Instructions for Reporting
PFAS Under TSCA Section 8(a)(7)
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics
October 2023
EPA-705-G-2023 -3 727
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DOCUMENT HISTORY
Dociimonl l);ilc
Art ion
October 2023
Creation of original document and posting to docket and TSCA website
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HIGHLIGHTS OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR
PFAS UNDER TSCA 8(a)(7)
• Reporting is required for any manufacturer (including importer) of a per- or poly-fluoroalkyl
substance (PFAS).
• Reporting is required for all PFAS, as defined in 40 CFR 705, that are chemical substances as
defined by TSCA, that have been manufactured (including imported) for commercial
purposes during this rule's lookback period.
• Information on the reportable chemical substance must be reported during the data submission
period (40 CFR 705).
• All reporting sites must report PFAS data electronically, using the section 8(a)(7) web-based
reporting tool within EPA's Central Data Exchange (CDX) system. Prior to submitting data,
submitters must register with CDX. Ensure that your pop-up blocker is disabled before you
begin to use the PFAS section 8(a)(7) tool to complete your form.
• Streamlined reporting is available for importers of articles and for manufacturers of less than
10 kg of a substance used solely for research and development.
• No small manufacturer exemptions are in effect for this data call. You may be required to
report under this PFAS data call even if you are not required to report to under other TSCA
requirements such as CDR due to a small manufacturer exemption.
• Information submitted under this data call may be claimed as confidential; however, such
claims must be made at the time of submission and substantiated in accordance with TSCA
and the PFAS data reporting rule. Submitters must provide upfront substantiation of all
confidentiality claims except for claims made for import or yearly production volume
information. Submitters who do not know the underlying identity of the chemical other than a
generic chemical name (i.e., do not know a CASRN, or TSCA Accession or LVE numbers)
are not required to assert and substantiate a CBI claim for chemical identity. Reporters using
the article importer form also are not required to assert and substantiate a CBI claim for
specific chemical identity. Certain processing and use data elements or a response that is
designated as "not known or reasonably ascertainable" may not be claimed as confidential (40
CFR 705.30).
• Visit the section 8(a)(7) rule website (https://www.ena.gov/assessine-and-managine-
chemicals-under-tsca/tsca-section-8a7-revorting-and-recordkeeying) for other guidance
materials and contact information for technical assistance.
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TABLE OF CONTENTS
1. Introduction 1-1
1.1 Background and Statutory Authority 1-1
1.2 Duplicative reporting 1-1
2. Reporting Requirements 2-1
2.1 Step I: Is Your Chemical Substance Subject to section 8(a)(7)? 2-1
2.1.1 Is Your Chemical Substance Manufactured for Commercial Purposes
During the Reporting Period? 2-2
2.1.2 Is Your Chemical Substance a PFAS? 2-3
2.2 Step II: Do You Qualify for Streamlined Reporting? 2-4
2.2.1 Did you import an article containing a reportable PFAS? 2-5
2.2.2 Did you manufacture a reportable PFAS in quantities below 10 kg per
year exclusively for purposes of research and development (R&D)? 2-6
2.3 Step III: What Information Must You Report? 2-7
3. When You Must Report 3-1
4. Instructions for Completing Section 8(a)(7) Reporting 4-1
4.1 Certification 4-2
4.2 Reporting Standard 4-2
4.3 Part I - Section A. Parent Company Information 4-5
4.3.1 U.S. Parent Company Name(s) 4-6
4.3.2 Parent Company Dun & Bradstreet D-U-N-S® Number 4-6
4.3.3 Parent Company Address 4-7
4.4 Part I - Section B. Site Information 4-8
4.4.1 Confidentiality of Company, Site, and Technical Contact Information 4-8
4.4.2 Special Provisions for Certain Sites 4-8
4.4.3 Site Name 4-9
4.4.4 Site Dun & Bradstreet Number D-U-N-S® 4-9
4.4.5 Site Street Address 4-9
4.4.6 NAICS code 4-9
4.4.7 Technical Contact Information 4-10
4.5 Part II - Section A. Chemical Substance Identification 4-10
4.5.1 Confidentiality of Chemical Substance Information 4-11
4.5.2 Are you manufacturing a mixture or a chemical substance of unknown
or variable composition or a polymer? 4-13
4.5.3 How to Report when Chemical Identity is Unknown 4-14
Provide the trade name or common name as appropriate. If the PFAS does not
have a trade name or common name, report "NA." For the molecular
structure, provide a correct representative or partial chemical structure
diagram, as complete as can be known, if one can be reasonably
ascertained. Further details on what to include in the structure diagram
are provided in Section 4.5.9 4-15
4.5.4 Chemical Substance Identifying Number 4-15
4.5.5 ID Code 4-16
4.5.6 Chemical Name 4-16
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4.5.7 Trade Name or Common Name 4-17
4.5.8 Generic Chemical Name or Description 4-17
4.5.9 Molecular Structure 4-17
4.5.10 Additional Information on Chemical Identity 4-18
4.5.11 Special Provisions for Joint Submitters of Unknown Chemical
Substances 4-18
4.5.12 Physical Form 4-19
4.6 Part II - Section B. The categories of use of each such substance or mixture 4-19
4.6.1 Confidentiality of Processing and Use Information 4-19
4.6.2 Industrial Processing and Use 4-20
4.6.3 Consumer and Commercial Use 4-26
4.7 Part II - Section C. Manufacturing, Processing, and Use Information 4-33
4.7.1 Confidentiality of Manufacturing Information 4-33
4.7.2 Reporting Manufacturing Information 4-34
4.8 Part II - Section D. A description of the byproducts resulting from the manufacture,
processing, use, or disposal of each such substance or mixture 4-40
4.8.1 Confidentiality of Byproduct Information 4-41
4.8.2 Byproduct Name or Description 4-41
4.8.3 Byproduct Generic Chemical Name [if byproduct chemical name is
CBI] 4-41
4.8.4 Byproduct Chemical ID 4-42
4.8.5 Byproduct Source 4-42
4.8.6 Byproduct Release 4-42
4.8.7 Byproduct Release Medium 4-42
4.8.8 Byproduct Release Volume 4-42
4.9 Part II - Section E. All existing information concerning the environmental and health
effects of such substance or mixture 4-44
4.9.1 Confidentiality of Environmental and Health Effects Information 4-44
4.9.2 OECD Harmonized Environmental and Health Effects Template
(attachment) 4-44
4.9.3 Study Report (attachment) 4-45
4.9.4 Supporting Information (attachment) 4-45
4.9.5 Analytical/Test Methods 4-45
4.9.6 Other Data Relevant to Environmental or Health Effects 4-46
4.10 Part II - Section F. The number of individuals exposed, and reasonable estimates of
the number who will be exposed, to such substance or mixture in their places of
employment and the duration of such exposure 4-46
4.10.1 Confidentiality of Worker Exposure Information 4-46
4.10.2 Worker Activity Descriptions 4-46
4.10.3 Number of Workers Exposed at the Manufacturing Site 4-47
4.10.4 Maximum Duration of Exposure for Manufacturing Workers 4-48
4.10.5 Number of Workers Exposed for each Industrial Process and Use 4-50
4.10.6 Maximum Duration of Exposure for Industrial Workers 4-50
4.10.7 Number of Workers Exposed for each Commercial Use 4-52
4.10.8 Maximum Duration of Exposure for Commercial Workers 4-52
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4.11 Part II - Section G. The manner or method of its disposal, and in any subsequent
report on such substance or mixture, any change in such manner or method 4-54
4.11.1 Confidentiality of Disposal Information 4-54
4.11.2 Manner or Method of Disposal 4-54
4.11.3 Changes in Disposal Methods 4-55
4.11.4 Release Quantity 4-55
4.11.5 Incineration Quantity and Temperature 4-56
4.12 Optional Information 4-56
4.13 Joint Submissions 4-56
4.13.1 Determining the Need for a Joint Submission 4-56
4.13.2 The Primary Submission is Completed by the PFAS Manufacturer 4-57
4.13.3 The Secondary Submission is Completed 4-57
4.13.4 Confidentiality of Information Jointly Submitted 4-58
5. How to Obtain Copies of Documents Cited in This Instructions Document 5-1
5.1 Obtaining Copies of the TSCA Rules 5-1
5.2 Obtaining Copies of Other Information Materials 5-1
Appendix A. Glossary of Terms 1
Appendix B. Key Comparisons between Section 8(a)(7) Data Call and CDR 1
Reporting Exemptions 1
Reported Data Elements 1
Covered Timeframe 1
Considerations for CBI claims 2
Appendix C. Examples of PFAS covered by this rule 1
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories 1
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APPENDICES
Appendix A. Glossary of Terms A-l
Appendix B. Key Comparisons between Section 8(a)(7) Data Call and CDR B-l
Appendix C. Examples of PFAS covered by this rule C-l
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors,
Function Categories, and Consumer and Commercial Product Categories D-l
LIST OF FIGURES
Figure 2-1. Decision Logic Diagram for Evaluating Step II 2-5
LIST OF TABLES
Table 1-1. Examples of prior reporting impacts on PFAS data call reporting 1-4
Table 4-1. Examples of the Application of the "Known to or Reasonably Ascertainable" Reporting Standard for
Processing and Use Data 4-3
Table 4-2. Applying Highest-level Parent Company Definition in Different Situations 4-5
Table 4-3. Parent Company Name Standardization 4-6
Table 4-4. Parent Company Street Address Standardization 4-7
Table 4-5. Substantiation Questions to be Answered when Asserting Chemical Identity CBI Claims (40 CFR 705.30(e))
4-12
Table 4-6. ID Code for Chemical Identifying Numbers 4-16
Table 4-7. Codes for Reporting Types of Industrial Processing or Use Operations 4-21
Table 4-8. Codes for Reporting Industrial Sectors 4-22
Table 4-9. Codes for Reporting Function Categories 4-23
Table 4-10. Product Category Codes 4-27
Table 4-11. Examples of Products Intended for Use by Children 4-32
Table 4-12. Codes for Reporting Maximum Concentration 4-33
Table 4-13. Substantiation Questions to be Answered when Asserting Manufacturing, Processing, and Use-Related
Confidentiality Claims (40 CFR 705.30(b)) 4-34
Table 4-14. Examples of Reporting Volumes for Part II-Section C 4-36
Table 4-15. Examples of Reporting Industrial Processing and Use Information 4-37
Table 4-16. Examples of Reporting Consumer and Commercial Use Information 4-39
Table 4-17. Examples of Reporting Recycling 4-39
Table 4-18. Examples of Byproduct Reporting 4-43
Table 4-20. Codes for Reporting Number of Workers Reasonably Likely to be Exposed 4-47
Table 4-20. Example manufacturing worker exposure scenarios 4-49
Table 4-21. Example industrial worker exposure scenarios 4-51
Table 4-22. Example commercial worker exposure scenarios 4-53
Table 4-23. Disposal Process codes 4-54
Table 4-24. Release media for disposal codes 4-55
Table D-l. Type of Processing or Use Operation and Descriptions D-2
Table D-2. Industrial Sector (IS) Code Descriptions with NAICS Crosswalk D-3
Table D-3. Product Category Codes D-5
Table D-4. Function Category Descriptions and Crosswalk: Section 8(a)(7) reporting and 2016-2020 CDR D-9
Table D-5. Consumer and Commercial Product Category Descriptions and Crosswalk D-13
Table D-6. Examples of Products Intended for Use by Children D-24
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PREFACE
The primary goal of this document is to help the regulated community comply with the
requirements of the TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for
Perfluoroalkyl and Polyfluoroalkyl Substances rule, hereafter referred to as section 8(a)(7)
reporting. This document does not substitute for that rule, nor is it a rule itself. It does not impose
legally binding requirements on the regulated community or on the U.S. Environmental
Protection Agency (EPA).
Manufacturers (including importers) are required by the section 8(a)(7) rule to report to
EPA information concerning the manufacturing, use, disposal, and environmental and health
effects of certain Perfluoroalkyl or Polyfluoroalkyl Substances (PFAS). Manufacturers
(including importers) are subject to the reporting requirements based on manufacturing
(including importing) activities conducted since January 1, 2011. This is a one-time reporting
event to provide greater transparency on the uses and risks associated with PFAS and is
mandated by the Fiscal Year 2020 National Defense Authorization Act (NDAA).
Data submissions are due by the close of the submission period. The submission period
will begin twelve months following the effective date of the final rule and will last for six
months. PFAS manufacturers will have 18 months from the effective date of the rule to report:
May 8, 2025. For small manufacturers (using the same definition as 40 CFR 704.3) whose PFAS
reporting obligations are exclusively due to article import, the submission period will last twelve
months, such that all reporting from these small article importers is due two years from the
effective date of the final rule: November 10, 2025. Data must be submitted using the "TSCA
section 8(a)(7) PFAS data call rule" service via EPA's Central Data Exchange (CDX), hereafter
referred to as the "reporting tool." Submitters are required to use the reporting tool to prepare
their submissions. The reporting tool guides users through a "hands-on" process of creating an
electronic submission. A user guide on how to register for CDX and access the reporting tool is
available on the TSCA section 8(a)(7) Reporting andRecordkeeping Requirements for
Perfluoroalkyl and Polyfluoroalkyl Substances website at https://www. epa. gov/assessing-and-
manasins-chemicals-under-tsca/tsca-section-8a7- reporting-and-recordkeeping.
This instructions document contains the following chapters and appendices:
• Chapter 1 - Introduction to the TSCA section 8(a)(7) PFAS reporting rule.
• Chapter 2 - Reporting requirements to determine which chemical substances are reportable,
who must report, and what information must be reported.
• Chapter 3 - When you must report.
• Chapter 4 - Instructions for completing section 8(a)(7) reporting.
• Chapter 5 - How to obtain copies of documents cited in this Instructions document.
• Appendix A - Glossary.
• Appendix B - Key Comparisons between Section 8(a)(7) Data Call and CDR
• Appendix C - Examples of PFAS covered by this rule.
• Appendix D - Descriptions of codes for reporting Processing or Use Operations, Industrial
Sectors, Industrial Function Categories, and Consumer and Commercial Product and
Function Categories.
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Chapter 1
Introduction
1. Introduction
1.1 Background and Statutory Authority
In accordance with obligations under TSCA section 8(a)(7), as amended by the National
Defense Authorization Act for Fiscal Year 2020, EPA is requiring persons that manufacture
(including import) or have manufactured these chemical substances for commercial purposes in
any year since January 1, 2011, to submit information to EPA regarding PFAS uses, production
volumes, byproducts, disposal, exposures, and existing information on environmental or health
effects.
This document provides detailed information and examples to assist manufacturers
(including importers) in reporting under TSCA section 8(a)(7). This document also makes
reference to a user guide for the reporting tool, which provides information for getting started
with the reporting tool and includes representative screenshots. The section 8(a)(7) Online
Reporting Guide is available on the TSCA section 8(a)(7) website at
https:/Avww.epa.sov/assessins-and-manasins-chemicals-under-tsca/tsca-section-8a7-reportins-
and-recordkeeying.
Appendix A of this document provides a glossary of terms, which may help you to
understand the reporting requirements.
This document is not a substitute for the TSCA section 8(a)(7) PFAS rule in 40 CFR
Part 705. To the extent that any inconsistencies exist between the section 8(a)(7) rule and this
document, the requirements as promulgated in the rule should be followed. You should carefully
review 40 CFR Part 705 and the final rule preamble (available in this rule's docket at
www.regulations.gov; docket ID EPA-HQ-OPPT-2020-0549) to determine whether you are
required to report information under the section 8(a)(7) rule.
1.2 Duplicative reporting
Your site may have already reported some section 8(a)(7) data to EPA through another
EPA program. If that is the case, the site should determine whether EPA has identified such
reporting as "duplicative" in the section 8(a)(7) rule. If EPA has identified the reporting as
duplicative, your site is not required to re-report duplicative information, but must submit a
report and include all information required by this data call that has not been previously reported
to EPA. Information that has been reported for some but not all years from 2011 to 2022 must be
reported for the "missing" years. Information that has been previously reported, but not to the
level of detail required by this data call, or using exemptions not applicable to this data call, must
be reported under this data call to the level of detail required, if known to or reasonably
ascertainable by you. In the event that new, more accurate, or more detailed information has
become known to or reasonably ascertainable by the site, that information must be reported
under this data call.
The electronic reporting system will allow you to indicate that certain information has
already been reported to EPA. EPA has identified data elements that could have been previously
reported under Chemical Data Reporting (CDR); Toxics Release Inventory (TRI) reporting, also
known as section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA
313); Greenhouse Gas Reporting (GHGRP); and TSCA sections 8(d) and 8(e). Additionally,
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Chapter 1
Introduction
there may be limited overlap between forms submitted under section 8(a)(7) reporting in the
event that a reportable PFAS is produced as a byproduct during manufacture, processing, or
disposal of another reportable PFAS.
The section 8(a)(7) reporting software will identify the data elements that could contain
information already reported to EPA. For these data elements, you may indicate if your company
has already reported the information to EPA. You must clearly indicate where the information
can be found (i.e., which reporting program) and when that information was submitted (i.e.,
which year). Information must have been reported as required by the section 8(a)(7) rule; for
example, other programs may have exemptions, such as for articles or impurities, that could
mean information reported to those programs was not reported as required by this data call.
EPA anticipates that the primary program with "duplicative reporting" is Chemical Data
Reporting (CDR). Two other EPA programs that have minor overlap with section 8(a)(7) include
the Toxics Release Inventory (TRI) and the Greenhouse Gas Reporting Program (GHGRP).
Note, however, that these programs both cover only a limited subset of the PFAS covered by
section 8(a)(7) and have thresholds for reporting that do not apply to this data call. Therefore,
you may be required to report under this data call even if you were not required to report under
TRI or GHGRP. Further, due to differences in how data are to be reported to those programs,
reporting to TRI or GHGRP may not fulfill the requirements of this data call. Some health or
environmental information may also have been reported under TSCA section 8(d) or TSCA
section 8(e) or another authority.
Note that information reported on pre-manufacture notices (PMNs) or low volume
exemptions (LVEs) generally does not fulfill requirements under section 8(a)(7), as PMNs and
LVEs reflect information before manufacture of a substance commences.
Information reported to entities other than EPA, such as state agencies, or provided to
EPA outside a formal EPA reporting program (such as comments provided on a proposed rule),
does not fulfill your requirement to report to EPA under section 8(a)(7) and cannot be cited as
duplicative reporting.
EPA expects that even when a company has previously reported some section 8(a)(7)
information, that information will constitute only a minority of information to be reported under
this data call.
Information that may have previously been reported under CDR includes:
(1) Physical state of the PFAS pursuant to § 711.15(b)(3)(C)(ix);
(2) Industrial processing and use type, sector(s), functional category(ies), and percent of
production volume for each use, pursuant to § 711.15(b)(4)(i)(A) through (D);
(3) Consumer and/or commercial indicator, product category(ies), functional category(ies),
percent of production volume for each use, indicator for use in products intended for
children, and maximum concentration in the product, pursuant to § 711.15(b)(4)(ii)(A)
through (F);
(4) Number of workers reasonably likely to be exposed for each combination of industrial
processing or use operation, sector, and function, pursuant to § 711.15(b)(4)(i)(F), and the
number of commercial workers reasonably likely to be exposed when the substance is
used in a commercial product, pursuant to § 711.15(b)(4)(ii)(G).
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Chapter 1
Introduction
Information that may have been reported to TRI includes:1'2
(1) Total volume recycled on-site
(2) Description of disposal process(es)
(3) Total volume released to land
(4) Total volume released to water
(5) Total volume released to air
(6) Total volume incinerated on site3
Information that may have been reported to GHGRP includes:1
(1) Production volume (imported)
(2) Volume directly exported
(3) Total volume incinerated on site
Information that may have been reported under TSCA section 8(d) or 8(e) or another authority
includes:
(1) Environmental and health effects (OECD harmonized template)
(2) Environmental and health effects study report
(3) Environmental and health effects supporting information
Table 1-1 shows some examples of how companies may consider prior reporting.
1 Due to differences in reporting requirements, exemptions, and other programmatic requirements,
reporting to TRI and GHGRP may not meet the requirements of TSCA section 8(a)(7). Carefully review any
previous TRI or GHGRP submissions and calculation methods to determine if you may claim duplicative reporting.
You may claim duplicative reporting for TRI and/or GHGRP only if the data were reported as required by the
section 8(a)(7) rule.
2 Only certain PFAS chemicals are reportable under TRI. Most PFAS were added to the TRI chemical list
for 2020 reporting, while some chemicals meeting the definition of PFAS used for PFAS 8(a)(7) reporting have
been reportable since before 2011. Note that the TRI chemical list includes certain chemicals as unspecified isomers,
such as dichloropentafluoropropane, which could include both chemicals considered to be PFAS and chemicals not
considered to be PFAS. In the event you know which isomer(s) were used at the site, you must report the specific
isomers for PFAS 8(a)(7) reporting and may not consider reporting to TRI under a mixed isomer listing as
duplicative.
