• Ready or Not —EPA’s Final Chemical Data Reporting Rule Has Arrived
  • September 22, 2011 | Authors: Lawrence E. Culleen; Peggy O. Otum
  • Law Firm: Arnold & Porter LLP - Washington Office
  • On August 16, 2011, the US Environmental Protection Agency (EPA or Agency) published its long-anticipated final rule amending the reporting requirements of the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) rule under 40 C.F.R. Part 710, and changing its name to the Chemical Data Reporting (CDR) rule. The CDR rule, now codified at 40 C.F.R. Part 711, requires manufacturers and importers of certain chemical substances listed on the TSCA Chemical Substances Inventory to report information about the manufacturing, processing, and use of those chemical substances. Reporting under the CDR rule for production that occurred during calendar years 2010 and 2011 will commence February 1, 2012 and conclude June 30, 2012. Given that EPA made a number of significant changes to the IUR rule, entities that have reporting obligations must begin now to become aware of and compile information needed to meet their expanded chemical reporting obligations. www.arnoldporter.com