CHEMICAL DATA
REPORTING
FACTORS TO CONSIDER WHEN USING
THE DATABASE
vvEPA
United States
Environmental Protection
Agency
The 2012 Chemical Data Reporting (CDR) database provides the
public, government officials, non-governmental organizations, and
industry access to non-confidential information on the manufacture,
import, processing, and use of chemicals in commerce at national
and regional levels. This fact sheet highlights important factors to
consider when working with the 2012 CDR database.
Reporting Thresholds
CDR reporting is triggered by the amount of a chemical
manufactured (including imported), rather than the hazard or
potential exposures associated with a chemical. Understanding
reporting thresholds of manufactured (including imported) chemicals
that trigger reporting is important when using and interpreting the
2012 CDR data.
Using CDR to
Screen Chemicals
The CDR data provides information
on chemical manufacturing,
processing, and use. To determine
potential exposures and risks to
human health and the environment,
EPA combines CDR data with
information on:
> Toxicity of the chemical
> Potential releases
> Site-specific conditions
• Determination of the need to report in 2012 was based on
whether 2011 site-specific production volume met or exceeded 25,000 pounds.
• For all reportable chemicals, manufacturers (including importers) were required to report in 2012 full
manufacturing data for calendar year 2011 and production volume only for calendar year 2010.
• The reporting threshold in 2012 was 100,000 pounds or greater for manufacturers (including
importers) to report processing and use information.
Due to these reporting thresholds, totals of CDR production volumes reported for 2012 may underestimate the
actual total amount manufactured and imported in the United States, particularly if there are a substantial
number of sites that manufacture (including import) the chemical in quantities less than 25,000 pounds per
year. When comparing changes in production over time at the site, particularly on the regional or national
levels, it is important to take into account changes in the reporting thresholds across the years of available data.
Confidential Business Information
The 2012 CDR public database provides non-confidential information on the manufacturing, processing, and use
of chemicals in commerce in the United States. It is important for users of the CDR public database to
understand what data submitters can claim as confidential business information (CBI), and the way in which the
public database has been aggregated and masked to protect CBI.
The CDR data described in this factsheet is a sub-set of the complete CDR data because confidential business information is
not included. The figures presented herein may be an underestimate.
Factors to Consider When Using the Database
EPA Publication 740K13002
page 1
February 2013
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CHEMICAL DATA
REPORTING
v>EPA
United States
Environmental Protection
Agency
Submitters may designate individual CDR data elements as CBI when they report information. However,
chemical identity may only be claimed confidential if the chemical is listed on the confidential portion of the
TSCA Inventory. Processing and use data elements can be claimed as CBI if a manufacturer (including importer)
believes that the release of information will reveal trade secrets or confidential commercial or financial
information. Submitters are required to provide upfront substantiations of confidentiality claims for chemical
identity, site identification, and processing and use information by answering a series of questions in the
reporting form. A blank response or a response that is designated as "not known or reasonably ascertainable"
may not be claimed as confidential.
Production volume may also be designated as CBI. If all the production
volumes of a chemical are not claimed as CBI, the public CDR database will
include specific values for individual and aggregated production volumes for
that chemical. However, if most or all of the production volumes reported for a
given chemical substance are claimed as CBI, the individual CBI production
volumes are not reported and aggregated production volumes are reported as
ranges to protect the CBI claims.
In preparing the CDR public database, EPA takes care to avoid release of CBI
while also publishing as much information as possible. Users examining
individual records will notice CBI protected entries in particular data fields.
When using aggregated CDR data, users should recognize that they do not have access to the complete set of
data.
Chemicals Exempt from Reporting
Manufacturers (including importers) may not be required to report information on certain chemicals to CDR
because of the type of chemical or because of the manner of manufacture (including import) or use of the
chemical.
• Chemicals manufactured (including imported) for non-TSCA uses are not required to be reported (e.g.,
pesticides are exempt from regulation by TSCA). If a portion of a manufacturer's (including importer's)
production is not subject to TSCA (for example, if the use is regulated by the Food and Drug
Administration), then the production associated with the non-TSCA second use will not be reported to
CDR. Note that manufacturers may report downstream non-TSCA uses for their chemical.
• Generally, water and naturally occurring substances are exempt from CDR requirements. Three other
groups of chemicals (polymers, microorganisms, and certain forms of natural gas) are also generally
exempt from CDR requirements. It is important to note that a particular polymer, microorganism, or
form of natural gas may not be exempt if the chemical becomes the subject of certain TSCA actions,
such as an Enforceable Consent Agreement.
The CDR data described in this factsheet is a sub-set of the complete CDR data because confidential business information is
not included. The figures presented herein may be an underestimate.
Factors to Consider When Using the Database
EPA Publication 740K13002
page 2
February 2013
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CHEMICAL DATA
REPORTING
vvEPA
United States
Environmental Protection
Agency
• Chemicals that are non-isolated intermediates, imported as part of an article, impurities, or byproducts
destined for certain commercial uses are exempt from reporting.
Manufacturers Exempt from Reporting
Small manufacturers (including importers) who meet one of the following requirements are generally exempt
from CDR requirements if:
• Total sales during 2011 combined with those of the parent company, domestic or foreign (if any), are
less than $4 million; or
• Total sales during 2011 of the parent company, domestic or foreign (if any), are less than $40 million and
annual production volume of a qualifying chemical substance does not exceed 100,000 pounds at any
individual plant site. If the annual production volume of the chemical substance at any particular site is
more than 100,000 pounds, the manufacturer is required to report for that particular site.
Reporting in Ranges
The following data elements are reported as ranges to reduce the industry reporting burden:
Manufacturing Information:
• Number of workers reasonably likely to be exposed to chemical
• Maximum concentration of chemical
Processing and Use Information:
• Percent production volume for each product category
• Maximum concentration for each product category
• Number of commercial workers reasonably likely to be exposed to chemical
Processing and Use Information
Often the processing and use of chemicals is not under the control of the manufacturers (including importers);
therefore they might have incomplete knowledge of these activities. Manufacturers (including importers) were
required to report processing and use information that was known to or reasonably ascertainable by them. They
were not required to collect information from their customers about end uses. Also, CDR submitters were not
required to report the quantities exported. As a result of these factors, the processing and use information in
the CDR public database presents only a limited picture of the actual processing and use situation in the United
States.
The CDR data described in this factsheet is a sub-set of the complete CDR data because confidential business information is
not included. The figures presented herein may be an underestimate.
Factors to Consider When Using the Database
EPA Publication 740K13002
page 3
February 2013
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