3 Carefully review any incineration data reported to TRI to determine if it is duplicative. To claim
duplicative reporting, EPA must be able to determine the total volume of the chemical incinerated on site. EPA
anticipates that many reporters' TRI reports will not fulfill the requirements of Section 8(a)(7) for the total volume
incinerated on site.
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Chapter 1
Introduction
Table 1-1. Examples of prior reporting impacts on PFAS data call reporting
Pro ions Reporting
A manufacturer previously reported on Example
PFAS A under 2020 CDR. That report included
information required by section C of this data
call, from 2016 through 2019. Most information
required by section C was reported for only the
principal reporting year, 2019, and some
information for section C was reported for 2016-
2018. The site started manufacturing the PFAS
in 2015 but did not meet the CDR reporting
threshold for that year. The manufacturer
continued to produce Example PFAS A in the
years since its last CDR report.
Sili- section XIum"7) responsibilities
The manufacturer considers whether any exemptions
applied to the prior CDR reporting that are not
available under this rule. The manufacturer
determines that the data previously submitted to
CDR did not exempt any activities or quantities that
would be reportable under this rule, and therefore
may be considered duplicative. For section C, the
manufacturer indicates that data were already
reported to CDR for the applicable fields for 2019,
completing the fields for "site-limited?" and
recycling, which are not reported to CDR. The
manufacturer also indicates the data were already
reported to CDR for the fields that were reported for
2016-2018. The manufacturer fills in the remaining
section C information for 2016-2018 and all section
C information for 2015 and 2020-2022. The
manufacturer fills in information for 2015-2022 in
all other sections of its PFAS data call reports, as
that information has not been reported to EPA for
any year.
A manufacturer previously reported information
about Example PFAS B, which was
manufactured from 2012-2015, to the 2016
CDR. At the time of 2016 CDR submission,
several required data fields were not known to
or reasonably ascertainable by the company
(NKRA). However, the company since learned
additional information about the chemical.
Example Company C manufactures Example
PFAS C and has begun gathering and compiling
information about this chemical for 2024 CDR
(for activities from 2020-2023). The company's
2024 CDR report will not be submitted before
the end of the section 8(a)(7) submission period.
Example Company D imported Example PFAS
D at one site in 2015. 10,000 pounds of Example
PFAS D was imported as a component of an
article, and 50,000 pounds was imported in a
mixture. The company reported Example PFAS
D to CDR for 2015, reporting on the 50,000
pounds imported in the mixture. The company
did not consider the 10,000 pounds of Example
PFAS D imported as articles, which are exempt
for CDR reporting.
The manufacturer indicates duplicative reporting for
the data that was known to the site and submitted to
EPA for 2012-2015. The manufacturer must report
newly acquired information to this PFAS data call
for fields reported as "NKRA" to CDR for 2012-
2015. The manufacturer may indicate duplicative
reporting for remaining fields that were originally
reported as "NKRA" and for which the manufacturer
has not acquired new information.
The company must report the 2020-2022 information
under section 8(a)(7) reporting, even if the
information will be reported to EPA in the future.
EPA encourages submitters to review their in-
progress CDR submissions in gathering data for
section 8(a)(7) submissions, and vice versa, to
reduce overall reporting burden.
The company must newly report all information for
Example PFAS D under this data call. Because
information reported to CDR excluded quantities
imported in articles, which are not exempt under this
data call, the information was not previously
reported as required by this data call. The site may
not indicate duplicative reporting.
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Chapter 1
Introduction
Pro ions Roporlinii
Example Company E imported an article
containing Example PFAS E in 2012,2013, and
2017, but has not been previously required to
report this information to any EPA programs.
The site reported information about this
chemical to the state of Washington's
Department of Ecology pursuant to the state's
requirements for chemicals in children's
products.
Silo section St;!))"7) responsibilities
The company must report to EPA all information
required by this data call for 2012, 2013, and 2017,
and indicate that Example PFAS E was not produced
in the other years. Reporting to a state program does
not fulfill or reduce any requirements for reporting
under this PFAS data call.
Example Company F manufactured 1,000
pounds of Example PFAS F each year during
2019, 2020, and 2021. Example PFAS F was
added to the TRI chemical list for 2020
reporting and was not TRI-reportable for 2019.
Each year, 50 pounds of the PFAS were
manufactured and used for quality control in a
laboratory on-site. All Example PFAS F
produced at Example Company D was disposed
of in the site's on-site landfill. After determining
that the quantity of Example PFAS F used in the
laboratory was exempt from TRI reporting,
Company C reported 950 pounds of Example
PFAS F releases to TRI for 2020 and 2021.
The company must report all information about
Example PFAS F for 2019, because no TRI report
was filed for that year. The site may not indicate
duplicative reporting for release quantities for 2020
and 2021, because the quantities reported to TRI
excluded laboratory uses that are not exempt under
Section 8(a)(7) reporting. The company instead
reports 1,000 pounds of land disposal for 2020 and
2021. The company may indicate duplicative
reporting for types of disposal processes and the
quantities released to air, water, and recycled on-site.
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Chapter 2
Reporting Requirements
2. Reporting Requirements
PFAS data reporting rule requirements apply to certain persons that manufacture
(including import) or have manufactured PFAS in any year since January 1, 2011. The term
"PFAS" is defined in Appendix A and examples of PFAS are provided in Appendix B. Please
note that any use of the term "manufacture" in this document will encompass "import" and the
term "manufacturer" will encompass "importer."
For reporting to the PFAS data reporting rule, manufacturers (including importers) are
required to use the section 8(a)(7) reporting tool via EPA's CDX to submit information in
response to the requirements of the section 8(a)(7) rule (40 CFR Part 705). You must register
with CDX to submit online, and you must register the name of the company on whose behalf you
are submitting. EPA does not accept paper submissions or electronic media (diskette, CD-ROM,
etc.) for any section 8(a)(7) submission (40 CFR 705). See the section 8(a)(7) Online Reporting
Guide for more information.
Note that many aspects of reporting for this PFAS data reporting rule are similar to
Chemical Data Reporting (CDR), but there are important differences. Even if you have reported
previously under the CDR or were exempt from reporting under CDR, you should carefully
review the reporting requirements for this rule to ensure you report correctly. Key comparisons
between section 8(a)(7) and CDR are outlined in Appendix B of this document.
You should consider the following three steps to determine whether you are required to report
for each PFAS chemical substance that you domestically manufacture (including import) into
the United States during each year since 2011 (i.e., consider calendar years 2011 through
2022):
• Step 1: Is your chemical substance subject to PFAS 8(a)(7)?
• Step 11: Do you qualify for streamlined reporting?
• Step 111: What information must you report?
This chapter discusses each of these steps and the associated reporting requirements in
more detail.
2.1 Step I: Is Your Chemical Substance Subject to section 8(a)(7)?
For the purposes of the section 8(a)(7) Reporting Rul e, per- andpolyfluoroalkyl
substances or PFAS means any chemical substance that contains at least one of these three
structure units:
1) R-(CF2)-CF(R')R", where both the CF2 and CF moieties are saturated carbons
2) R-CF2OCF2-R', where R and R' can either be F, O, or saturated carbons
3) CF3C(CF3)R'R", where R' and R" can either be F or saturated carbons.
This definition may not be identical to other definitions of PFAS used within EPA and/or
other organizations. To assist potential reporters with determining whether certain substances
may be covered under this structural definition, EPA has identified specific PFAS covered by
this rule. This non-exhaustive list is available in EPA's CompTox Dashboard
(https://www.epa.sov/chemical-research/comptox-chemicals-dashboard) and a limited version
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including only chemicals on the public TSCA Inventory or with low-volume exemptions is
included as Appendix B in this guidance document.
Note that the manufacture of PFAS as a byproduct, an impurity, or a non-isolated
intermediate is not exempt for the purpose of this rule, unlike CDR reporting. However, because
entities that import of municipal solid wastes (MSW) for the purpose of disposal or destruction
cannot know or reasonably ascertain that they imported PFAS in the MSW streams, these waste
management activities are not within the scope of this rule's reporting requirements. Per 40 CFR
705.15, "reporting under this part is not required for the import of municipal solid waste streams
for the purpose of disposal or destruction of the waste."
2.1.1 Is Your Chemical Substance Manufactured for Commercial Purposes During the
Reporting Period?
The first step in determining your reporting requirements is to determine whether you
meet the definition of manufacture or manufacturer. The following manufacturing-related terms
are defined below:
~ Manufacture - To import into the customs territory of the United States (as defined in
general note 2 of the Harmonized Tariff Schedule of the United States), produce, or
manufacture for commercial purposes. (40 CFR 705.3)
~ Manufacture for commercial purposes - (1) To import, produce, or manufacture with
the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer, and includes among other things, such "manufacture" of any amount of a
chemical substance or mixture:
(i) For commercial distribution, including for test marketing.
(ii) For use by the manufacturer, including use for product research and
development, or as an intermediate.
(2) Manufacture for commercial purposes also applies to chemical substances that are
produced coincidentally during the manufacture, processing, use, or disposal of
another chemical substance or mixture, including both byproducts that are separated
from that other substance or mixture and impurities that remain in that chemical
substance or mixture. Such byproducts and impurities may, or may not, in themselves
have commercial value. They are nonetheless produced for the purpose of obtaining a
commercial advantage since they are part of the manufacture of a chemical product
for a commercial purpose (40 CFR 705.3).
For purposes of section 8(a)(7) reporting, a chemical substance is manufactured
(including imported) only if it is domestically produced or imported for commercial purposes.
See TSCA section 8(f), TSCA section 3(9), and 40 CFR 704.3, which includes a parallel
definition of "Import for commercial purposes." In the case of chemical substances
manufactured (including imported) by one person on behalf of another person, the manufacturer
is the person actually manufacturing the chemical substance.
As identified above, the term manufacture for commercial purposes means that the
chemical substance is produced for the purpose of obtaining an immediate or eventual
commercial advantage. Manufacture for commercial purposes also applies to chemical
substances that are produced coincidentally during the manufacture, processing, use, or disposal
of another chemical substance or mixture, including both byproducts that are separated and
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impurities that remain in a chemical substance or mixture (40 CFR 705.3). Certain activities are
not considered "manufacture for a commercial purpose" (e.g., non-commercial R&D activities
such as scientific experimentation, research, or analysis conducted by academic, government, or
independent not-for-profit research organizations, unless the activity is for eventual commercial
purposes) and are not subject to the reporting requirements in this rule.
2.1.1.1 Changes to Company Ownership or Legal Identity
Under 40 CFR 705, the reporting obligation falls to the "person who manufactured
(including imported)" a chemical substance that is a PFAS. EPA recognizes that in some cases,
business transactions occurring during the reporting period have led to questions about who is
now the "person who manufactured." The scenarios in Fact Sheet: Reporting After Changes to
Company Ownership or Legal Identity are intended to serve as a general aid in appropriately
resolving these questions, but they will not necessarily account for all the relevant circumstances
of a particular transaction {note that while this fact sheet was developedfor CDR, changes in
company ownership or legal identity are to be handled the same for section 8(a)(7) reporting as
for CDR). It is ultimately the manufacturer's responsibility to report appropriately under this data
call, notwithstanding the complexity of its own business transactions.
2.1.2 Is Your Chemical Substance a PFAS?
For the purposes of this proposed action, the definition of PFAS includes any chemical
substance that structurally contains at least one of the following three sub-structures:
1. R-(CF2)-CF(R')R", where both the CF2 and CF moieties are saturated carbons
2. R-CF2OCF2-R', where R and R' can either be F, O, or saturated carbons
3. CF3C(CF3)R'R", where R' and R" can either be F or saturated carbons.
This definition may not be identical to other definitions of PFAS used within EPA and/or
other organizations. To assist potential reporters with determining whether certain substances
may be covered under this structural definition, EPA has identified specific PFAS covered by
this proposed rule. This non-exhaustive list is available in EPA's CompTox Dashboard and a
limited version including only chemicals on the public TSCA Inventory or with low-volume
exemptions as of the publication of this guidance document is included as Appendix B in this
guidance document. Note that the CompTox list may change as chemicals are added to the
Dashboard.
Manufacturers must consider all manufacturing activities during the reporting period,
which begins January 1, 2011. If a manufacturer has manufactured PFAS for commercial
purposes in any year since January 1, 2011, they would be required to report under this rule even
if they are not currently manufacturing PFAS.
This rule is limited to manufacturers (including importers) of PFAS that are considered a
"chemical substance" under TSCA section 3(2). This rule does not require reporting on activities
that are excluded from the definition of "chemical substance" in TSCA section 3(2)(B).
Under TSCA section 3(2), "chemical substance" means any organic or inorganic
substance of a particular molecular identity, including (1) any combination of such substances
occurring in whole or in part as a result of a chemical reaction or occurring in nature, and (2) any
element or uncombined radical. This rule does not require reporting on activities that are
excluded from the definition of "chemical substance" in TSCA section 3(2)(B). The term
"chemical substance" does not include: "(i) any mixture, (ii) any pesticide (as defined by the
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Federal Insecticide, Fungicide, and Rodenticide Act) when manufactured, processed, or
distributed in commerce for use as a pesticide, (iii); tobacco or any tobacco product, (iv) any
source material, special nuclear material, or byproduct material (as such terms are defined in the
Atomic Energy Act of 1954 and regulations issued under such Act), (v) any article the sale of
which is subject to the tax imposed by Section 4181 of the Internal Revenue Code of 1954
(determined without regard to any exemptions from such tax provided by section 4182 or 4221
or any other provision of such Code) and any component of such an article (limited to shot
shells, cartridges, and components of shot shells and cartridges), and (vi) any food, food additive,
drug, cosmetic, or device, as defined in section 201 of the Federal Food, Drug, and Cosmetic
Act, when manufactured, processed, or distributed in commerce for use as a food, food additive,
drug, cosmetic or device" [15 USC 2602(2)(B)].
Even though the definition of chemical substance excludes mixtures, PFAS as a chemical
substance may be present in a mixture. Therefore, this rule requires reporting on each chemical
substance that is a PFAS, including as a component of a mixture. This rule does not require
reporting on components of a mixture that do not fall under the structural definition of PFAS.
2.2 Step II: Do You Qualify for Streamlined Reporting?
If you determined from Step I that you manufacture (including import) a reportable PFAS
for commercial purposes, Figure 2-1 presents a decision logic diagram that may help you
determine whether you are a manufacturer (including importer) who must report with the
Standard Form or if you may qualify for streamlined reporting. The following subsections
explain each question in greater detail. Note that unlike CDR reporting, no reporting exemptions
apply to section 8(a)(7).
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Figure 2-1. Decision Logic Diagram for Evaluating Step II
2.2.1 Did you import an article containing a reportable PFAS?
If you imported an article containing PFAS, you may use a streamlined Article Import
form. This streamlined form does not require all information required for the standard form;
when you select "article import reporting" in the section 8(a)(7) reporting tool, the program will
show only fields required for this streamlined reporting. Only certain fields in Sections A, B, and
C are required for the streamlined article importing. Further, because importers may not know or
be able to ascertain how much PFAS is contained within the articles, the article import form
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allows production volume to reported as the total weight of the imported articles or as the
quantity of articles imported (see Section 4.7.2.2), rather than weight of the PFAS. If you have
any additional information, such as an SDS or information about disposal, report that
information in the Optional Information section of the form (see Section 4.12).
Some sites may both import a PFAS in an article and otherwise manufacture the same
PFAS (i.e., domestically manufacture or import other than in an article). In that case, you may
choose to either report the imported article and otherwise manufactured PFAS separately, using
the streamlined article import form for the imported article and using the standard form for the
otherwise manufactured PFAS, or you may include the information for the imported article
within the standard form, submitting one standard form for all PFAS produced and imported by
the site.
If you are unsure whether you are importing an article, refer to the CDR "Imported
Articles" factsheet at https://www.epa.gov/cheMical-data-reportmg/tsca-cheMical-data-
reportmg-fact-sheet-iMported-articles-2020. The TSCA definition of an article is the same for
both CDR reporting, as referenced in this factsheet, and for PFAS section 8(a)(7) reporting (40
CFR 705.3). However, recall that while importing an article is exempt from CDR, it is not
exempt from section 8(a)(7) reporting. If you import an article containing a chemical substance
that is a PFAS, you may be eligible to use the streamlined Article Import form, but you are not
exempt from reporting. You have until May 8, 2025, to report. However, if you meet the
following two criteria, you have until November 10, 2025, to report: (1) are considered a small
manufacturer pursuant to 40 CFR 704.3 (see Appendix A); and (2) have reporting obligations
under this rule exclusively due to importing articles.
2.2.2 Did you manufacture a reportable PFAS in quantities below 10 kg per year
exclusively for purposes of research and development (R&D)?
Persons who manufacture (including import) PFAS in small quantities solely for research
or analysis for commercial purposes may report using the streamlined small quantity R&D form.
The streamlined small quantity R&D form requires reporting only of the chemical substance
identification information (see Section 4.3), domestic manufacture and imported volumes,
indication of whether the substance was imported but never on site, and an optional additional
information field.
Note that any PFAS manufactured for commercial purposes is reportable under this data
call. "Manufacture for commercial purposes" encompasses any importing, production, or other
manufacturing activities with the purpose of obtaining an immediate or eventual commercial
advantage and includes chemicals "for use by the manufacturer, including use for product
research and development." R&D substances which meet the scope of "manufactured for
commercial purposes" are to be reported under this rule, even if the PFAS itself was not later
commercialized. See Section 2.1.1 for additional guidance on determining if a PFAS was
manufactured for commercial purposes."
Some sites may both manufacture a PFAS in small quantities for R&D and otherwise
manufacture the same PFAS (i.e., domestically manufacture or import). In that case, your site
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does not qualify for use of the streamlined form. The streamlined form is limited to persons
manufacturing (including importing) PFAS solely for research or analysis.
Example 2-1. Example Company G produces Example PFAS G at one site. Example PFAS G
was produced in amounts of 3 kg in 201 1, 7 kg in 2012, and 6 kg in 2013. Example PFAS G
was not produced during any other year since 201 1 and the quantities produced were used
exclusively for research and development.
Because Example PFAS G is used only for research and development, and the volume
manufactured was less than 10 kg each year, Example Company G reports using the streamlined
R&D form for Example PFAS G.
2.3 Step III: What Information Must You Report?
Once you determine from Steps I and II that you are a manufacturer (including importer)
of a reportable PFAS and are required to report, this section will help you determine what
information you must report.
If you are required to report and do not qualify for either streamlined form, you are
required to report all information described in 40 CFR 705. Importers of PFAS-containing
articles and manufacturers (including importers) of small R&D quantities may use streamlined
forms, which include only the data elements that EPA believes will be known to or reasonably
ascertainable to manufacturers in those situations. The online reporting software will guide you
through the data elements required for each form.
Basic company and site identification information, (submitted on Part I of the form) is
required by 40 CFR 705.15(a)(1). Chemical identification and information pertaining to the
manufacture (including import) of chemical substances (described in Part II- Section A) is
required by 40 CFR 705.15(a)(2). Note that the basic company and site information is reported
once per site, while the manufacturing information is reported separately for each reportable
PFAS at the site. Industrial processing and use, and consumer and commercial uses of the
chemical substance (described in Part II - Section B) is required by 40 CFR 705.15(a)(3).
Information about byproducts (described in Part II - Section D) is required by 40 CFR
705.15(a)(3). Information about the environmental and health effects of the PFAS (described in
Part II - Section E) is required by 40 CFR 705.15(f). Information about worker exposure to the
PFAS (described in Part II - Section F) is required by 40 CFR 705.15(g). Information about the
release or disposal of the PFAS (described in Part II - Section G) is required by 40 CFR
705.15(h).
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Example 2-2. Example Company H manufactures 8 kg of Example PFAS H in 2017 for on-site
R&D operations in development of a new cleaning product. The company scales up R&D for
this substance and manufactures 100 kg of Example PFAS H in 2018. The company then
discontinues R&D and does not ultimately commercialize Example PFAS H. Example PFAS H
is not manufactured after 2018.
Example PFAS H is manufactured for commercial purposes because Example Company H
manufactured the chemical with the purpose of obtaining an eventual commercial advantage, so
Example Company H must report the substance, even though it was not ultimately
commercialized. For 2017, the company manufactured < 10 kg of the substance for R&D and
meets the requirements for the R&D form. For 2018, the company manufactured > 10 kg so
exceeds the threshold for the R&D form. The company may take one of two actions:
1) Use the R&D form to report for 2017 and the standard form for 2018
2) Report for both 2017 and 2018 on one standard form, completing all fields on the form
for both years.
