For detailed information on the CDR reporting requirements, please refer our client alert here.
Under the rule, regulated companies must disclose certain information on the chemical substances they manufacture or import. This information can include specific production volume, processing and use, or other relevant technical data. Additionally, upfront substantiation is required for Confidential Business Information (CBI) claims for processing and use information, as well as for site identity and chemical identity. CBI claims must be made and substantiated at the time the information is submitted. Otherwise, the information reported will not be confidential.
Because all data must be submitted electronically using US EPA’s web-based reporting tool (e-CDRweb) through EPA’s Central Data Exchange (CDX), we recommend uploading the required data to US EPA well in advance of the October 31, 2016 deadline to avoid any last-minute problems. If a company fails to submit and upload all applicable data by the deadline, it could face potential enforcement action and penalties.
Squire Patton Boggs attorneys are available to assist with any questions regarding the CDR reporting requirements.