From: Quarles & Brady LLP
The five-month period to submit required reporting under the Inventory Update Rule, now known as the Chemical Data Rule (“CDR”), begins February 1 and runs through June 30. EPA finalized the CDR on August 16, 2011. The CDR requires manufacturers to report information to EPA regarding the volume of commercial chemical substances and mixtures manufactured, processed, and used by facilities located in the United States. The rule has changed significantly in the five years since reporting was last required in 2007, and the vague nature of the guidance provided with the rule has lead to concerns from some in Congress that EPA is setting industries up for enforcement.
The CDR requires reporting of chemical production volumes for 2010 and chemical production, processing, and use information from 2011. The CDR also requires the reporting of byproducts that are being recycled or reprocessed. Under guidance issued by the agency with the rule, byproducts such as metallic or coke fines, as well as spent solvent solutions may be considered chemicals “manufactured” by a given facility and may require reporting under the rule.
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