Example 2-3. Example Company I begins importing an article containing Example PFAS I in
2017 and continues importing the article through 2022. Example PFAS 1 provides stain
resistance in a finished textile product. Example Company 1 does not produce or import any
other products containing Example PFAS 1.
Because Example PFAS 1 is only imported in an article, Example Company 1 reports for this
chemical using the streamlined article importer form.
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3. When You Must Report
You are required to report information pertaining to each calendar year since January 1,
2011 through December 31, 2022, in which you manufactured a PFAS. The submission period
begins twelve months after the effective date of the section 8(a)(7) final rule and lasts for six
months. Therefore, reporting is due 18 months after the effective date of this final rule: May 8,
2025. Small manufacturers (per 40 CFR 704.3) whose PFAS reporting obligations are
exclusively due to importing articles have an additional six months to report. These small article
importers have 24 months from the effective date of the final rule to report: November 10, 2025.
Your report must be submitted to EPA using the electronic section 8(a)(7) reporting tool
("reporting tool") via EPA's Central Data Exchange (CDX) no later than the close of the
submission period. You should note that registration with CDX is required prior to accessing the
reporting tool to submit your PFAS data call information (40 CFR 705.35). To get you started,
guides are available on EPA's website:
~ CDX Registration Guide, which covers the specifics of CDX registration
(httys://cdx. ena. sov/A bout/User Guide')
If you are required to report, failure to file your report during this period is a violation of
TSCA sections 8(a) and 15 and may subject you to penalties (40 CFR 705.1).
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Instructions for Completing Section 8(a)(7) Reporting
4. Instructions for Completing Section 8(a)(7)
Reporting
This chapter will help you complete section 8(a)(7) reporting. Section 4.1 describes how
to certify your submission. Section 4.2 discusses the reporting standard - the effort required to
comply with the PFAS data call. Sections 4.3 through 4.11.3 provide information to help you
complete each required section of the reporting form.
You are required to use the section 8(a)(7) online reporting tool in CDX to complete and
submit a reporting form for each reportable PFAS. If you are reporting information for more than
one PFAS at your site, you must report information for each reportable PFAS on its own form. If
you are reporting for multiple sites, you must submit separate forms for each site. In most cases,
you will submit exactly one form per chemical at the site. However, in certain cases if you are an
article importer, you may submit multiple forms for the same chemical at one site; see Section
2.2.
The standard reporting form is comprised of a certification statement and three parts, as
follows:
• The certification statement and Part I of the form are completed once per reporting site.
Part I contains company, site, and contact information, some of which is pre-populated
based on the information in your CDX account for the site. Once this section has been
completed for a reporting site, the reporting tool will automatically populate Part I with
this information for any additional forms for the site.
• Part II - Sections A - C are completed for each reportable PFAS at the site and contains
information associated with the identity, manufacture, and properties of the chemical
substance.
• Part II - Section D is completed for the byproducts produced during manufacture of each
PFAS.
• Part II - Section E is completed for each reportable PFAS at the site and contains
information associated with the environmental and health effects of the PFAS.
• Part II - Section F is completed for each reportable PFAS at the site and contains
information associated with workers' exposure to the PFAS.
• Part II - Section G is completed for each reportable PFAS at the site and contains
information associated with the disposal of the PFAS.
• Part II - Section H is an optional free text field that allows submittal of any additional
information.
• Part III is completed for each reportable chemical substance at the site for which
confidentiality claims are made for one or more data elements, when substantiations of
the confidentiality claims are required at the time of data submission.
The streamlined article import and small-quantity R&D forms reduce the number of
fields to be reported. Sections D - G are not required on these forms and the requirements for
Sections A - C are reduced. If any information in the omitted sections is known to you, you may
report that information in the free text field in Section H.
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Note: Items such as the validation page and the SRS search page will appear in separate
windows. As described in the PFAS section 8(a)(7) online reporting guide, ensure that your pop-
up blocker is disabled before you begin to complete PFAS section 8(a)(7) reporting.
4.1 Certification
Your submission(s) must be certified, indicating that your submitted information has
been completed in compliance with the PFAS data call requirements, such as all information
known or reasonably ascertainable is submitted, and that the confidentiality claims made in this
report are true and correct. To certify, the certification statement must be electronically signed
and dated by an authorized official at your company. The authorized official typically is a senior
official with management responsibility for the person (or persons) completing the form(s). You
must include the printed name, title, and email address for the person signing the certification.
See the user guide including CDX Registration for information on how to complete an electronic
signature agreement.
This certification statement applies to all the information supplied on the form(s) for your
site. The certification statements appear when the submission process has been initiated, at which
time the submitter must either certify or cancel the submission process. If you are completing
forms for multiple sites, one submission certification will be created and must be submitted for
each site. Note that knowingly providing false or misleading information or concealing required
information may be punishable by fine or imprisonment or both under TSCA section 16(b)(1).
4.2 Reporting Standard
Submitters are required to exercise certain levels of due diligence in gathering the
information required by the section 8(a)(7) rule. You must report your information to the extent
that the information is known to or reasonably ascertainable by you and your company.
The term "known to or reasonably ascertainable by" is defined in 40 CFR 705.3, meaning
all information in a person's possession or control, plus all information that a reasonable person
similarly situated might be expected to possess, control, or know.
Under TSCA section 8(a), EPA may collect information associated with chemical
substances to the extent that it is known to or reasonably ascertainable by the submitter. This
includes, but is not limited to, information that may be possessed by employees or other agents
of the company reporting under the section 8(a)(7) rule, including persons involved in the
research, development, manufacturing, or marketing of a chemical substance and includes
knowledge gained through discussions, symposia, and technical publications. For purposes of
section 8(a)(7), the known to or reasonably ascertainable by standard applies to all the
information required by the rule.
Examples of types of information that are considered to be in a person's possession or
control, or that a reasonable person similarly situated might be expected to possess, control, or
know include:
• Files maintained by the manufacturer, such as marketing studies, sales reports, or
customer surveys,
• Information contained in standard references, such as a safety data sheet (SDS) or a
supplier notification, and
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• Information from the Chemical Abstracts Service (CAS) and from Dun & Bradstreet
D-U-N-S®.
The hypothetical examples in Table 4-1 illustrate the anticipated application of the
"known to or reasonably ascertainable" reporting standard, in the specific context of the
collection of processing and use data under section 8(a)(7). Because the standard applies on a
case-by case basis, however, these examples cannot substitute for a complete analysis of a
submitter's particular circumstances.
This reporting standard does not confer a testing requirement on manufacturers. But, if
manufacturers have previously tested their products for the presence of PFAS, then that
information may be considered known to or reasonably ascertainable to them and should be
submitted to EPA as appropriate.
Table 4-1. Examples of the Application of the "Known to or Reasonably Ascertainable"
Reporting Standard for Processing and Use Data
Scenarios. Actions, iinri Oiiicoiik-s
Scenario: Example Company J discovers that it has no knowledge of how a particular PFAS (Example PFAS J)
is processed or used by its customers. Example Company J usually maintains marketing data documenting
customers' use of its chemicals, in line with the reasonable business practices typical of comparable
manufacturers, but it irrevocably lost these data for Example PFAS J due to an inadvertent computer
malfunction. Example Company J has many customers, but it expects that it could substantially reconstruct this
missing information by briefly contacting its largest customer and asking that customer what Example PFAS J is
generally used for.
Application of KRA Reporting Standard:
If:
Then:
Example Company J contacts its largest customer and reports on the
basis of the processing and use data that the customer was willing to
provide.
Duties Likely Fulfilled
Example Company J did not endeavor to supplement the information it
already knew.
Duties Not Fulfilled
Scenario: Example Company K has never maintained information on how a particular PFAS (PFAS K) is
processed or used by its customers. However, it is typical for comparable manufacturers to collect such
information as part of their reasonable business practices. Example Company K has many customers, who it
believes process and use the particular PFAS in a similar manner and it expects that it could substantially fill this
data gap by reviewing the public website of its largest customer.
Application of KRA Reporting Standard:
If:
Then:
Example Company K reviews its largest customer's website, and
reports on the basis of the information contained on the website.
Duties Likely Fulfilled
Example Company K did not endeavor to supplement the information
it already knew.
Duties Not Fulfilled
Scenario: Example Company L maintains seasonal marketing data on changes in use patterns for a particular
PFAS (Example PFAS L). Comparable manufacturers typically only maintain such data on an annual basis, in
line with reasonable business practices. Example Company L irrevocably loses its summer marketing data for
Example PFAS L, due to an inadvertent computer malfunction. Example Company L expects that it could
substantially reconstruct the missing summer marketing data by contacting its largest customer and asking the
customer what it used or processed Example PFAS L for in the past summer.
Application of KRA Reporting Standard:
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Scenarios. Actions. :iikI On (comes
If:
Then:
Instead of attempting to reconstruct the summer data by contacting its
largest customer, Example Company L reports on the basis of the
processing and use data that it already knows (regarding the winter,
spring, and fall of the year).
Duties Likely Fulfilled
Example Company L designated the information as "not known or
reasonably ascertainable" simply because one of the seasonal
marketing reports was missing.
Duties Not Fulfilled
Scenario: Example Company M has never maintained information on how a particular PFAS (Example PFAS
M) is processed or used by its customers. However, it is typical for comparable manufacturers to collect such
information as part of their reasonable business practices. Example Company M has one major customer and ten
minor customers.
Application of KRA Reporting Standard:
If:
Then:
Example Company M asks its major customer to supply information
about how Example PFAS M is processed and used, but that customer
is unwilling to supply this information. Example Company M
reasonably expects that the only remaining way to substantially fill this
data gap would be to send a survey to its ten minor customers.
Example Company M reports that the information is "not known or
reasonably ascertainable" to it.
Duties Likely Fulfilled
Example Company M did not endeavor to obtain processing and use
information from its customers and designated the information as "not
known or reasonably ascertainable."
Duties Not Fulfilled
Scenario: Example Company N imports an article with a water repellant "fluoropolymer" surface. However.
Example Company N does not know the chemical identity or molecular structure of the fluoropolymer coating.
Application of KRA Reporting Standard:
If:
Then:
Example Company N contacts their supplier to determine the name,
CASRN, and molecular structure of the fluoropolymer. The supplier
provides this information or a joint submission is initiated.
Duties Likely Fulfilled
Example Company N did not contact their supplier to obtain information
on the fluoropolymer coating.
Duties Not Fulfilled
Scenario: Example Company 0 imports stain-resistant garments. Example Company 0 does not know
specifically what chemical is used to impart stain resistance, but Example Company 0 does know that chemicals
used to impart stain resistance are often fluorinated chemicals and could meet the definition of PFAS.
Application of KRA Reporting Standard:
If:
Then:
Example Company 0 contacts their supplier to determine the name,
CASRN, and molecular structure of the stain-resistant chemical. The
supplier provides this information or a joint submission is initiated.
Duties Likely Fulfilled
Example Company 0 did not contact their supplier to obtain
information on the stain-resistant chemical.
Duties Not Fulfilled
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4.3 Part I - Section A. Parent Company Information4
You must provide information about your parent company. For purposes of section
8(a)(7), a parent company is the highest-level company of your site's ownership hierarchy as of
the start of the submission period according to the definitions of parent company and highest-
level parent company at 40 CFR 711.3. Report your highest-level parent company located in the
United States. Provide the company name, address, and D&B number following the instructions,
including the naming conventions, provided below. Table 4-2 contains examples of how to
identify the parent company in different situations.
Note that although CDR requires you to report your U.S. parent company and your foreign
parent company, section 8(a)(7) reporting requires only the U.S. parent to be reported.
Table 4-2. Applying Highest-level Parent Company Definition in Different Situations
Site Otnicrshi/'
I '..V. Parent ( om/xmy
(1) If the site is entirely owned by a single U.S.
company that is not owned by another company
Then that single company is the U.S. parent company.
(2) If the site is entirely owned by a single U.S.
company that is, itself, owned by another U.S.-based
company (e.g., it is a division or subsidiary of a higher-
level company)
The highest-level domestic company in the ownership
hierarchy is the U.S. parent company.
(3) If the site is owned by more than one company
(e.g., company A owns 40 percent, company B owns
35 percent, and company C owns 25 percent of the
site)
The company with the largest ownership interest in the site is
the parent company. Under this scenario, this would be either
company A itself (if it doesn't have a U.S.-based parent
company), company A's parent, or, if it exists, a single parent
company that owns both company B and company C, in
which case that single parent company would have the largest
ownership interest (e.g., corporation X owns companies B
and C, for a total ownership of 60 percent for the site).
If the parent company is a U.S. company owned by another
U.S. company, then the highest-level domestic company in
the ownership hierarchy is the U.S. parent company.
If the parent company is a foreign company, then the site is its
own U.S. parent company.
(4) If the site is ultimately owned by a 50:50 joint
venture or a cooperative
The joint venture or cooperative is its own U.S. parent
company.
If the site is owned by a U. S. joint venture or cooperative, the
highest level of the joint venture or cooperative is the U. S.
parent company.
(5) If the site is entirely owned by a foreign company
(i.e., without a U.S.-based subsidiary within the site's
ownership hierarchy)
The site is the U.S. parent company.
(6) If the site is a federally owned site
The highest-level federal agency or department is the U.S.
parent company.
(7) If the site is owned by a non-federal public entity
That entity (such as a municipality, State, or tribe) is the U.S.
parent company.
4 See Section 4.4.1 for information concerning CBI claims for Parent Company Information.
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4.3.1 U.S. Parent Company Name(s)
All sites must enter the full name of the U.S. parent company. EPA requires that parent
companies be referenced consistently by the same name so that site-level information can be
aggregated to the associated parent company. This can be challenging because filers within the
same parent company often submit names with small variations (e.g., Exopack vs. Exopack
Holdings Corp). When reporting your parent company name, eliminate all periods, commas, and
all leading, trailing, and duplicate spaces. Replace commonly used acronyms and corporate terms
according to Table 4-3.
Table 4-3. Parent Company Name Standardization
I so 1 his
Nol This
&
AND
CORP
CORPORATION
ASSOC
ASSOCIATION
CO
COMPANY
COS
COMPANIES
DIV
DIVISION
INC
INCORP
INC
INCORP.
INC
INCORPORATED
INC
INCORPERATED
LP
LIMITED PARTNERSHIP
LTD
LIMITED
LLC
LIMITED LIABILITY COMPANY
LLC
LIMITED LIABILITY CO.
PTNR
PARTNERSHIP
USA
U.S.A.
USA
U.S.A
USA
USA
USA
UNITED STATES OF AMERICA
USA
UNITED STATES
4.3.2 Parent Company Dun & Bradstreet D-U-N-S® Number
Enter the 9-digit Dun & Bradstreet D-U-N-S® number (D&B number) associated with
each parent company name. The number may be obtained from the treasurer or financial officer
of the company.
D&B assigns separate numbers to subsidiaries and parent companies; you should make
sure that the number you provide EPA belongs to your U.S. parent company. To verify the
accuracy of your site and parent company D&B number and name, go to
www.dnb.com/product/dlw/form cc4.htm or call 1-800-234-3867. Callers to the toll-free phone
number should understand that the D&B support representatives will need to verify that callers
requesting the D&B number are an agent of the business. D&B recommends knowing basic
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information such as when the business originated, officer names, and the name, address, and
phone number for the site.
For the purpose of responding to the section 8(a)(7) rule, you are not required to obtain a
D&B number for your parent company if none exists. However, if your parent company does not
have a D&B number, you can request one from your local office of D&B if desired. There is no
charge for this service, and you are not required to disclose sensitive financial information to get
a number. For more information on obtaining a D&B number, see www.dnb.com. If you are
already listed with D&B, but do not know your number, you can call 1-800-234-3867 for
assistance.
4.3.3 Parent Company Address
Enter the mailing address of each parent company, including the appropriate county or
parish, using standard addressing techniques as established by the U.S. or international postal
services. Post office box numbers should be accompanied by a street address. If a post office box
is listed, it must be entered after the street address. Standardized conventions for listing a street
address should be used to account for common formatting discrepancies, such as punctuation (by
eliminating all periods, commas, and all leading, trailing, and duplicate spaces), capitalization,
and abbreviations in order to increase the reliability and usability of the data. Replace commonly
used acronyms and street abbreviations according to Table 4-4:
Table 4-4. Parent Company Street Address Standardization
I so 1 his
Nnl This
AVE
AVENUE
AVE
AVE.
BLVD
BOULEVARD
BLVD
BLVD.
DR
DRIVE
DR
DR.
HWY
HIGHWAY
HWY
HWY.
JCT
JUNCTION
JCT
JCT.
LN
LANE
LN
LN.
PL
PLACE
PL
PL.
PO BOX
P.O. BOX
RD
ROAD
RD
RD.
RTE
ROUTE
ST
STREET
ST
ST.
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4.4 Part I - Section B. Site Information
EPA requires the following information to be reported for each site at which a reportable
chemical substance is manufactured: the site name, site D&B number, street address, city, county
(or parish), state, and zip code, and six-digit North American Industry Classification System
(NAICS) code(s) of the site.
4.4.1 Confidentiality of Company, Site, and Technical Contact Information
Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the link between the chemical substance and the company or
site identity reported in Part I or the technical contact identity reported in Part II - Section B.
Checking the CBI box automatically triggers the substantiation questions. See Table 4-13 for
substantiation questions related to these data elements. If you do not check the CBI box for
any information element, then that information is not claimed as CBI and may be made
public without further notice to you. Further, if you fail to substantiate your CBI claims in
accordance with the statute and applicable rules, EPA may make the information available to the
public without further notice to you. For additional information about how to answer
substantiation questions, visit www.ena.gov/tsca-cbi on the EPA website.
You may assert a claim of confidentiality for a site, company, or technical contact
identity to protect the link between that information and the reported chemical substance. Such
claim may only be asserted where the linkage of that information to a reportable PFAS is
confidential and not publicly available. You may claim the connection between chemical
substance and company, site, or technical contact as confidential for some PFAS for which you
are reporting, while not making the claim for others. Any confidentiality claims need to be made
on a chemical-by-chemical basis. For example, if you claimed as confidential the link between
chemical A and your company information and do not claim the link as confidential for chemical
B, EPA may make the link between your company and chemical B public without notice. If the
chemical identity is confidential, your company may instead claim the chemical identity as
confidential to protect the link between the company, site, or technical contact information and
the chemical identity. Ensure you are claiming the correct data elements as CBI to protect
confidential data.
EPA also has observed that submitters sometimes claim only their company identity, but
not their site identity, as confidential. EPA will not impute the existence of a CBI claim for site
identity from a CBI claim for company identity, even if the company name appears within the
site identity information. In other words, if your intent is to claim company name as confidential
you must claim all data elements that reference or allude to company name as CBI. The failure to
do this will likely result in a denial of a CBI claim for company name.
4.4.2 Special Provisions for Certain Sites
For PFAS that are domestically manufactured, the site is the location where the PFAS is
physically manufactured.
For importers, the site where you import a chemical substance is considered the site of
the operating unit within your organization that is directly responsible for importing the
chemical substance and that controls the import transaction. For section 8(a)(7), all importers
must provide a U.S. address for the controlling site; this site may be your company's
headquarters in the United States. If there is no such operating unit or headquarters in the United
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States, the site address for the importer is the U.S. address of an agent acting on the importer's
behalf who is authorized to accept service of process for the importer (40 CFR 711.3). In the
event that more than one person may meet the definition of "importer" (40 CFR 704.3), only one
person should report. See 40 CFR 711.22(b).
Example 4-1. The headquarters of your company is located in New Town. Your
company owns a plant site located in Old Town, which is in a different state. A
headquarters employee purchases and arranges to have 50,000 lb of Example PFAS
P imported from Japan to the Old Town plant site. The headquarters site in New
Town controls the import transaction and is the site reported.
Example 4-2. The headquarters of your company is located in New Town. Your
company owns three manufacturing sites, Sites 1, 2, and 3, all located in different
states. An employee based at headquarters purchases and arranges to have 50,000 lb
of Example PFAS R imported from Japan. The chemical is distributed as follows:
2,000 lb is delivered to Site 1; 18,000 lb is delivered to Site 2; and 30,000 lb is
delivered to Site 3. The headquarters in New Town controls the import transaction
for all three sites, and therefore is responsible for reporting all 50,000 lb of Example
PFAS R. The site reported is New Town.
4.4.3 Site Name
The section 8(a)(7) reporting tool will automatically populate the site name from the site
used for CDX registration. If you need to change this information, you will need to make
corrections or create a new site in CDX and create a new form for the corrected or new site.
4.4.4 Site Dun & Bradstreet Number D-U-N-S®
D&B assigns separate numbers to subsidiaries and parent companies; make sure that the
number you provide EPA belongs to the individual site for which you are reporting. You are not
required to obtain a D&B number for the site if none exists. However, if the site does not have a
D&B number, you can request one from your local office of D&B if desired. Please refer to
Section 4.3.2 for information on obtaining a D&B number.
