CDX Early

Set up CDX accounts and authorized officials well before June 1 of the submission year.

Example: Chemical Data Reporting in Practice

A specialty chemical company imports a solvent through one terminal and makes a resin intermediate at its main plant. In 2025 the terminal imports 30,000 lb of the solvent, so it must report that chemical for the 2028 cycle even though volumes in other years were lower. The compliance team finds that the intermediate is subject to a TSCA section 6 rule, so the 2,500 lb threshold applies there too. Both Form U reports are prepared in e-CDRweb and filed through CDX before September 30, 2028.

Related regulations: EPA TSCA Section 8(e) Substantial Risk Reporting, EPA Toxics Release Inventory, EPA PCB Regulations.

Note: This summary reflects the federal regulation text current at the time of writing. EPA can change submission periods and data elements by rule, so check the current Part 711 text and EPA's CDR website before each cycle.

Frequently Asked Questions

When is the next CDR submission period?

From June 1 to September 30, 2028. The principal reporting year for that cycle is 2027, and annual volumes since the last principal reporting year are also tested.

Do importers have to report?

Yes. In Part 711, manufacturing includes importing, so importers report on the same thresholds as domestic manufacturers.

Can I submit a paper report?

No. Form U must be completed in e-CDRweb and submitted electronically through CDX.