Lynn L. Bergeson, “Off to the Races—CDR Reporting Begins!,” Washington Watch, Fall 2020.
As the expression goes, it is that time of year again. Section 8 of the Toxic Substances Control Act (TSCA) requires manufacturers, including importers, to provide the U.S. Environmental Protection Agency (EPA) with information on the production and use of chemicals in commerce at four-year intervals. The last reporting cycle for the requirement, known as the Chemical Data Reporting (CDR) requirement, was in 2016, so TSCA stakeholders have been gearing up since then for the current quadrennial reporting obligation, which commenced on June 1, 2020. This column provides an overview of what is new and different since 2016.