4.4.5 Site Street Address
The reporting tool will automatically populate the site address from the site used for CDX
registration. If you need to change this information, you will need to make corrections or create a
new site in CDX and create a new form for the corrected or new site.
4.4.6 NAICS code
Enter the appropriate six-digit North American Industry Classification System (NAICS)
code or choose the correct code for each site reported. The NAICS code is the standard used by
Federal statistical agencies in classifying business establishments for the purpose of collecting,
analyzing, and publishing statistical data related to the U.S. business economy. Information
about NAICS codes can be obtained from the U.S. Census website at
www. census, gov/eos/www/naics/.
In some circumstances it may be challenging to identify a single NAICS code for the site.
In those circumstances, you may report up to three NAICS codes to more appropriately describe
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your site. For example, headquarters sites that import for other sites may have difficulty
identifying a single NAICS code.
4.4.7 Technical Contact Information
This section requests information about the person whom EPA may contact for
clarification of the information in your submission. The technical contact should be a person who
can answer questions about the reported PFAS. Typically, a person located at the manufacturing
site is best able to answer such questions. However, companies may use their discretion in
selecting a technical contact or multiple technical contacts, as provided by the section 8(a)(7)
online reporting tool. In selecting the technical contact, submitters should consider that EPA may
have follow-up questions about a PFAS data submission years after the submission date. The
technical contact need not be the person who signed the certification statement.
4.4.7.1 Technical Contact Name and Company Name
Enter the name of the person whom EPA may contact for clarification of information
submitted. Enter the name of the company employing the technical contact. You may use the
same technical contact for all chemicals submitted or you may use a different technical contact
for each chemical.
4.4.7.2 Technical Contact Telephone Number and Email Address
Enter the technical contact's telephone number, including the area code, and the
contact's email address. If the technical contact is outside of the United States, include the
country code.
4.5 Part II - Section A. Chemical Substance Identification
You must use the Agency's Substance Registry Services (SRS) to report the chemical
substance identification information consisting of the currently correct Chemical Abstracts (CA)
Index Name and the correct corresponding Chemical Abstracts Service (CAS) Registry Number
(CASRN), as described in Sections 4.5.4 and 4.5.6. The SRS is EPA's central system for
information about chemical substances that are tracked or regulated by EPA or other sources. It
is the authoritative resource for basic information about chemicals, biological organisms, and
other chemical substances of interest to EPA and its state and tribal partners.
The correct CA Index Name and CASRN must be reported separately for each reportable
PFAS at your site. If you wish to report a PFAS listed on the confidential portion of the TSCA
Inventory, you will need to report the PFAS using a TSCA Accession Number (the generic
chemical name corresponding to the Accession Number will automatically be incorporated into
your form). See Section 4.5.1 for details on how to report confidential chemical substances. If
you have a low-volume exemption (LVE) case number for the chemical substance, that number
may be used if a CASRN or Accession Number is not known to or reasonably ascertainable by
you. If you know the CASRN or Accession Number for the chemical substance, report that
number instead of an LVE case number.
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You will be able to connect directly to the SRS database from the reporting tool to report
the correct CA Index Names and CASRNs for all of
your non-confidential chemical substances on the
TSCA Inventory. TSCA Accession Numbers and
generic chemical names will be listed instead of CA
Index Names and CASRNs for chemical substances
on the confidential portion of the TSCA Inventory.
The use of the SRS to obtain the identities for all
reportable chemical substances is a convenient way to
meet the chemical nomenclature requirement and will
help to prevent errors in the reporting of chemical
identification information for section 8(a)(7).
If certain information in section A is not known to or reasonably ascertainable by you
(including your company), you may enter or select "NKRA" for "not known or reasonably
ascertainable" in the box corresponding to that data element. You may only report NKRA in this
section for the chemical ID, molecular structure, or physical state of the PFAS. You may not
report NKRA for the specific or generic chemical name or trade or common name.
4.5.1 Confidentiality of Chemical Substance Information
If you wish to report a chemical substance listed on the confidential portion of the TSCA
Inventory, you will need to report the chemical substance using a TSCA Accession Number.
Accession numbers are only assigned to inventory chemicals and not to other chemicals
authorized to be in US commerce, like LVEs. The generic chemical name corresponding to the
TSCA Accession Number will also be automatically incorporated into your report.
The identities of chemical substances listed on the public version of the TSCA Inventory
are already publicly known. Therefore, claims for confidential treatment of the identity of a
chemical substance which is listed on the public section of the TSCA Inventory are not valid and
will not be allowed (40 CFR 715.30(a)(2)(i)). This includes claims for confidential treatment of
the chemical name, ID, and molecular structure.
You may claim as confidential the identity (chemical name, CAS registry number, and
molecular structure) of a chemical substance that is already listed as confidential on the TSCA
Inventory (40 CFR 715.30(c)). To do so, you must check the appropriate CBI box and submit
detailed written answers to the substantiation questions listed in Table 4-5. The confidentiality
claim is only applicable to the information as it is listed on the confidential portion of the TSCA
Inventory; the corresponding accession number and generic chemical name listed on the public
portion of the TSCA Inventory is already public and cannot be claimed as confidential. You may
also claim as confidential the identity of a chemical substance that is not listed on the TSCA
Inventory, e.g., LVE substances. CBI claims for trade names or common names are allowed but
may not be valid if the trade name or common name is public.
CBI claims for physical state(s) of the chemical are allowed regardless of the
confidentiality status of the chemical. Substantiation questions to be answered for physical state
CBI claims are the same questions to be answered for confidentiality of manufacturing
information listed in Table 4-13 in Section 4.7.1.2.
CBI claims for chemical identity will be accepted only when accompanied by a separate
written substantiation for the chemical substances claimed as CBI, except for chemicals reported
on article importer forms. Article importers are not required to assert CBI claims for chemical
Duplicative Reporting
The information in this section
regarding physical form, described in
Section 4.5.12, may have been
previously reported under CDR. See
Section 1.2 for instructions on how to
inform EPA that this information has
already been reported.
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identity. Additionally, PFAS manufacturers (except article importers) who do not know nor can
reasonably ascertain one of the following chemical-specific identifiers, are not required to assert
and substantiate a CBI claim for the PFAS identity: CASRN, TSCA Accession number, or LVE
number. Clicking the checkbox next to "CBI for Chemical Identification" triggers the
substantiation questions to appear. If you fail to click the checkbox next to "CBI for Chemical
Identification" or fail to substantiate the claim for confidentiality of the chemical identity in
accordance with applicable rules, EPA may make the information available to the public. Note
that checking this box does not protect the link between your company and the chemical
substance; it only asserts a CBI claim for the specific identity of the chemical substance as listed
on the confidential portion of the TSCA Inventory.
Following the conclusion of the reporting period for this rule, EPA intends to compile a
list of reported confidential Inventory substances for which either no chemical identity CBI
claim was asserted or for which the claim was denied. Similar to past compilations, EPA will
publish this list of candidates for disclosure on the public version of the Inventory, by TSCA
accession number, on the EPA website for several months in advance of any update to the
Inventory itself. Interested parties will have an opportunity to review the list for possible errors
and contact EPA with any questions or concerns about specific candidates. In some cases, there
may be assertions by a company that a mistake has been made (e.g., an incorrect chemical was
reported), in which case EPA will undertake appropriate factual investigation as necessary to
confirm whether there were any errors that would cause EPA to reconsider whether the chemical
is no longer entitled to confidential Inventory protection. This investigation would take place
prior to the point that the specific chemical identity would be disclosed on the public Inventory.
The requirements to report by Accession number, assert a CBI claim, and to substantiate
such claims to maintain confidential Inventory treatment do not apply to submissions
concerning imported articles. Such reporters may assert a CBI claim for trade name (if not
already public) or other non-public identifiers, but need not report by Accession number or assert
a CBI claim to maintain the confidential status of any chemical(s) associated with the trade name
or generic chemical name. EPA will not determine the CBI status of a chemical identity based on
imported article reporting.
Additional information about making and substantiating confidentiality claims is
available on EPA's website, at www.epa.gov/tsca-cbi.
Table 4-5. Substantiation Questions to be Answered when Asserting Chemical Identity CBI
Claims (40 CFR 705.30(e))
No.
Question
1.
Please specifically explain what harm to the competitive position of your business would be likely to
result from the release of the information claimed as confidential. How would that harm be substantial?
Why is the substantial harm to your competitive position likely (i.e., probable) to be caused by release
of the information rather than just possible? If you claimed multiple types of information to be
confidential (e.g., site information, exposure information, environmental release information, etc.),
explain how disclosure of each type of information would be likely to cause substantial harm to the
competitive position of your business.
2.
Has your business taken precautions to protect the confidentiality of the disclosed information? If yes,
please explain and identify the specific measures, including but not limited to internal controls, that
your business has taken to protect the information claimed as confidential. If the same or similar
information was previously reported to EPA as non-confidential (such as in an earlier version of this
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No.
Question
submission), please explain the circumstances of that prior submission and reasons for believing the
information is nonetheless still confidential.
3.
(i) Is any of the information claimed as confidential required to be publicly disclosed under any other
Federal law? If yes, please explain.
(ii) Does any of the information claimed as confidential otherwise appear in any public documents,
including (but not limited to) safety data sheets; advertising or promotional material; professional or
trade publications; state, local, or Federal agency files; or any other media or publications available to
the general public? If yes, please explain why the information should be treated as confidential.
4.
Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If
yes, please indicate the number of years (between 1-10 years) or the specific date after which the claim
is withdrawn.
5.
Has EPA, another federal agency, or court made any confidentiality determination regarding
information associated with this chemical substance? If yes, please provide the circumstances
associated with the prior determination, whether the information was found to be entitled to
confidential treatment, the entity that made the decision, and the date of the determination.
6.
Is this chemical substance publicly known (including by your competitors) to be in U.S. commerce? If
yes, please explain why the specific chemical identity should still be afforded confidential status (e.g.,
the chemical substance is publicly known only as being distributed in commerce for research and
development purposes, but no other information about the current commercial distribution of the
chemical substance in the United States is publicly available). If no, please complete the certification
statement:
I certify that on the date referenced, I searched the internet for the chemical substance identity (i.e., by
both chemical substance name and CASRN). I did not find a reference to this chemical substance that
would indicate that the chemical is being manufactured or imported by anyone for a commercial
purpose in the United States, [provide date].
7.
Does this particular chemical substance leave the site of manufacture (including import) in any form,
e.g., as a product, effluent, emission? If yes, please explain what measures have been taken to guard
against the discovery of its identity.
8.
If the chemical substance leaves the site in a form that is available to the public or your competitors,
can the chemical identity be readily discovered by analysis of the substance (e.g., product, effluent,
emission), in light of existing technologies and any costs, difficulties, or limitations associated with
such technologies? Please explain why or why not.
9.
Would disclosure of the specific chemical name release confidential process information? If yes, please
explain.
4.5.2 Are you manufacturing a mixture or a chemical substance of unknown or variable
composition or a polymer?
You should report for PFAS that are chemical substances as defined by TSCA. Note that
a mixture is not considered a chemical substance. Mixture means any combination of two or
more chemical substances if the combination does not occur in nature and is not, in whole or in
part, the result of a chemical reaction; except that such term does include any combination
which occurs, in whole or in part, as a result of a chemical reaction if none of the chemical
substances comprising the combination is a new chemical substance and if the combination
could have been manufacturedfor commercial purposes without a chemical reaction at the time
the chemical substances comprising the combination were combined. (TSCA 3(10))
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If you manufacture a mixture, you must determine whether you manufactured any
components of the mixture and report for each individual PFAS component of the mixture using
the information known to or reasonably ascertainable by you.
If you manufacture a PFAS as a result of a chemical reaction, you may manufacture a
chemical substance of unknown or variable composition (UVCB). A UVCB substance is an
indefinite combination of chemicals, that does not meet the statutory definition of "mixture" at
TSCA section 3(10), whose number and individual identities and/or composition are not
precisely or completely known. A UVCB combination of chemicals is subject to reporting under
section 8(a)(7) and is considered a single chemical substance.
• If you imported a mixture, you will need to report the individual PFAS components of the
mixture.
• If you domestically manufactured a mixture, you will need to determine whether any
PFAS chemical substances were formed from a chemical reaction that occurred as part of
manufacturing the mixture. If a chemical reaction has occurred, a PFAS formed from the
chemical reaction may be a chemical substance subject to reporting. If a chemical
reaction has not occurred, you have not manufactured any reportable chemical substances
in the production of the mixture. In such a case, the production of the mixture has not
triggered any requirement to report under the PFAS data call.
• Domestic manufacturers and importers should also consider whether the combination of
the chemicals they have domestically manufactured or imported (respectively) should be
chemically identified for TSCA purposes as a single UVCB chemical substance instead
of a mixture.
EPA has developed two Inventory nomenclature guidance documents related to the
mixture-UVCB determination:
• Toxic Substances Control Act Inventory Representation for Chemical Substances of
Unknown or Variable Composition, Complex Reaction Products and Biological
Materials: UVCB Substances. Available online at:
www.epa.gov/sites/production/files/2015-Q5/documents/uvcb.pdf:;
• Toxic Substances Control Act Inventory Representation for Combinations of Two or
More Substances: Complex Reaction Products. Available online at:
www.epa.gov/sites/production/files/2015-Q5/documents/rxnprods.pdf
Polymers are a specific type of chemical that may have unknown or variable
composition. Polymers often consist of a mixture of molecules with varying degree of
polymerization, so that individual polymer molecules have different chain lengths and/or
branching and therefore have different molecular structures. For copolymers (polymers formed
from multiple monomer species), there may also be variance in the ratio and connectivity of the
monomer subunits. In that case, report the identity of each monomer and average ratios for each
copolymer. A polymer should be reported as a single PFAS. Provide any known information
about the structure and variability of the structure in the chemical description and molecular
structure data fields.
4.5.3 How to Report when Chemical Identity is Unknown
In some cases, you may know that you are manufacturing (including importing) a PFAS
but not know the identity of the PFAS. For instance, this can occur if you import a PFAS and
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your supplier will not disclose the identity of the chemical, or if you do not know the identity of
reaction products or byproducts.
You must use all information known to or reasonably ascertainable by you to determine if
you are manufacturing a PFAS. For example, if you import a type of product known to
sometimes include PFAS, this could include reviewing purchase records, SDS or product data
sheets, or contacting your supplier. Additionally, you may consider the generic or trade name
provided by your supplier, published studies, results of testing or other analysis, or any other
information known to or reasonably ascertainable by you, in determining whether you have a
reportable PFAS. If you determine that the chemical substance is unlikely to be a PFAS as
defined by section 8(a)(7), you are not required to report.
If you determine that the chemical substance likely meets the definition of PFAS, you
must report the chemical even if you do not know its specific chemical identity. You must report
a chemical ID number (i.e., CASRN, TSCA Accession number, or LVE number) if one is known
to or reasonably ascertainable by you; note that CAS numbers, Accession numbers, and LVE
numbers may be assigned to chemicals with unknown or variable composition. Additionally, if
you know or can reasonably ascertain another entity who would be able to provide the chemical
identity (e.g., a co-manufacturer or a foreign supplier), you must initiate a joint submission with
that entity. See Section 4.13 for more details on joint submissions.
For the chemical name, report the CA Index name if known to or reasonably
ascertainable by you. If the CA index name is not known to or reasonably ascertainable by you,
provide the generic chemical name or description of the PFAS instead. If the PFAS is not on the
public portion of the TSCA Inventory, you may claim the name as CBI. Substantiation is
required unless the PFAS has not been introduced into commerce (TSCA section 14(c)(2)(G)).
Provide the trade name or common name as appropriate. If the PFAS does not have a
trade name or common name, report "NA." For the molecular structure, provide a correct
representative or partial chemical structure diagram, as complete as can be known, if one can be
reasonably ascertained. Further details on what to include in the structure diagram are provided
in Section 4.5.9.
4.5.4 Chemical Substance Identifying Number
Every chemical substance reported in accordance with the section 8(a)(7) rule must be
accompanied by its correct CASRN, corresponding to the chemical substance's specific chemical
name as described in Section 4.5.6. (40 CFR 705.15(b)(l)(i)). You may enter either a CASRN or
the specific name of the chemical substance to select the appropriate CASRN/Chemical
Abstracts (CA) Index Name combination from the SRS database.
Report the correct CASRN for your chemical substance if it is listed on the non-
confidential portion of the TSCA Inventory. In the case of a chemical substance listed on the
confidential portion of the TSCA Inventory, report the TSCA Accession Number as the chemical
identifying number. Note that the SRS contains a cross-reference list that displays the Accession
Number, generic chemical name, and PMN case number (or for an initial TSCA Inventory
substance, the TSCA Inventory reporting form number) for any chemical substance listed on the
confidential portion of the TSCA Inventory.
PFAS are often confidential and therefore are usually assigned Accession numbers. You
can look up a chemical's Accession number in SRS if you have the PMN case number. You may
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also submit an inventory inquiry via the CDX TSCA communications module if your rights to
access this information have been validated.
If the PFAS is not listed on the TSCA Inventory, it may have a low-volume exemption
(LVE) case number. Report the LVE case number as the chemical identification number. If you
also know the CASRN for the PFAS, report the CASRN instead. If none of these types of
identification numbers have been assigned to the chemical, or if you do not know enough
information about the chemical identity to determine one of those identification numbers, report
NKRA.
4.5.5 ID Code
The code corresponding to the type of identifying number you selected in the SRS will be
entered. See codes in Table 4-6.
Table 4-6. ID Code for Chemical Identifying Numbers
II (lie Number You ;uv Reporting is ;i(n)
This ( ode \\ ill ho link-mi
TSCA Accession Number
A
CAS Registry Number
C
Low-volume exemption (LVE) Case Number
L
4.5.6 Chemical Name
Report your chemical substance using the CA Index Name currently used to list the
chemical substance on the TSCA Inventory. You can identify the CA Index name by searching
SRS using a CASRN, the specific name of the chemical substance, or related synonyms. In the
event that a synonym is used for multiple chemical substances, you should take care to select the
correct substance. In describing the chemical substance, the EPA requires Chemical Abstracts
Service (CAS) chemical nomenclature be used for identification purposes when it is available.
In cases where a chemical substance is listed on the confidential portion of the TSCA
Inventory, the generic chemical name will automatically be incorporated into your report when
you select the Accession Number.
In order to continue to protect the confidentiality of the underlying specific chemical
identification information (i.e., the CASRN and specific chemical name as listed on the
confidential portion of the Inventory), you must claim the chemical identity as confidential and
complete the upfront substantiation. The Accession Number and generic chemical name will
remain non-confidential. Failure to identify the chemical identity as confidential waives any
confidentiality claim for the chemical identity and will likely result in the transfer of the
chemical substance from the confidential portion of the TSCA Inventory to the public portion of
the TSCA Inventory.
If any entity reports a PFAS by specific chemical identity and does not claim the specific
chemical identity as CBI, EPA expects to determine that the specific chemical identity is no
longer entitled to confidential treatment. However, EPA would not make this determination
where an entity attests that it does not have knowledge of the specific chemical identity. Instead,
an entity that does not have knowledge of a specific chemical identity must initiate a joint
submission with its supplier or other manufacturer if that entity is known. In these cases, the
secondary submitter would be responsible for providing the specific chemical identity and for
asserting and substantiating any CBI claims concerning the specific chemical identity. See, e.g.,
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40 CFR 711.15(b)(3); 711.30(c). Importers of articles using the streamlined article import form
are not required to assert or substantiate CBI claims for chemical identity. Therefore, joint
submissions are not required or enabled for article importers.
4.5.7 Trade Name or Common Name
Report the common or trade name(s) by which the product is sold or commonly known.
4.5.8 Generic Chemical Name or Description
If you do not know the specific identity of the chemical substance, provide a description
of the substance. If you claimed CBI for the chemical name, you must provide a generic
chemical name. If the chemical is on the confidential portion of the TSCA Inventory, the generic
chemical name will be pre-populated from EPA's Substance Registry Service (SRS).
Generic chemical names must be sufficiently detailed to identify the reported chemical as
a PFAS. Specifically, any generic chemical name reported for a PFAS that does not contain
"fluor" in the name would be rejected by EPA as insufficient under TSCA section 14(c)(1)(C).
Additionally, any previously existing generic chemical names from earlier TSCA section 5
submissions for PFAS without "fluor" are insufficient. Further, even if a generic chemical name
reported under the TSCA 8(a)(7) rule lacks the structural unit "fluor," the Agency will identify
the chemical substance as a PFAS.
4.5.9 Molecular Structure
Upload as an attachment a representative molecular structure. This is not required if your
chemical is listed as a class I substance on the TSCA inventory. If the chemical has a single
defined structure, provide a complete, correct chemical structure diagram. The diagram should
clearly indicate the identity of the atoms and the nature of bonds joining the atoms. Any ionic
charges or stereochemistry should be shown clearly. All known stereochemical details should be
provided. Carbon atoms in ring systems and their attached hydrogen atoms need not be explicitly
shown. Where applicable, specify the proportions of isomers or tautomeric forms, degree of
neutralization, etc.
For a substance with unknown or variable composition, provide a correct representative
or partial chemical structure diagram, as complete as can be known, if one can be reasonably
ascertained. The diagram should indicate the characteristic structure or variable compositional
elements of the substance. For PFAS described as reaction products, as much specific detail as
possible should be provided.
For polymers, provide a simple, representative structural diagram that illustrates what
you know or can reasonably ascertain concerning the key structural features of the polymer
molecules. For example, you could identify the linkages formed during polymerization, the
functional groups present, the range and typical values for the number of repeating structural
units, and the relative molar ratios of the precursors. Indicate if the repeating substructures are
arranged in a nonrandom order such as in graft or block arrangements. For example:
H0-C(=0)-R-0-(C(=0)-R'-C-0-R-0)„-H
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Further instructions on uploading a molecular structure are provided in the section 8(a)(7)
Online Reporting Guidance.
4.5.10 Additional Information on Chemical Identity
In this free text field, provide any additional information known to or reasonably
ascertainable by you regarding the identity, structure, or composition of the PFAS. This may
include, but is not limited to, additional information on the composition of a UVCB chemical or
descriptions of a polymer. Report any additional information that was known to or reasonably
ascertainable by you at the time of the substance's manufacture. If no additional information is
known to or reasonably ascertainable by you, leave this text field blank.
4.5.11 Special Provisions for Joint Submitters of Unknown Chemical Substances
You may report an alternate chemical name, and a trade name, in those instances where
your supplier will not disclose to you the specific chemical name of an imported PFAS because
the information is claimed confidential. In these cases, you and the supplier may report the
information required in a joint submission, which is further discussed in Section 4.13 of this
chapter. If you, as the importer, cannot provide the chemical name, supply a trade name or other
designation to identify the proprietary chemical substance and provide the supplier's (secondary
submitter's) company information. Complete as much of the section 8(a)(7) reporting as is
known to or reasonably ascertainable by you. In addition, you must use the reporting tool to ask
the supplier (secondary submitter) of the confidential chemical substance to directly provide
EPA with the correct chemical identity (as described in Section 4.5.2), in a joint submission with
you. Note that if you actually know or can reasonably ascertain the specific chemical identity of
the chemical, you must provide that information regardless of your supplier's confidentiality
claims, rather than using a joint submission.
Your request to the supplier must include instructions for submitting chemical identity
information electronically, using the reporting tool via CDX (see 40 CFR 711.35), and for
clearly referencing your submission. Contact information for the supplier, a trade name or other
designation for the chemical substance or mixture, and a copy of the request to the supplier must
be included with your submission for the chemical substance. If your connection to your
supplier's name and other contact information, including the trade name, is confidential, you
must indicate so by checking the CBI box. Failing to check the CBI box may result in EPA
making the information publicly available without further notice to you, the submitter.
Substantiation of this confidentiality claim is not required at the time of submission.
If the secondary submitter does not know the chemical components of a mixture supplied
to you, they may ask their supplier to complete the form as a tertiary submitter. When the
secondary (or tertiary, as appropriate) submitter responds to the primary submitter's request, the
secondary submitter would use the reporting software to identify the chemical substance in
question.
If this information is considered confidential, the secondary (or tertiary, as appropriate)
submitter must indicate so by checking the CBI box and, in the case of the chemical identity as
listed on the confidential portion of the TSCA Inventory, completing the required substantiation
questions (as listed in section 4.5.1 of this document). The chemical-specific function cannot be
claimed as confidential (see section 4.8 of this document for more information). Failing to check
the CBI box may result in EPA making the information publicly available without further notice
to the submitter.
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These special provisions only apply in cases where the supplier will not reveal the
pertinent chemical identity to you because it is claimed confidential. In the event that you
actually know the chemical identity of a chemical substance subject to section 8(a)(7) reporting,
you must provide that information irrespective of a supplier's confidentiality claims.
EPA will only accept joint submissions that are submitted electronically using the
reporting tool via CDX (see 40 CFR 711.35) and that clearly reference the specific section
8(a)(7) submission to which they refer. See Section 4.13 in this chapter for more information on
preparing joint submissions.
In the event that the supplier is unknown or no longer exists (e.g., supplier has gone out
of business without a successor entity), provide as much identifying detail as is known to you
and report NKRA for the secondary submitter. In this case a joint submission will not be
required.
4.5.12 Physical Form
Report all physical forms of the PFAS at the time it is reacted or as it leaves your site (40
CFR 711.15(b)(2)). For each PFAS at each site, the submitter must report as many physical
forms as applicable from the following six physical forms:
• Dry powder
• Pellets or large crystals
• Water- or solvent-wet solid
• Other solid
• Gas or vapor
• Liquid
4.6 Part II - Section B. The categories of use of each such
substance or mixture
The processing or use information should be reported to the extent that it is known to or
reasonably ascertainable by you (40 CFR 711.15). See Section 4.2 for a discussion of this
reporting standard and examples of information that may or may not be known to or reasonably
ascertainable by you.
If any information is not known or reasonably ascertainable by you (including your
company), enter or select "NKRA" for "not known or reasonably ascertainable" in the box
corresponding to that data element. Keep in mind that you cannot claim an "NKRA" designation
as confidential.
4.6.1 Confidentiality of Processing and Use Information
Most data elements in Section B may not be claimed as confidential. You may not claim
the following data elements as confidential:
• Certain industrial processing and use data elements. These data elements are a general
description of how the chemical is used or processed and cannot be claimed as
confidential:
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o type of process or use
o industrial sector
o function code
• Certain Consumer and Commercial use data elements. These data elements are a general
description of how the chemical is used and cannot be claimed as confidential:
o product category
o function of the chemical in the consumer or commercial product
o whether the chemical is used in commercial or consumer products
o whether the chemical predictably is used in children's products
In this section, you may only assert a claim of confidentiality for the maximum
concentration of the chemical in any product. Checking the CBI box associated with this data
element automatically triggers substantiation questions. If you do not check the CBI box for
any information element, then that information is not claimed as CBI and may be made
public without further notice to you. See Table 4-13 for substantiation questions to be
answered when asserting CBI claims for processing and use information.
4.6.2 Industrial Processing and Use
For purposes of section 8(a)(7) reporting, an industrial use means use at a site at which
one or more chemical substances or mixtures are manufactured (including imported) or
processed (40 CFR 705.3).
For each PFAS manufactured (including imported), report up to ten unique combinations
of the following data elements: the Type of Process or Use Operation (TPU) (described in
Section 4.6.2.1), the Industrial Sector (IS) (described in Section 4.6.2.2), and the Function
Category (FC) (described in Section 4.6.2.3) (40 CFR 705.15(c)(4)). A combination of these
three data elements defines a potential exposure scenario for risk-screening and priority-setting
purposes. If more than ten unique combinations apply to a chemical substance, you need only
report the ten combinations for the chemical substance that cumulatively represent the largest
percentage of production volume, measured by weight. The reporting tool will allow you to enter
more than ten combinations if you choose to do so.
For each of these unique combinations, you are also required to report the percentage of
production volume in Section C (described in Section 4.7.2.5), and information about worker
exposure in Section F (described in Section 4.10.5) (40 CFR 705.15(g)). When you reach these
sections, the reporting tool will populate the TPU, IS, and FC codes reported in this section.
You are required to report information that is known to or reasonably ascertainable by
you concerning the industrial uses of the PFAS manufactured (including imported) at sites you
control and at sites controlled by people to whom you have either directly or indirectly
(including through a broker/distributor, from a customer, etc.) distributed the reportable chemical
substance (40 CFR 705.15(c)(1)).
4.6.2.1 Type of Process or Use Operation
To the extent that it is known to or reasonably ascertainable by you, report the code
which corresponds to the appropriate Type of Processing or Use Operation (TPU) for the
particular combination of IS and FC codes. Table 4-7 shows the codes and TPUs. Note that if a
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chemical substance is fully reacted (i.e., reporting "PC" for the processing code), then the
chemical substance is wholly consumed and further processing and use information for that
chemical substance will not exist. In such a situation, there is no further downstream processing
and use information to be reported for that particular type of processing or use operation under
40 CFR 705.15(c)(1). A processing or use code may be reported more than once if more than one
IS and/or FC code applies to the same processing or use operation. Definitions for each code are
provided in Appendix D (), which may assist you in determining which code to report.
Table 4-7. Codes for Reporting Types of Industrial Processing or Use Operations
Dosiuiiiilion
Opci'iilion
PC
Processing as a reactant.
PF
Processing—incorporation into formulation, mixture, or reaction product.
PA
Processing—incorporation into article.
PK
Processing—repackaging.
U
Use—non-incorporative activities.
4.6.2.2 Industrial Sectors
Report the code that corresponds to the appropriate Industrial Sector (IS) for all sites that
receive a reportable PFAS from you either directly or indirectly (including through a
broker/distributor, from a customer of yours, etc.) and that process and use the PFAS to the
extent that this information is known to or reasonably ascertainable by you (40 CFR
711.15(c)(2)). Table 4-8 shows the codes and sectors. Because an industrial sector may apply to
more than one processing and use scenario for a chemical substance, the same IS code may be
reported with different combinations of FC and TPU codes. A list identifying the correspondence
between NAICS codes and IS codes is provided in Appendix D (Table D-2). Additional, more
detailed information can be found on the CDR website at www,epa.sov/cdr. (The IS codes used
for PFAS section 8(a)(7) reporting are the same as CDR IS codes).
When you chose the IS "Other," you also need to provide a written description of the use
of the chemical substance. The written description should be used to provide a description at a
comparable level of specificity as found with the current codes. It should not be used to add
additional, more specific detail. Your description may include the NAICS code. If you select the
IS "Other", a text box will appear for you to enter the description.
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Table 4-8. Codes for Reporting Industrial Sectors
('ode
Sector description
IS1
Agriculture, forestry, fishing, and hunting.
IS2
Oil and gas drilling, extraction, and support activities.
IS3
Mining (except oil and gas) and support activities.
IS4
Utilities.
IS5
Construction.
IS6
Food, beverage, and tobacco product manufacturing.
IS7
Textiles, apparel, and leather manufacturing.
IS8
Wood product manufacturing.
IS9
Paper manufacturing.
IS 10
Printing and related support activities.
IS11
Petroleum refineries.
IS 12
Asphalt paving, roofing, and coating materials manufacturing.
IS13
Petroleum lubricating oil and grease manufacturing.
IS 14
All other petroleum and coal products manufacturing.
IS15
Petrochemical manufacturing.
IS 16
Industrial gas manufacturing.
IS 17
Synthetic dye and pigment manufacturing.
IS18
Carbon black manufacturing.
IS19
All other basic inorganic chemical manufacturing.
IS20
Cyclic crude and intermediate manufacturing.
IS21
All other basic organic chemical manufacturing.
IS22
Plastics material and resin manufacturing.
IS23
Synthetic rubber manufacturing.
IS24
Organic fiber manufacturing.
IS25
Pesticide, fertilizer, and other agricultural chemical manufacturing.
IS26
Pharmaceutical and medicine manufacturing.
IS27
Paint and coating manufacturing.
IS28
Adhesive manufacturing.
IS29
Soap, cleaning compound, and toilet preparation manufacturing.
IS30
Printing ink manufacturing.
IS31
Explosives manufacturing.
IS32
Custom compounding of purchased resins.
IS33
Photographic film, paper, plate, and chemical manufacturing.
IS34
All other chemical product and preparation manufacturing.
IS35
Plastics product manufacturing.
IS36
Rubber product manufacturing.
IS37
Non-metallic mineral product manufacturing (includes cement, clay, concrete, glass, gypsum,
lime, and other non-metallic mineral product manufacturing)
IS38
Primary metal manufacturing.
IS39
Fabricated metal product manufacturing.
IS40
Machinery manufacturing.
IS41
Computer and electronic product manufacturing.
IS42
Electrical equipment, appliance, and component manufacturing.
IS43
Transportation equipment manufacturing.
IS44
Furniture and related product manufacturing.
IS45
Miscellaneous manufacturing.
IS46
Wholesale and retail trade.
IS47
Services.
IS48
Other (requires additional information).
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4.6.2.3 Function Category
Report the code that corresponds to the appropriate Industrial Function Category (FC) for
each particular combination of TPU and IS that you report (40 CFR 711.15(c)(3)). You must use
the codes in Table 4-9 for reporting under this data call. These codes, based on Organisation for
Economic Cooperation and Development (OECD) standards, were required for reporting of
chemical substances designated by EPA as a high priority for risk evaluation for 2020 CDR
reporting and were optional for the 2020 CDR for other chemical substances; if you reported to
2020 CDR, you may be familiar with these codes. If your site reported this PFAS to 2020 or
earlier CDR using other codes, you will need to determine the appropriate 2020 CDR codes and
report those in this section. Because data reported using other codes was not reported as required
by the PFAS section 8(a)(7) rule, it is not considered duplicative. Descriptions for each FC and a
crosswalk between the OECD-based 2020 CDR codes and 2016 CDR codes are provided in
Appendix D (Table D-4). This crosswalk may be helpful if you are already familiar with the
2016 CDR codes and can help you determine the correct 2020 CDR codes to use if you have
previously reported the PFAS using 2016 CDR codes. Function Category codes to be used for
section 8(a)(7) reporting are provided in Table 4-9.
If you select F999 (Other), you must provide a description of the function of the chemical
substance. The written description should be used to provide a description at a comparable level
of specificity as found with the current codes. It should not be used to add additional, more
specific detail.
Function codes are based on the intended physical or chemical characteristic for when a
chemical substance or mixture is consumed as a reactant; incorporated into a formulation,
mixture, reaction product, or article; repackaged; or used (e.g., as an abrasive, a catalyst, or an
elasticizer). However, the functional use categories for consumer or commercial categories cover
the life cycle and describe the specific function that a chemical provides when used in the
formulation of a product or article, or when used within an industrial process. While the function
of a chemical may be the same across its life cycle, certain functions may only be appropriate for
consideration in an industrial setting, while others may be relevant for a consumer or commercial
setting. For more information on reporting consumer and commercial use data, see Section 4.6.3
below.
Table 4-9. Codes for Reporting Function Categories
( ode
( ;ik'}ion
F001
Abrasives
F002
Etching agent
F003
Adhesion/cohesion promoter
F004
Binder
F005
Flux agent
F006
Sealant (barrier)
F007
Absorbent
F008
Adsorbent
F009
Dehydrating agent (desiccant)
F010
Drier
F011
Humectant
F012
Soil amendments (fertilizers)
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Code
F013
Anti-adhesive/cohesive
F014
Dusting agent
F015
Bleaching agent
F016
Brightener
F017
Anti-scaling agent
F018
Corrosion inhibitor
F019
Dye
F020
Fixing agent (mordant)
F021
Hardener
F022
Filler
F023
Anti-static agent
F024
Softener and conditioner
F025
Swelling agent
F026
Tanning agents not otherwise specified
F027
Waterproofing agent
F028
Wrinkle resisting agent
F029
Flame retardant
F030
Fuel agents
F031
Fuel
F032
Heat transferring agent
F033
Hydraulic fluids
F034
Insulators
F035
Refrigerants
F036
Anti-freeze agent
F037
Intermediate
F038
Monomers
F039
Ion exchange agent
F040
Anti-slip agent
F041
Lubricating agent
F042
Deodorizer
F043
Fragrance
F044
Oxidizing agent
F045
Reducing agent
F046
Photosensitive agent
F047
Photosensitizers
F048
Semiconductor and photovoltaic agent
F049
UV stabilizer
F050
Opacifer
F051
Pigment
F052
Plasticizer
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Code
F053
Plating agent
F054
Catalyst
F055
Chain transfer agent
F056
Chemical reaction regulator
F057
Crystal growth modifiers (nucleating agents)
F058
Polymerization promoter
F059
Terminator/Blocker
F060
Processing aids, specific to petroleum production
F061
Antioxidant
F062
Chelating agent
F063
Defoamer
F064
pH regulating agent
F065
Processing aids not otherwise specified
F066
Energy Releasers (explosives, motive propellant)
F067
Foamant
F068
Propellants, non-motive (blowing agents)
F069
Cloud-point depressant
F070
Flocculating agent
F071
Flotation agent
F072
Solids separation (precipitating) agent, not otherwise specified
F073
Cleaning agent
F074
Diluent
F075
Solvent
F076
Surfactant (surface active agent)
F077
Emulsifier
F078
Thickening agent
F079
Viscosity modifiers
F080
Laboratory chemicals
F081
Dispersing agent
F082
Freeze-thaw additive
F083
Surface modifier
F084
Wetting agent (non-aqueous)
F085
Aerating and deaerating agents
F086
Explosion inhibitor
F087
Fire extinguishing agent
F088
Flavoring and nutrient
F089
Anti-redeposition agent
F090
Anti-stain agent
F091
Anti-streaking agent
F092
Conductive agent
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Code
F093
Incandescent agent
F094
Magnetic element
F095
Anti-condensation agent
F096
Coalescing agent
F097
Film former
F098
Demulsifier
F099
Stabilizing agent
F100
Alloys
F101
Density modifier
F102
Elasticizer
F103
Flow promoter
F104
Sizing agent
F105
Solubility enhancer
F106
Vapor pressure modifiers
F107
Embalming agent
F108
Heat stabilizer
F109
Preservative
F110
Anti-caking agent
Fill
Deflocculant
F112
Dust suppressant
F113
Impregnation agent
F114
Leaching agent
F115
Tracer
F116
X-ray absorber
F999
Other
4.6.3 Consumer and Commercial Use
For purposes of section 8(a)(7) reporting, a commercial use means the use of a chemical
substance or a mixture (including as part of an article) in a commercial enterprise providing
saleable goods or a service (40 CFR 711.3). A consumer use, on the other hand, means the use of
a chemical substance or a mixture (including as part of an article) when sold to or made available
to consumers for their use (40 CFR 711.3).
For each PFAS manufactured (including imported), report up to ten unique combinations
of the following data elements: the Product Category (PC) (described in Section 4.6.3.1), the
Function Category (FC) (described in Section 4.6.3.2), whether the use is consumer and/or
commercial (described in Section 4.6.3.3), and whether the use is in products intended for use by
children (described in Section 4.6.3.4) (40 CFR 705.15(c)(7)). A combination of these four data
elements defines a potential exposure scenario for risk-screening and priority-setting purposes. If
more than ten unique combinations apply to a chemical substance, you need only report the ten
combinations for the chemical substance that cumulatively represent the largest percentage of
production volume, measured by weight (40 CFR 705.15(c)(4)). The reporting tool will allow
you to enter more than ten combinations if you choose to do so.
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For each of these unique combinations, you are also required to report the maximum
concentration (described in Section 4.6.3.5), the percentage of production volume (reported in
Section C of the reporting form - described in Section 4.7.2.6), and, for commercial uses,
information about worker exposure (reported in section C of the reporting form - described in
Section 4.10.7) (40 CFR 711.15(c)(8)).
You are required to report information that is known to or reasonably ascertainable by
you concerning the consumer and commercial end uses of each chemical substance
manufactured (including imported) at sites you control and at sites controlled by people to whom
you have either directly or indirectly (including through a broker/distributor, from a customer,
etc.) distributed the reportable PFAS (40 CFR 711.15(c)(4)).
4.6.3.1 Product Category
You must designate up to ten product categories which correspond to the actual use of the
chemical substance by reporting the codes which correspond to the appropriate product
categories (40 CFR 711.15(c)(4)). If more than ten codes apply, you need report only the ten
codes for the chemical substance that cumulatively represent the largest percentage of production
volume, measured by weight (40 CFR 711.15(c)(4)). The reporting tool will allow you to enter
more than ten categories if you choose to do so.
You must use the codes in Table 4-10 for reporting under this data call. These codes,
based on OECD standards, were required for reporting of chemical substances designated by
EPA as a high priority for risk evaluation for 2020 CDR reporting and were optional for the 2020
CDR for other chemical substances; if you reported to 2020 CDR, you may be familiar with
these codes. If your site reported this PFAS to 2020 or earlier CDR using other codes, you will
need to determine the appropriate 2020 CDR codes and report those in this section. Because data
reported using other codes was not reported as required by the PFAS section 8(a)(7) rule, it is not
considered duplicative. Descriptions for each product category code and a crosswalk between the
OECD-based 2020 CDR codes and 2016 CDR codes are provided in Appendix D (Table D-3).
This crosswalk may be helpful if you are already familiar with the 2016 CDR codes and can help
you determine the correct 2020 CDR codes to use if you have previously reported the PFAS
using 2016 CDR codes. Product Category codes are provided in Table 4-10.
If you select CC980 (Other), you must provide a description of the product category. The
written description should be used to provide a description at a comparable level of specificity as
found with the current codes. It should not be used to add additional, more specific detail.
Table 4-10. Product Category Codes
Code
CiiK'Sion
( homiciil Siihsliinccs in l-'ni-iiishin<±. ( loiininu. 1 roiilmonl C;uv Products
CC101
Construction and building materials covering large surface areas including stone, plaster, cement,
glass and ceramic articles; fabrics, textiles, and apparel
CC102
Furniture & furnishings including plastic articles (soft); leather articles
CC103
Furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or
rubber articles
CC104
Leather conditioner
CC105
Leather tanning, dye, finishing, impregnation and care products
CC106
Textile (fabric) dyes
CC107
Textile finishing and impregnating/surface treatment products
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Code
Ciili'Korj
CC108
All-purpose foam spray cleaner
CC109
All-purpose liquid cleaner/polish
CC110
All-purpose liquid spray cleaner
CC111
All-purpose waxes and polishes
CC112
Appliance cleaners
CC113
Drain and toilet cleaners (liquid)
CC114
Powder cleaners (floors)
CC115
Powder cleaners (porcelain)
CC116
Dishwashing detergent (liquid/gel)
CC117
Dishwashing detergent (unit dose/granule)
CC118
Dishwashing detergent liquid (hand-wash)
CC119
Dry cleaning and associated products
CC120
Fabric enhancers
CC121
Laundry detergent (unit-dose/granule)
CC122
Laundry detergent (liquid)
CC123
Stain removers
CC124
Ion exchangers
CC125
Liquid water treatment products
CC126
Solid/Powder water treatment products
CC127
Liquid body soap
CC128
Liquid hand soap
CC129
Solid bar soap
CC130
Air fresheners for motor vehicles
CC131
Continuous action air fresheners
CC132
Instant action air fresheners
CC133
Anti-static spray
CC134
Apparel finishing, and impregnating/surface treatment products
CC135
Insect repellent treatment
CC136
Pre-market waxes, stains, and polishes applied to footwear
CC137
Post-market waxes, and polishes applied to footwear (shoe polish)
cms
Waleipi'iuifiimand walei-iesislanl spm\ s
Chomiciil Suhsiiiiicos in ( oust ruclion. Psiini. Ikclrknl. ;iikI Mel.il Products
CC201
Fillers and putties
CC202
Hot-melt adhesives
CC203
One-component caulks
CC204
Solder
CC205
Single-component glues and adhesives
CC206
Two-component caulks
CC207
Two-component glues and adhesives
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Code
CiiK'Sion
CC208
Adhesive/Caulk removers
CC209
Aerosol spray paints
CC210
Lacquers, stains, varnishes and floor finishes
CC211
Paint strippers/removers
CC212
Powder coatings
CC213
Radiation curable coatings
CC214
Solvent-based paint
CC215
Thinners
CC216
Water-based paint
CC217
Construction and building materials covering large surface areas, including wood articles
CC218
Construction and building materials covering large surface areas, including paper articles; metal
articles; stone, plaster, cement, glass and ceramic articles
CC219
Machinery, mechanical appliances, electrical/electronic articles
CC220
Other machinery, mechanical appliances, electronic/electronic articles
CC221
Construction and building materials covering large surface areas, including metal articles
CC222
Electrical batteries and accumulators
( hemic;! 1 Suhsl;inces in P;ick;i<±ini±. Pnncr. Pliislic. To\s. Ilobln Products
( ( wo
Non-TSCA use
CC301
Packaging (excluding food packaging), including paper articles
CC302
Other articles with routine direct contact during normal use, including paper articles
CC303
Packaging (excluding food packaging), including rubber articles; plastic articles (hard); plastic
articles (soft)
CC304
Other articles with routine direct contact during normal use including rubber articles; plastic articles
(hard)
CC305
Toys intended for children's use (and child dedicated articles), including fabrics, textiles, and
apparel; or plastic articles (hard)
CC306
Adhesives applied at elevated temperatures
CC307
Cement/concrete
CC308
Crafting glue
CC309
Crafting paint (applied to body)
CC310
Crafting paint (applied to craft)
CC311
Fixatives and finishing spray coatings
CC312
Modelling clay
CC313
Correction fluid/tape
CC314
Inks in writing equipment (liquid)
CC315
Inks used for stamps
CC316
Toner/Printer cartridge
CC317
Liquid photographic processing solutions
(hciniciil Su hsl ;i nces in Aiiioinoli\o. Fuel. Agriculture. Ouldooi' I sc Products
CC401
Exterior car washes and soaps
CC402
Exterior car waxes, polishes, and coatings
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Code
CiiK'Sion
CC403
Interior car care
CC404
Touch up auto paint
CC405
Degreasers
CC406
Liquid lubricants and greases
CC407
Paste lubricants and greases
CC408
Spray lubricants and greases
CC409
Anti-freeze liquids
CC410
De-icing liquids
CC411
De-icing solids
CC412
Lock de-icers/releasers
CC413
Cooking and heating fuels
CC414
Fuel additives
CC415
Vehicular or appliance fuels
CC416
Explosive materials
CC417
Agricultural non-pesticidal products
CC418
Lawn and garden care products
( Ik-iiiic;il Substances in Products not Described l)\ Oilier ( odes
CC980
Other (specify)
CC990
Non-TSCA use
4.6.3.2 Functional Use for Consumer and/or Commercial Products
For each consumer and/or commercial product category reported, report the code(s) that
designates the function category(ies) that best represents the specific manner in which the
chemical substance is used (40 CFR 705.(c)(5)). You must use the codes in Table 4-9 for
reporting under this data call. These codes are the same as those used to report the appropriate
Function Category for industrial processing and use. A particular function category may need to
be reported more than once, to the extent that more than one consumer or commercial product
category applies to a given function category.
For the special situation where the PFAS has multiple functions within the same product,
you can report in one of two ways:
1) If one function is predominant, simply report the primary function; or
2) If all functions represent a substantial portion of the product, report each on a
separate line and either estimate the portions individually or bifurcate the percent
Production Volume (%PV) equally across the functions (so as not to double or
triple-count the %PV for the one product).
If none of the listed function categories accurately describes a use of a chemical
substance, the category "Other" may be used, and must include a description of the use. The
written description should be used to provide a description at a comparable level of specificity as
found with the current codes. It should not be used to add additional, more specific detail.
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4.6.3.3 Consumer and/or Commercial Use
For each product category reported, report whether the use is a consumer use or a
commercial use (40 CFR 705.15(c)(4). If the product has both consumer and commercial uses,
report both.
4.6.3.4 Use in Produces) Intended for Use by Children
Within each consumer product category reported, you must determine whether any
amount of each reportable chemical substance manufactured (including imported) by you is
present in or on any consumer product(s) intended for use by children age 14 or younger,
regardless of the concentration of the chemical substance remaining in or on the product (40
CFR 705.15(c)(7)). If you determine that your chemical substance or mixture is used in a
consumer product intended for use by children, report "Yes" in the "Used in Product(s) Intended
for Children" column in Part II.D.2 of the reporting form. If you determine that your chemical
substance or mixture is not used in a consumer product intended for use by children, report "No."
EPA defines "intended for use by children" to mean the chemical substance or mixture is
used in or on a product that is specifically intended for use by children age 14 or younger (40
CFR 705.3). Your chemical substance or mixture is intended for use by children if you answer
"yes" to at least one of the following questions about the product into which your chemical
substance or mixture is incorporated:
• Is the product commonly recognized (i.e., by a reasonable person) as being
intended for use by children age 14 or younger?
• Does the manufacturer of the product state through product labeling or other
written materials that the product is intended or will be used by children age 14 or
younger?
• Is the advertising, promotion, or marketing of the product aimed at children age
14 or younger?
Table 4-11 illustrates some (non-exhaustive) examples of "Use in Product(s) Intended for
Use by Children." For example, certain products (e.g., crayons, coloring books, diapers, and toy
cars) are typically used by children age 14 or younger. If you determine that your chemical
substance or mixture is used in crayons, for example, you would report "Y" for children's use for
CC305.
Certain products, such as household cleaning products, automotive supplies, and
lubricants, typically are not intended to be used by children age 14 or younger. As such, if you
determine that your chemical substance or mixture is used in automotive care products and
lubricants, for example, you would report "no" for children's use for categories CC401 and
CC402.
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Table 4-11. Examples of Products Intended for Use by Children
Code
(;iU'iior\
I'Aiimpk's
Chciniciil Suhsiiiiicos in l-'iirnishinus. (Icnninus. I iviiIiiu'iK ( ;iit Products
CC102
Furniture & furnishings including Plastic articles (soft);
Leather articles
Child's car seat, children's sheets
CC103
Furniture & furnishings including Stone, plaster, cement,
glass and ceramic articles; Metal articles; or Rubber articles
Baby cribs, changing tables
CC106
Textile (fabric) dyes
Children's clothing
CC107
Textile finishing and impregnating/surface treatment
products
Children's clothing, children's
sheets, child's car seat
CC127
Liquid body soap
Baby shampoo, children's bubble
bath
( homiciil Suhsl;incos in ( oustruclicm. P;iini. I.lcdricid ;iihI Moliil Products
CC219
Machinery, mechanical appliances, electrical/electronic
articles
Electronic games, remote control
cars
CC222
Electrical batteries and accumulators
Batteries used in toys
( hoiniciil Su hsl ;i ncos in Piickiiuinu. Pnncr. Pl;is(ic. Ilohln Products
CC302
Other articles with routine direct contact during normal use,
including paper articles
Diapers, baby wipes, coloring
books
CC305
Toys intended for children's use (and child dedicated
articles), including Fabrics, textiles, and apparel; or Plastic
articles (hard)
Pacifiers, toy trucks, dolls, toy
cars, wagons, action figures,
balls, swing sets, slides, skates,
baseball gloves, kid's rake
CC306
Adhesives applied at elevated temperatures
Craft glue for a hot glue gun
CC308
Crafting glue
Craft glue
CC309
Crafting Paint (applied to body)
Chemicals used to add color to
body paint, finger paints
4.6.3.5 Maximum Concentration Code
When the chemical substance you manufacture (including import) is used in commercial
or consumer products, you are required to report the estimated typical maximum concentration
(measured by weight) of each chemical substance in each commercial or consumer product
category reported (40 CFR 715.15(c)(8)). For each chemical substance used in a reported
commercial or consumer product, report the code that corresponds to the appropriate
concentration range. Table 4-12 shows the codes and concentration ranges.
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Table 4-12. Codes for Reporting Maximum Concentration
(tide
( oniTiilnilinii Riiniic(wc'iiihl pcivoul)
Ml
Less than l%by weight
M2
At least 1 but less than 30% by weight
M3
At least 30 but less than 60% by weight
M4
At least 60 but less than 90% by weight
M5
At least 90% by weight
4.7 Part II - Section C. Manufacturing, Processing, and Use
Information
The following subsections describe the manufacturing information required to be
reported for each PFAS.
4.7.1 Confidentiality of Manufacturing Information
Information reported in the
manufacturing section of the section
8(a)(7) form can be claimed as
confidential. For most of the data
elements, upfront substantiation of the
claim is required. Specifically, upfront
substantiation:
• IS NOT required for the annual
domestically manufactured
volume, imported volume.
• IS required for all other data
elements.
4.7.1.1 Confidentiality of Production
Volume Information
Check the appropriate CBI box
in this block to assert a confidentiality claim for the associated production volume information
(domestically manufactured volume, imported volume, or percent production volume for each
consumer and commercial use) being submitted. If you do not check the CBI box for any
information element, then that information is not claimed as CBI and may be made public
without further notice to you. Further, if you fail to assert your CBI claims in accordance with
the statute and applicable rules, EPA may make the information available to the public without
further notice to you.
4.7.1.2 Confidentiality of all Other Manufacturing Information
Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the associated information being submitted. Checking the CBI
box automatically triggers the substantiation questions. See Table 4-13 for substantiation
questions related to these data elements. If you do not check the CBI box for any information
Summary of substantiation requirements for claims of
confidentiality:
All claims of confidentiality, except for information
exempt from substantiation under TSCA section 14(c)(2)
such as production volume information (including
domestic manufacture and import), and certain
information in joint submissions, must be substantiated at
the time of submission as required by TSCA section
14(c)(3).
When using the reporting tool, you will be alerted when
CBI substantiations are required.
For additional information about how to answer
substantiation questions, visit www. eva. gov/tsca-cbi on
the EPA website.
For information on EPA's policy of reviewing CBI
claims, visit EPA Review and Determination of CBI
Claims under TSCA on the EPA website.
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element, then that information is not claimed as CBI and may be made public without
further notice to you. Further, if you fail to substantiate your CBI claims in accordance with the
statute and applicable rules, EPA may make the information available to the public without
further notice to you. For additional information about how to answer substantiation questions,
visit www.ena.gov/tsca-cbi on the EPA website.
Table 4-13. Substantiation Questions to be Answered when Asserting Manufacturing,
Processing, and Use-Related Confidentiality Claims (40 CFR 705.30(b))
No.
Question
1.
Will disclosure of the information claimed as confidential likely cause substantial harm to your
business's competitive position? If you answered yes, describe the substantial harmful effects that
would likely result to your competitive position if the information is disclosed, including but not
limited to how a competitor could use such information and the causal relationship between the
disclosure and the harmful effects.
2.
Has your business taken precautions to protect the confidentiality of the disclosed information? If yes,
please explain and identify the specific measures, including but not limited to internal controls, that
your business has taken to protect the information claimed as confidential.
3.
(i) Is any of the information claimed as confidential required to be publicly disclosed under any other
Federal law? If yes, please explain.
(ii) Does any of the information claimed as confidential otherwise appear in any public documents,
including (but not limited to) safety data sheets; advertising or promotional material; professional or
trade publications; state, local, or Federal agency files; or any other media or publications available to
the general public? If yes, please explain why the information should be treated as confidential.
(iii) Does any of the information claimed as confidential appear in one or more patents or patent
applications? If yes, please provide the associated patent number or patent application number (or
numbers) and explain why the information should be treated as confidential.
4.
Does any of the information that you are claiming as confidential constitute a trade secret? If yes,
please explain how the information you are claiming as confidential constitutes a trade secret.
5.
Is the claim of confidentiality intended to last less than 10 years (see TSCA section 14(e)(1)(B))? If
yes, please indicate the number of years (between 1-10 years) or the specific date after which the claim
is withdrawn.
5.
Has EPA, another federal agency, or court made any confidentiality determination regarding
information associated with this chemical substance? If yes, please provide the circumstances
associated with the prior determination, whether the information was found to be entitled to
confidential treatment, the entity that made the decision, and the date of the determination.
4.7.2 Reporting Manufacturing Information
This section describes the manufacturing data elements that should be reported for your
PFAS for each year. If any information is not known or reasonably ascertainable by you
(including your company), enter or select "NKRA" for "not known or reasonably ascertainable"
in the box corresponding to that data element. You may also check the CBI box next to each data
element to claim data as confidential. However, keep in mind that you cannot claim an "NKRA"
designation as confidential.
4.7.2.1 Domestically Manufactured Production Volume
Report the volume of the chemical substance domestically manufactured at your
site, in pounds. Report the quantity to at least two significant figures; it should be accurate
to the extent known to or reasonably ascertainable by you. Production volumes should be
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reported in numeric format, without commas (e.g., 6352000). See Table 4-14 for
examples.
4.7.2.2 Imported Production Volume
Reporting for a chemical with multiple sources
• If you import a PFAS from multiple sources, or
domestically manufacture the PFAS through multiple
processes, sum those sources together for reporting the
total production volume, and consider the total amount
for all other data fields.
• If you import or domestically manufacture a chemical
and also have quantities on site that were not
manufactured by your site (e.g., purchased from a
domestic source), consider only the volume
manufactured (including imported) by your site
when reporting total production volume and all other
data fields. Do not report on quantities of the PFAS
that were not manufactured (including imported) by
your site.
instance, if you import three mixtures and each mixture contains PFAS A, then you would
determine the volume of PFAS A in each mixture and report the aggregated amount. See Table
4-14 for examples.
For article importers reporting on the Article Importer form, you should report the
volume of the article imported, rather than attempting to calculate the volume of the PFAS
contained within the articles. You may choose to report the total weight of the PF AS-containing
articles (e.g., in tons or pounds) or the quantity of the article imported (e.g., the number of
vehicles). You must specify the unit of measurement for the reported production volume.
4.7.2.3 For Imported Chemical Substances, Is the Chemical Never Physically at Site?
Report whether or not your imported PFAS is physically at the reporting site. Report one
of the following choices:
~ Yes, the imported PFAS is never physically at the reporting site (e.g., if you ship the
chemical substance from a foreign country directly to another location such as a
warehouse, a processing or use site, or a customer's site).
~ No, the imported PFAS is physically present at the reporting site.
~ NA, not applicable because the PFAS is not imported.
~ NKRA, it is not known to or reasonably ascertainable by you whether the
imported PFAS is physically present at the reporting site.
4.7.2.4 Volume Directly Exported
Report the volume directly exported and not domestically processed or used, in pounds.
The volume exported should not exceed the sum of the domestically manufactured and imported
volumes minus volume used on site. Note that direct exporting includes sending a PFAS to a
Report the volume of the
chemical substance imported by
your site, in pounds. Report the
quantity to at least two significant
figures; it should be accurate to the
extent known to or reasonably
ascertainable by you. You should
use the same numeric format as
described for the domestically
manufactured production volume.
Imported and domestically
manufactured production volumes
are reported separately for each
PFAS at each site.
Note that if you import
various mixtures containing PFAS,
you should add all import volumes
associated with each PFAS. For
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distributor who then exports it without repackaging it, even if it is relabeled. Direct exporting
does not include sending a PFAS to a distributor who repackages and relabels it. The latter case
would be considered a processing and use activity potentially reportable under Part II - Section
B of the reporting form. Report the quantity to at least two significant figures; it should be
accurate to the extent known to or reasonably ascertainable by you. You should use the same
numeric format as described for domestically manufactured production volume (see section
4.7.2.1). See Table 4-14 for examples.
Table 4-14. Examples of Reporting Volumes for Part II - Section C
Description
Reporting Kc(|iiimiK*nl
Example Site S domestically
manufactures 31,415 lb of Example
PFAS S.
Example Site S should report 31,415 lb as domestically
manufactured for Example PFAS S. The total production volume
(i.e., the domestically manufactured volume) should be used to report
all remaining information.
Example Site T domestically
manufactures 15,000 lb of Example
PFAS T and directly imports 15,112 lb
of Example PFAS T.
Example Site T should report 15,000 lb as domestically
manufactured. Because Example Site T controls the import
transaction, Example Site T should also report 15,112 lb as imported
for Example PFAS T. The total production volume (i.e., sum of the
domestically manufactured and import volumes, 30,112 lb) should be
used to report all remaining information.
Example Site U domestically
manufactures 33,500 lb of Example
PFAS U. Of the 33,500 lb
manufactured, Example Site U directly
exports 13,000 lb to a foreign customer.
Example Site U should report 33,500 lb as domestically
manufactured and 13,000 lb as exported for Example PFAS U. The
volume not directly exported (20,500 lb) should be used to report all
remaining information.
Example Company V coordinates the
import of 105,000 lb of Example PFAS
V, which is imported directly to three
different sites owned by Company V.
Site 1 receives 41,000 lb and Sites 2 and
3 each receive 32,000 lb of Example
PFAS V.
Example Company V should report 105,000 lb as imported for
Example PFAS V. The total production volume (i.e., the imported
volume) should be used to report all remaining information. Because
the three sites controlled by Company V did not control the import
transaction, the sites are not required to report the imported volumes.
Example Site W domestically
manufacturers 77,000 lb, imports
22,000 lb, and exports 11,000 lb of
Example PFAS W.
Example Site W should report an amount that does not exceed
88,000 lb as volume used at site for Example PFAS W, as the volume
used at site should not be greater than the sum of the domestically
manufactured and imported volumes minus the volume exported
(77,000 lb + 22,000 lb - 11,000 lb).
Example Site X imports 20,000 lb of
Example PFAS X and purchases 30,000
lb of Example PFAS X from a domestic
producer.
Example Site X should report 20,000 lb as imported for Example
PFAS X. The total production volume is 20,000 lb; the 30,000 lb of
Example PFAS X purchased from a domestic producer is not
included because Example Site X is not the manufacturer of that
quantity of PFAS X (i.e., Site X neither imported norproduced those
30,000 lb). Only the 20,000 lb of PFAS X imported should be
considered throughout the entire section 8(a)(7) form.
4.7.2.5 Industrial Processing and Use - Percentage of Production Volume
Report the estimated percentage of total production volume of the PFAS associated
with each unique combination of industrial processing or use operation, sector, and
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function category (TPU, IS, and FC) as reported in Part II - Section B of the reporting
form (see section4.6.2). The percentage should be accurate to the extent that it is known to
or reasonably ascertainable by you. Round your estimates to the nearest 10 percent of
production volume (40 CFR 711.15(d)(4)). If you would like to provide more specific
percentages, please do so. Do not round a particular combination that accounts for less
than five percent of the total production volume to zero percent. In such cases, you must
report the percentage of production volume attributable to that combination to the nearest
one percent of production volume.
The total percentage of
production volumes associated with
the TPU, IS, and FC combinations
may add up to more than 100
percent, given that you are reporting
on distribution of a PFAS to sites in
your control as well as downstream
sites, some of which are not
immediate purchasers from your
original manufacturing site. Thus,
you may "double count" quantities
of the PFAS as you consider its use
at multiple sites. The sum may also
add to more than 100% due to rounding.
Additionally, the total percentage of production volume may add up to less than 100 percent if,
for example:
• You do not know or cannot reasonably ascertain information about how all of your production
volume is processed or used;
• More than 10 combinations of codes are applicable to your chemical substance;
• You export a portion of the production volume;
• A portion of the production volume is used for commercial, or consumer uses rather than
industrial uses; or
• Percentages round such that they do not sum to 100% (e.g., three use combinations that each
account for one-third of total use will be reported as 30% each, totaling 90%).
Table 4-15 provides examples of reporting industrial processing and use data.
Table 4-15. Examples of Reporting Industrial Processing and Use Information
Description
Reporting Kc(|iii miicul
Example Site Y manufactures 12,000 lb of Example
PFAS Y for processing for incorporation into a
mixture. All of the production is for use in industrial
sector IS 17 (Synthetic Dye and Pigment
Manufacturing). Of the production volume, 67%
(8,000 lb) is used as an anti-stain agent and 33%
(4,000 lb) is used as a viscosity modifier.
On line 3 .A. 1 of the Form, enter PF for type of
process or use, IS 17 for industrial sector, F090 for
FC, and 70% for production volume. On line 3.A.2
of the form, enter PF for type of process or use,
IS 17 for industrial sector, F079 for FC, and 30% for
production volume.
Example Site Z manufactures 50,000 lb of Example
PFAS Z for processing for incorporation into a
mixture. All of the production is for use under
On line 3 .A. 1 of the form, enter PF for type of
process or use, IS 17 for industrial sector, F090 for
FC, and 100% for production volume. Online 3.A.2
How to determine your percent production volume:
1. Determine the production volume that is attributable
to each unique combination of TPU, IS, and FC.
2. Determine your total production volume for the
year.
a. Add together the volume domestically
manufactured and the volume imported.
b. DO NOT subtract the volume used on-site or
the volume exported.
3. Divide the volume determined in step 1 by the
volume determined in step 2 and multiply by 100.
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Description
Reporting Kc(|iii miicul
industrial sector IS 17 (Synthetic Dye and Pigment
Manufacturing). Of the production volume, 97%
(48,500 lb) is used as an anti-stain agent and 3%
(1,500 lb) is used as a viscosity modifier.
of the form, enter PF for type of process or use,
IS 17 for industrial sector, and F079 for FC. Because
less than 10% of the production volume is used as a
viscosity modifier, enter the percentage to the
nearest one percent, i.e., 3%, for production volume.
4.7.2.6 Consumer and Commercial Use - Percentage of Production Volume
Report the estimated percentage of total production volume of the reportable chemical
substance associated with each consumer and commercial product category as reported in Part II
- Section B of the reporting form (see Section 4-274.6.3.1). The percentage should be accurate to
the extent that it is known to or reasonably ascertainable by you. Round your estimates to the
nearest 10 percent of production volume (40 CFR 705.15(d)(5)). If you would like to provide
more specific percentages, please do so. Do not round a particular combination that accounts for
less than five percent of the total production volume to zero percent. In such cases, you must
report the percentage of production volume attributable to that combination to the nearest one
percent of production volume.
The total percentage of
production volumes associated with
the product codes may add up to
more than 100 percent, given that
you are reporting on distribution of
a chemical substance to sites in
your control as well as downstream
sites, some of which are not
immediate purchasers from your
original manufacturing site. Thus,
you may "double count" quantities
of the PFAS as you consider its use
at multiple sites. The sum may also
add to more than 100% due to rounding.
Additionally, the total percentage of production volume may add up to less than 100
percent if, for example:
• You do not know or cannot reasonably ascertain information about how all of your production
volume is processed or used;
• More than 10 combinations of codes are applicable to your chemical substance;
• You export a portion of the production volume;
• A portion of the production volume is used for industrial uses rather than
commercial/consumer uses; or
• Percentages round such that they do not sum to 100% (e.g., three use combinations that each
account for one-third of total use will be reported as 30% each, totaling 90%).
Table 4-16 provides examples of reporting consumer and commercial use information.
How to determine your percent production volume:
1. Determine the production volume that is attributable
to each consumer or commercial product category.
2. Determine your total production volume for the
year.
a. Add together the volume domestically
manufactured and the volume imported.
b. DO NOT subtract the volume used on-site or
the volume exported.
3. Divide the volume determined in step 1 by the
volume determined in step 2 and multiply by 100.
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Table 4-16. Examples of Reporting Consumer and Commercial Use Information
Description
Reporting Kc(|iiircmcnl
Example Site AB manufactures 12,000 lb of Example PFAS
AB for processing for incorporation into a mixture. All of
the production is for use in commercial products. Of the
production volume, 67% (8,000 lb) is used in waterproofing
sprays for apparel and 33% (4,000 lb) is used in paper
packaging (for non-food use).
On one line, enter CC138 for PC and 70% for
production volume. On another line, enter
CC301 for PC and 30% for production
volume.
Example Site CD manufactures 50,000 lb of Example PFAS
CD for processing for incorporation into a mixture. All of
the production is for use in commercial products. Of the
production volume, 97% (48,500 lb) is used in
waterproofing sprays for apparel and 3% (1,500 lb) is used
in paper packaging (for non-food use).
On one line, enter CC138 for PC and 100%
for production volume. On another line, enter
CC301 for PC. Because less than 10% of the
production volume is used in paper
packaging, enter the percentage to the nearest
one percent, i.e., 3%, for production volume.
4.7.2.7 Site-limited?
Indicate whether the PFAS was site-limited. Site-limited means a chemical substance is
manufactured and processed only within a site and is not distributed as a chemical substance or
as part of a mixture or article outside the site. Imported chemical substances are never site-
limited. Report yes if the PFAS was site-limited, no if the PFAS was not site-limited, or NKRA
if you do not know and cannot reasonably ascertain whether the PFAS was site-limited.
4.7.2.8 Recycled Volume
Report the volume of the manufactured PFAS, which otherwise would be disposed of as
a waste, that is being removed from the waste stream (on site) and is being used for a
commercial purpose (40 CFR 705.15(d)(7)). Report the quantity, in pounds, to at least two
significant figures; it should be accurate to the extent known to or reasonably ascertainable by
you. You should use the same numeric format as described for the domestically manufactured
production volume.
Table 4-17 provides examples of reporting recycling activities.
Table 4-17. Examples of Reporting Recycling
Description
Reporting Kc(|iiircnicnl
Example Site EF manufactures 2,721 lb of Example
PFAS EF, none of which is recycled instead of being
disposed of as a waste.
Enter 0 as no portion of the chemical is being
recycled.
Example Site GH manufactures 5,550 lb of Example
PFAS GH, 1,650 lb of which is then recycled instead of
being disposed of as a waste.
Enter 1,650 lb as the volume recycled.
Example Site IJ manufactures 52,000 lb of Example
PFAS IJ, 10% (1,500 lb) of which is manufactured as a
byproduct. That 1,500 lb is then directly recycled and the
other 50,500 lb is sold into commerce.
Enter 1,500 lb as the volume recycled.
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Ik'scriplion
Reporting Ko(|iiiiviiioiil
Example Site KL manufactures a chemical substance,
WonderChem. The process to manufacture WonderChem
results in the production of a byproduct, Example PFAS
KL. Some portion of PFAS KL stays with WonderChem.
The remaining portion of PFAS KL is 58,000 lb. Initially
Site KL disposed of PFAS KL as a waste, but partway
through the year discovered a use for PFAS KL and
diverted the remaining portion (29,000 lb) from the waste
stream. The full volume of WonderChem is intended for
commercial use.
Enter the portion of Example PFAS KL that is
being recycled instead of being disposed of as a
waste. Do not include any quantity of PFAS KL
that stays with and is distributed with
WonderChem, because WonderChem is
produced for commercial use and no quantity is
intended to be disposed of as a waste or
recycled. In this case, 29,000 pounds were
recycled.
Example Site MN manufactures 12,000 lb of Example
Chemical MN for processing by incorporation into a
mixture. Of the production volume, 92% (11,040 lb) is
processed for incorporation and 8% (960 lb) is shipped to
a waste management facility that also recycles certain
materials. The manufacturer cannot reasonably ascertain
whether this portion of Example PFAS MN is being
recycled or disposed of as a waste.
Enter NKRA as the manufacturer does not know
and cannot reasonably ascertain whether PFAS
MN is being recycled or disposed of as a waste.
Example Site OP manufactures 100% of Example PFAS
OP (15,000 lb) as a byproduct. That 15,000 lb is then
sold directly to a recycler.
Enter 15,000 lb as the entire volume of Example
PFAS OP is known to be recycled rather than
disposed of as a waste.
4.8 Part II - Section D. A description of the byproducts
resulting from the manufacture, processing, use, or
disposal of each such substance or mixture
In this section, report information about all byproducts resulting from the manufacture,
processing, use, or disposal of the PFAS. Report information about all byproducts that are
chemical substances, regardless of whether the byproducts are themselves PFAS. Information in
this section is to be reported for each byproduct for each year. Report all information known to
or reasonably ascertainable by you, including byproducts produced during processing, use, or
disposal of the PFAS at sites not under your control.
Note that in the case that you produce a PFAS as a byproduct, you may also be required
to report that PFAS on its own section 8(a)(7) form. For example, if you are reporting for PFAS
A, and PFAS B is produced as a byproduct of manufacturing PFAS A, note that you may also
need to complete a section 8(a)(7) form for PFAS B. In that case, you may indicate duplicative
reporting for PFAS B in this section.
For purposes of section 8(a)(7) reporting, refer to the following definition of byproduct:
Byproduct means a chemical substance produced without separate commercial intent
during the manufacture, processing, use, or disposal of another chemical substance(s) or
mixture(s). (40 CFR 704.3)
Manufacture for commercial purposes means:
(1) To manufacture, produce, or import with the purpose of obtaining an immediate or
eventual commercial advantage, and includes, among other things, the "manufacture " of any
amount of a chemical substance or mixture
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(1) for commercial distribution, including for test marketing, or
(ii) for use by the manufacturer, including use for product research and development or
as an intermediate.
(2) The term also applies to substances that are produced coincidentally during the
manufacture, processing, use, or disposal of another substance or mixture, including byproducts
that are separatedfrom that other substance or mixture and impurities that remain in that
substance or mixture. Byproducts and impurities without separate commercial value are
nonetheless producedfor the purpose of obtaining a commercial advantage, since they are part
of the manufacture of a chemical substance for commercial purposes.
4.8.1 Confidentiality of Byproduct Information
Except for the byproduct source, any information reported in the byproducts section of
the section 8(a)(7) form can be claimed as confidential. For all of the data elements in this
section, upfront substantiation of the claim is required.
Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the associated information being submitted. Checking the CBI
box automatically triggers the substantiation questions. See Table 4-13 for substantiation
questions related to these data elements. If you do not check the CBI box for any information
element, then that information is not claimed as CBI and may be made public without
further notice to you. Further, if you fail to substantiate your CBI claims in accordance with the
statute and applicable rules, EPA may make the information available to the public without
further notice to you. For additional information about how to answer substantiation questions,
visit www,ena.gov/tsca-cbi on the EPA website.
4.8.2 Byproduct Name or Description
Report your chemical substance using the CA Index Name currently used to list the
chemical substance on the TSCA Inventory. You can identify the CA Index name by searching
SRS using a CASRN, the specific name of the chemical substance, or related acronyms. In the
event that an acronym is used for multiple chemical substances, you should take care to select
the correct substance. Using the search widget to select a substance will automatically populate
both the chemical name and chemical ID.
If the name of the byproduct is unknown, describe the byproduct. The description may be
a descriptive name, or you may describe the byproduct as specifically as possible. The
description you provide should accurately and precisely convey as much information about the
molecular structure of the byproduct as is known to you.
4.8.3 Byproduct Generic Chemical Name [if byproduct chemical name is CBI]
In cases where a chemical substance is listed on the confidential portion of the TSCA
Inventory, the generic chemical name will automatically be incorporated into your report when
you select the Accession Number.
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4.8.4 Byproduct Chemical ID
Every byproduct reported in accordance
with section 8(a)(7) requirements must be
accompanied by its correct CASRN,
corresponding to the chemical substance's
specific chemical name as described in Section
4.5.6. (40 CFR 705.15(e)(1)). You may use the
search widget to enter either a CASRN or the
specific name of the chemical substance to select
the appropriate CASRN/Chemical Abstracts
(CA) Index Name combination from the SRS
database. Using the search widget to select a
substance will automatically populate both the
chemical name and chemical ID.
In the case of a chemical substance listed
on the confidential portion of the TSCA Inventory, report the TSCA Accession Number as the
chemical identifying number.
If the chemical substance is not listed on the TSCA Inventory, report the CASRN if one
has been assigned to the chemical substance; report NKRA only if no CASRN or Accession
Number has been assigned or if you do not know and cannot reasonably ascertain the identity of
the chemical substance.
4.8.5 Byproduct Source
Indicate whether the byproduct was created as a result of manufacturing, processing, use,
and/or disposal. For example, a byproduct created unintentionally while manufacturing a PFAS
was created as a result of manufacturing. A byproduct created during management of the PFAS
waste, such as a combustion byproduct formed during thermal treatment, is considered to be
created as a result of disposal.
4.8.6 Byproduct Release
Indicate whether the byproduct(s) were released to the environment. Select yes, no, or
NKRA. For purposes of reporting under this section, "released to the environment" includes
quantities of the chemical disposed of in contained land disposal units such as underground
injection wells and landfills as well as releases directly to air, water, and soil.
4.8.7 Byproduct Release Medium
If the byproduct(s) were released to the environment, select all media to which the
byproducts(s) were released: air, water, or land. If unknown, select NKRA. If the byproduct was
not released, report "not applicable."
4.8.8 Byproduct Release Volume
Report the total weight of the byproduct released to all media, in pounds. Report
the quantity to at least two significant figures; it should be accurate to the extent known to
or reasonably ascertainable by you. Release volumes should be reported in numeric
format, without commas (e.g., 6352000). Report only the weight of the byproduct(s)
Report the correct CASRN for your chemical
substance if it is listed on the non-
confidential portion of the TSCA Inventory.
If your chemical substance is listed on the
confidential portion of the TSCA Inventory,
report the EPA-designated TSCA Accession
Number.
If your chemical substance is not on the
TSCA Inventory, report the CASRN if one
has been assigned. Report "NKRA" only if
no CASRN has been assigned to the
chemical substance or if the identity of the
byproduct is not known to or reasonably
ascertainable by you.
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released. Do not include the weight of other materials (e.g., water, solvents, containers, or
other chemical substances).
If the byproduct was not released, report "not applicable."
Table 4-18 provides some examples of facilities reporting byproduct information.
Table 4-18. Examples of Byproduct Reporting
I'xiimpk-
Reporting |
Example Company QR manufactures Example
PFAS QR and is completing the section 8(a)(7) form
for Example PFAS QR. During treatment of PFAS
QR-containing waste, the site produces 5.0 pounds
of hydrogen fluoride. 80% of the hydrogen fluoride
is captured by a dry scrubber and spent scrubber
medium is disposed of on site in a landfill. The
remaining 20% is directly released to air through the
site's stacks.
Example Company QR enters CAS # 7664-39-3 as a
byproduct. The section 8(a)(7) software populates
the CAS name for the chemical, hydrofluoric acid.
Company QR reports that the source of this
byproduct was disposal. The company reports that
the byproduct was released to air and land and 5.0
pounds were released.
Example Site ST manufactures Example PFAS ST
and is completing a section 8(a)(7) form for
Example PFAS ST. During manufacture of Example
PFAS ST, another chemical substance is formed that
is also a PFAS, Example PFAS UV. Most of PFAS
UV remains in the company's product, but 12
pounds of PFAS UV are released to air on site.
Example Site ST enters the CAS number and CA
name of Example PFAS UV and reports
manufacturing as its source. Example Site ST reports
that PFAS UV was released to air and that releases
totaled 12 pounds. Example Site ST also completes a
full section 8(a)(7) submission for Example PFAS
UV, including reporting these releases in Section G
of that reporting form.
Example Site WX manufactures Example PFAS
WX. The company knows that during on-site
processing of Example PFAS WX, a byproduct is
formed, but the company does not know the identity
of the byproduct. All of the byproduct produced
remains in the company's product and is distributed
into commerce.
Example Site WX reviews the information they
know and can reasonably ascertain and determines
that the specific chemical identity is unknown.
Example Site WX provides a description of the
byproduct and indicates "NKRA" for the Chemical
ID. Example Site WX indicates that the byproduct
was produced during processing and that the
byproduct was not released to the environment. The
site reports "N/A" for the byproduct release medium
and release volume.
Example Site YZ manufactures Example PFAS YZ.
During manufacture of Example PFAS YZ, two
byproducts are formed, Example PFAS AA and
Example PFAS BB. PFAS AA is separated from the
mixture and all 150 pounds produced are disposed of
in the site's on-site landfill. Most of PFAS BB
remains in the product and is distributed into
commerce. The company knows some amount of
PFAS BB is released to air on site but cannot
determine how much.
Example Site YZ first reports the chemical name and
CAS number for PFAS AA and indicates that PFAS
AA is produced during manufacturing. Site YZ
reports that 150 lb of PFAS AA are disposed of to
land. Next, Site YZ enters the name and CAS
number of PFAS BB as another byproduct. For
PFAS BB, the company reports its source as
manufacturing and reports that it is released, to air,
with total release quantity NKRA.
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4.9 Part II - Section E. All existing information concerning the
environmental and health effects of such substance or mixture
In this section, report all information concerning the environmental and health effects of
the substance or mixture that is known to or reasonably ascertainable by you. This information
includes but is not limited to:
• Toxicity information (e.g., in silico, in vitro, animal test results, human data); and
• Other data relevant to environmental and health effects including range-finding studies,
preliminary studies, OSHA medical screening or surveillance standards reports, adverse
effects reports.
4.9.1 Confidentiality of Environmental and Health Effects Information
Information reported in this section of the PFAS data reporting form can be claimed as
confidential, but reporters should note that TSCA section 14(b) places significant limitations on
confidentiality protections for information from health and safety studies. CBI claims for
environmental and health effects are only valid if they would disclose certain information related
to a company's process or operations used in the manufacturing of the chemical. For all of the
data elements in this section, upfront substantiation of the claim is required. For any
environmental or health effects information being claimed as CBI, you must also submit a
sanitized version (omitting only information that is claimed as confidential and appropriately
substantiated) of the study report or other attachment for public release.
Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the associated information being submitted. Checking the CBI
box automatically triggers the substantiation questions. See Table 4-13 for substantiation
questions related to these data elements. Further, if you fail to substantiate your CBI claims
and to provide a sanitized version of the report or attachment in accordance with the statute
and applicable rules, EPA may make the information available to the public without
further notice to you. For additional information about how to answer substantiation questions,
visit www,epa.gov/tsca-cbi on the EPA website. Redactions must be as sparing as possible. It is
your responsibility to ensure that any sanitized reports are thoroughly sanitized. EPA may
publicly release sanitized reports as provided by you. It is your responsibility to ensure you have
fully sanitized the report and that any changes or redactions cannot be reversed in the submitted
sanitized version.
4.9.2 OECD Harmonized Environmental and Health Effects Template (attachment)
Upload all known or reasonably ascertainable information concerning the environmental
and health effects of the substance or mixture, using OECD Harmonized Templates (OHTs) if
available for the endpoint being reported on. OHTs are available from the OECD website:
https://www.oecd.org ehs templates harmonised-templates.htm. This can be accomplished by
using the freely available IUCLID6 software (https://iuclid6.echo.europa.euf). exporting the
dossier in the OHT working context, and uploading via this rule's reporting tool. As of this
writing, EPA uses IUCLID6 v6.27.2; submitters using future IUCLID6 v7 can export their
dossier via the "Export to previous major version" function described in the IUCLID Manual
(https://iuclid6.echa.europa.en/documents/1387205/1809908/iuclid functionalities html en.pdf/
9d0lcb53-902d-dbb6-fb00-fal41688c395?t=1667168830907). Submitters using future versions
IUCLID6 v8 and higher (such as IUCLID7) should consult with EPA before submitting their
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data to confirm the current data format acceptance standards. EPA can accept any dossiers
generated using an earlier version of IUCLID6. You may already have data in this format if the
company has submitted the studies under the European Union's Registration, Evaluation,
Authorization and Restriction of Chemicals (REACH) regulation.
The reporting software will guide you through the process of uploading attachment(s).
4.9.3 Study Report (attachment)
Upload as attachment(s) any relevant study report(s). You are required to provide any test
data on the health and environmental effects of the PFAS in your possession or control, and a
description of any other health and environmental effects data on the substance known to or
reasonably ascertainable by you. Data in the possession or control of either a parent company or
an affiliated subsidiary located outside the U.S. are considered by the Agency to be data that
should be known to or reasonably ascertainable by a submitter.
Data must be submitted in English. Standard literature citations may be submitted for
data in the open scientific literature. Complete test data (not summaries) must be submitted if
they do not appear in the open literature. Incomplete reports (e.g., from ongoing studies) are
exempt from full reporting. However, you must describe the nature and objective of any
incomplete study, report, or test, the name and address of any laboratory developing the data;
progress to date; type of data collected; significant preliminary results; and an anticipated
completion date. If significant preliminary results or final results are obtained prior to the
submission deadline or any other additional information significant to the review of the notice
becomes available to you, you must submit this information. This includes reports from studies
not conducted by your company, such as studies commissioned by your company. The reporting
software will guide you through the process of uploading attachment(s). You may consider
developing and voluntarily submitting a robust study summary along with the record as EPA is
interested in the potential utility of this information to reduce the future burden of reporting, but
this may not be submitted in lieu of a full study report.
4.9.4 Supporting Information (attachment)
Upload as attachments any relevant supporting information. This section is intended for
you to provide any supporting information related to the study reports uploaded in the previous
section. Other data not related to the uploaded study reports will be uploaded in the "Other Data
Relevant to Environmental or Health Effects" section (i.e., section 4.9.6 below). The reporting
software will guide you through the process of uploading attachment(s).
4.9.5 Analytical/Test Methods
Use the text entry field to describe any and all known analytical or test methods for the
PFAS substance. If the method is an EPA method or is substantially similar to an EPA method,
you may state which EPA method is the basis of the test method used and clearly describe all
modifications. If the method is not an EPA method or substantially similar to an EPA method,
describe all steps of the method in as much detail as possible. Standard literature citations may
be submitted for test methods described in the open scientific literature. Complete method
descriptions (not summaries) must be submitted if they do not appear in the open literature.
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4.9.6 Other Data Relevant to Environmental or Health Effects
Provide, as attachments, any other data relevant to environmental or health effects not
published in a study report. Such information may include, but is not limited to, material safety
data sheets (SDS), information on physical/chemical properties, preliminary studies, range-
finding studies, OSHA medical screening or surveillance standards reports, adverse effects
reports, anonymized or aggregated informal test results in workers, underlying environmental
monitoring data, blood levels, or inhalation studies.
4.10 Part II - Section F. The number of individuals exposed, and
reasonable estimates of the number who will be exposed, to
such substance or mixture in their places of employment and
the duration of such exposure
In this section, report information concerning workers' exposure to the PFAS. Reporting
in this section includes information on the activities resulting in exposure, number of workers
exposed and the maximum duration of exposure, at the manufacturing site as well as industrial
users and commercial sites.
Information in this section may depend on knowledge of activities occurring at sites not
under your control. Recall that information provided under section 8(a)(7) reporting follows the
"known to or reasonably ascertainable" reporting standard, which may entail requesting
information from downstream users. Refer to Section 4.2 of this Guidance Document for a
discussion of the reporting standard.
4.10.1 Confidentiality of Worker Exposure Information
Information reported in the worker exposure section of section 8(a)(7) reporting can be
claimed as confidential. For all of the data elements in this section, upfront substantiation of the
claim is required.
Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the associated information being submitted. Checking the CBI
box automatically triggers the substantiation questions. See Table 4-13 for substantiation
questions related to these data elements. If you do not check the CBI box for any information
element, then that information is not claimed as CBI and may be made public without
further notice to you. Further, if you fail to substantiate your CBI claims in accordance with the
statute and applicable rules, EPA may make the information available to the public without
further notice to you. For additional information about how to answer substantiation questions,
visit www.ena.gov/tsca-cbi on the EPA website.
4.10.2 Worker Activity Descriptions
Describe the activities for workers at the manufacturing site. For example:
• Workers unload totes of the PFAS from delivery trucks into different containers in site
chemical storage area.
• Workers take samples of the product for QA/QC testing.
• Workers clean reaction vessels which contain residual PFAS product and reactants.
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4.10.3 Number of Workers Exposed at the Manufacturing Site
For each activity listed above, report the total number of workers reasonably likely to be
exposed to the reportable PFAS at the manufacturing site (40 CFR 711.15(g)). Select the code
corresponding to the appropriate range for the number of workers reasonably likely to be
exposed to the PFAS during manufacture. Table 4-19 lists the codes and ranges.
Table 4-19. Codes for Reporting Number of Workers Reasonably Likely to be Exposed
Cock'
Riiniicol'Workers Rc;inoii;iI)I\ l.ikclv to Ik* l-lxposod
W1
Fewer than 10 workers
W2
At least 10 but fewer than 25 workers
W3
At least 25 but fewer than 50 workers
W4
At least 50 but fewer than 100 workers
W5
At least 100 but fewer than 500 workers
W6
At least 500 but fewer than 1,000 workers
W7
At least 1,000 but fewer than 10,000 workers
W8
At least 10,000 workers
"Reasonably likely to be exposed" means "an exposure to a chemical substance which,
under foreseeable conditions of manufacture, processing, distribution in commerce, or use of the
chemical substance, is more likely to occur than not to occur. Such exposures would normally
include, but would not be limited to, activities such as charging reactor vessels, drumming, bulk
loading, cleaning equipment, maintenance operations, materials handling and transfers, and
analytical operations. Covered exposures include exposures through any route of entry
(inhalation, ingestion, skin contact, absorption, etc.), but excludes accidental or theoretical
exposures" (40 CFR 711.3).
Persons reasonably likely to be exposed to a chemical substance include workers whose
employment requires them to pass through areas where chemical substances are manufactured,
processed, or used (e.g., production workers and foremen, process engineers, and plant
managers). Workers employed to drive vehicles which transport the chemical substance should
be included in the number of workers reasonably likely to be exposed to the chemical substance
if they come into contact with the chemical substance during loading or unloading. For example,
workers engaged in the connection or disengagement of hoses used to load or unload the
chemical substance should be included. However, workers involved solely with transporting
chemical substances in sealed containers that are totally enclosed with no potential for exposure
should not be included.
In addition, when a site employs temporary, seasonal, or contract workers in the
manufacture of a reportable chemical substance, these workers should be included in the number
of workers reasonably likely to be exposed to a chemical substance if they work in areas where
the chemical substance is manufactured. The term does not include those employees whose jobs
are not associated with potential exposures to a chemical substance or mixture (e.g.,
administrative staff who never enter areas where the chemical substance is manufactured) and
who are unlikely to be exposed to a chemical substance for even a brief period of time.
No allowance is made for personal protective equipment or for engineering controls that
reduce but do not preclude exposure to a chemical substance; however, if contact between a
worker and a chemical substance is highly improbable, the worker should not be included among
those persons reasonably likely to be exposed to the chemical substance.
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Workers are considered to be exposed even if the chemical does not enter the body. For
instance, skin contact with a PFAS-containing article is considered an exposure if the worker
comes into contact with the PFAS, even if it is believed not to migrate from the article or is not
dermally absorbed.
There is no minimum duration or frequency of exposure for determining the number of
workers reasonably likely to be exposed to a chemical substance. If it is determined that a worker
is reasonably likely to be exposed at any time during the year for any length of time, this worker
should be included in the estimate.
There is no minimum level of exposure to a PFAS below which a worker need not be
counted among the number reasonably likely to be exposed to a chemical substance. Therefore,
if a company knows that a chemical substance manufactured at the site is present in the air
throughout the site, all workers at the site must be included in the number of workers reasonably
likely to be exposed to the chemical substance.
When there is no potential exposure to a chemical substance, the code W1 corresponding
to fewer than 10 workers would be reported. This would be the case, for instance, when a
chemical substance is imported in sealed containers and resold without repackaging or is shipped
from a foreign source directly to a customer.
Throughout this section, for clarity, the terms "exposed" and "exposure" are used to
mean "reasonably likely to be exposed" and "reasonably likely exposure."
4.10.4 Maximum Duration of Exposure for Manufacturing Workers
For each activity reported, indicate the maximum duration of exposure for any worker at
the manufacturing site in hours per day and the maximum number of days per year that workers
may be exposed. If workers have different lengths of exposure (for example, due to shift
schedules or different job roles), consider two scenarios: the worker(s) who have the longest
duration of exposure on any day of the year (called maximum daily exposure), and the worker(s)
who are exposed on the highest number of days per year (called maximum annual exposure). For
each of these workers, report the maximum duration of exposure on any single day as well as the
number of days per year that the worker is reasonably likely to be exposed. For each activity,
consider the following questions:
1. What worker or group of workers is exposed for the longest amount of time on any
one day doing this activity?
a. How long is that maximum amount of time that the worker or group of workers is
exposed doing this activity?
b. On how many days per year is this worker(s) exposed to the PFAS while doing
this activity?
2. What worker or group of workers is exposed on the largest number of days each year
doing this activity?
a. How many days per year is that worker or group of workers exposed doing this
activity?
b. What is the longest amount of time that worker(s) is exposed doing this activity
on any one day?
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Report maximum daily exposure to the nearest hour, except for workers exposed for less
than one hour. Report 1 hour for any worker exposed for less than one hour; do not round to
zero. If you know the duration of exposure to a greater degree of precision than the nearest hour,
report the more precise information. If work shifts at your site cross midnight, you may consider
the work shift to be one day (e.g., a worker who is exposed on one shift from 10 PM until 6 AM
the next day may be counted as one day of exposure and 8 hours of daily exposure). Recall that
in this section, you are reporting exposure by activity. If a worker at your site may be exposed to
the PFAS during multiple activities, report for each activity considering that activity alone, and
not any other activities.
Table 4-20 shows how companies would report in various example scenarios.
Table 4-20. Example manufacturing worker exposure scenarios
l''\|)OMIIV SlTllill'io
i:\posiiro lor «orkiT(s) «ith
iiiiixiiiiiiin (l;iih exposure
I'Apnsiiiv lor worki'i'(s) with
maximum annual exposure
Example Site CC has reported reaction
vessel clean-outs as an activity with
worker exposure to Example PFAS CC.
Production line workers perform one
thorough clean out per year, which takes
10 hours, and less-thorough monthly
clean-outs, which each take 5 hours, for
a total of 12 cleanings per year. The
same workers perform all cleanouts.
Report 10 hours as the
maximum daily exposure,
because this is the longest
duration of exposure for workers
on any single day. Report 12
days as the maximum annual
frequency, because these
workers are exposed up to 12
days per year.
In this case, this activity is only
done by one group of workers, so
the workers with the maximum
daily exposure are also the workers
with the maximum annual
exposure. Report 10 hours as the
maximum daily exposure and 12
days as the maximum annual
frequency.
At Example Site DD, workers may be
exposed to Example PFAS DD when
charging reactor vessels, a process that
usually takes one hour but sometimes
takes up to two hours. Reactor vessels
are charged every day and the site
operates 360 days per year, but no one
worker works more than 5 days per
week, or 260 days per year.
Report 2 hours as the maximum
daily exposure, because this is
the longest amount of time the
activity takes. Report 260 days
per year as the maximum annual
exposure, because any single
exposed worker may be exposed
up to 260 days per year.
In this case, this activity is only
done by one group of workers, so
the workers with the maximum
daily exposure are also the workers
with the maximum annual
exposure. Report 2 hours as the
maximum daily exposure and 260
days as the maximum annual
frequency.
Example Site EE imports Example
PFAS EE in sealed vessels, re-labels
the containers, and ships the containers
without repackaging. No workers are
expected to be exposed to PFAS EE.
Because no activities resulting in
worker exposure occurred,
report "N/A" for this section.
Because no activities resulting in
worker exposure occurred, report
"N/A" for this section.
Workers at Example Site FF are
reasonably expected to be exposed to
Example PFAS FF while charging
reactor vessels, which takes no more
than 3 hours. Reactor vessels are
charged every day. The site rotates
staff duties, so that no worker performs
reactor vessel charging more than one
day per week, or 52 times per year.
Line supervisors may also be briefly
exposed to PFAS FF during this
activity. Supervisory duties are split
equally between two workers, so that
each performs this duty 180 days per
year.
The workers with the maximum
daily exposure for this activity
are the workers actually
charging reaction vessels, who
may be exposed for up to 3
hours in a single day. Report 3
hours for the maximum daily
exposure in this section. These
workers are exposed up to 52
days per year, so report 52 days
as the maximum annual
exposure in this section.
The workers with the maximum
annual exposure for this activity
are the supervisors, who may each
be exposed for up to 180 days
during the year. These workers are
exposed for no more than 15
minutes on any given day. Report
1 hour (do not round exposures
less than one half-hour down to
zero) for the maximum daily
exposure and 180 days as the
maximum annual exposure in this
section.
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I'.xposuiT Scenario
I'Aposuiv I'm- \\
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Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
2. What worker or group of workers is exposed on the largest number of days each year
doing this activity?
a. How many days per year is that worker or group of workers exposed for this
TPU/IS/FC combination?
b. What is the longest amount of time that worker(s) is exposed for this TPU/IS/FC
combination?
Report maximum daily exposure to the nearest hour, except for workers exposed for less
than one hour. Report one hour for any worker exposed for less than one hour; do not round to
zero. If work shifts cross midnight, you may consider the work shift to be one day (e.g., a worker
who is exposed on one shift from 10 PM until 6 AM the next day may be counted as one day of
exposure and 8 hours of daily exposure). Recall that in this section, you are reporting exposure
by activity. If a worker at your site may be exposed to the PFAS during multiple activities, report
for each activity considering that activity alone, and not any other activities.
Table 4-21. Example industrial worker exposure scenarios
Kxposure Scenario
r.xposure lor worker(s) \\ it h
maximum exposure
|
Kxposure lorworker(s) with
maximum animal exposure
Example Site HH incorporates
Example PFAS HH into a
metalworking fluid. Site HH knows
that workers at its customers' facilities
may work with the metalworking fluid
for an entire shift and are reasonably
likely to be exposed to the PFAS during
this activity, which may occur on a
daily basis. Site HH also knows its
customers operate on 4xl0-hour shift
schedule, and therefore exposed
workers are likely to be exposed for up
to 10 hours per day, up to 4 days per
week, or 208 days per year.
Report 10 hours per day as the
maximum duration per day for
this this combination of Type of
Process or Use Operation,
Industrial Sector, and Function
Category. Report 208 days per
year as the maximum duration per
year.
In this case, this activity is only
done by one group of workers,
so the workers with the
maximum daily exposure are
also the workers with the
maximum annual exposure.
Report 10 hours as the
maximum daily exposure and
208 days as the maximum
annual frequency.
Example Site II manufactures
Example PFAS II and processes the
chemical on site. The site knows that
its processing activity is reasonably
expected to expose workers for no
more than 3 hours per day and occurs
on Monday and Thursday every week.
One group of production workers
performs the activity on Mondays and
a different group of workers performs
the activity on Thursdays. One
supervisor may also be exposed for no
more than one hour during the
activity. The same supervisor
oversees the activity every time it is
performed.
The workers with the most
exposure on any given day are the
production workers, who are
exposed for up to 3 hours per day.
Report 3 hours per day for the
workers with the maximum daily
exposure for this combination of
TPU, IS, and FC codes. Report 52
days as the maximum duration
per year for workers with the
maximum daily exposure for this
this combination of TPU, IS, and
FC codes, because no single
production worker is exposed
more than one day per week, or
52 days per year.
The worker with the largest
number of days of exposure is
the supervisor, who may be
exposed twice per week, or 104
days per year. The supervisor is
not exposed for more than one
hour per day during this
activity, so report 1 hour for
the maximum daily exposure
for the worker with maximum
annual exposure. Report 104
days per year for the maximum
annual frequency of exposure
for the worker with the
maximum daily exposure.
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Instructions for Completing Section 8(a)(7) Reporting
I'.xposuiT Scenario
r.xpoMirc lor norkcrts) \\ it h
|
K\|)ommv for wnrki'r(s) i|h
Example Site JJ imports a PFAS
chemical in an article. The PFAS
chemical is part of a non-stick coating
on the inside of equipment and
workers are not expected to have
physical contact with the internal non-
stick surface.
Report N/A for this combination
of TPU, IS, and FC codes.
Report N/A for this
combination of TPU, IS, and
FC codes.
4.10.7 Number of Workers Exposed for each Commercial Use
Report the total number of commercial workers, including those at sites not under your
control that are reasonably likely to be exposed while using the reportable chemical substance,
with respect to each commercial use (40 CFR 705.15(g)(5)). For each combination of
commercial Product Category and Function Category reported (Section 4.6), report the code
which corresponds to the appropriate range of commercial workers reasonably likely to be
exposed. Table 4-19 shows the codes for numbers of workers. See Section 4.10.3 for a
discussion of "reasonably likely to be exposed."
4.10.8 Maximum Duration of Exposure for Commercial Workers
For each unique combination of Product Category and Function Category, estimate the
maximum duration of exposure for workers that are reasonably likely to be exposed to the
chemical substance at sites that process or use the chemical substance. Include workers at sites
that are not under your control as well as those sites you control.
If workers have different lengths of exposure (for example, due to shift schedules or
different job roles), consider two scenarios: the worker(s) who have the longest duration of
exposure on any day of the year (called maximum daily exposure), and the worker(s) who are
exposed on the highest number of days per year (called maximum annual exposure). For each of
these workers, report the maximum duration of exposure on any single day as well as the number
of days per year that the worker is reasonably likely to be exposed. For each activity, consider
the following questions:
1. What worker or group of workers is exposed for the longest amount of time on any
one day for this combination of Product Category and Function Category?
a. How long is that maximum amount of time that the worker or group of workers is
exposed for this PC/FC combination?
b. On how many days per year is this worker(s) exposed to the PFAS for this PC/FC
combination?
2. What worker or group of workers is exposed on the largest number of days each year
doing this activity?
a. How many days per year is that worker or group of workers exposed for this
PC/FC combination?
b. What is the longest amount of time that worker(s) is exposed for this PC/FC
combination?
Report maximum daily exposure to the nearest hour, except for workers exposed for less
than one hour. Report one hour for any worker exposed for less than one hour; do not round to
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Instructions for Completing Section 8(a)(7) Reporting
zero. If work shifts cross midnight, you may consider the work shift to be one day (e.g., a worker
who is exposed on one shift from 10 PM until 6 AM the next day may be counted as one day of
exposure and 8 hours of daily exposure). Recall that in this section, you are reporting exposure
by activity. If a worker may be exposed to the PFAS during multiple activities, report for each
activity considering that activity alone, and not any other activities.
Table 4-22. Example commercial worker exposure scenarios
Kxposure Scenario
Kxposure for\\orkcr(s) with
maximum riuilx exposure
I'lxposuiv lor workers) n it h
maximum iinnual exposure
Example Company KK
incorporates Example PFAS KK
into a lubricating wax. Many of its
customers are sporting good rental
and repair shops, including ski
shops and bike shops. Company
KK knows that workers are likely
exposed to the PFAS when
applying lubricating waxes to
equipment, an activity that may be
done intermittently throughout a
shift. Company KK knows from
discussions with its customers that
ski shops use the wax daily during
the ski season, and that workers
work up to 12 hour shifts up to 5
days per week during this 20-week
season; the shops are closed the rest
of the year. Bike shops using these
products operate with shifts no
longer than 10 hours long, up to 5
days per week year round.
The ski shop workers in this
scenario have the longest
maximum exposure on any given
day and should be considered the
workers with the maximum daily
exposure. The ski shop workers
work up to 12 hours at a time.
Although exposure is intermittent,
these workers may be exposed
throughout the 12 hour shift.
Company KK reports 12 hours as
the maximum daily exposure. The
ski shop workers work up to 100
days per year, so Company KK
reports 100 days per year as the
maximum annual exposure for the
workers with the maximum daily
exposure.
The bike shop workers in this
scenario are exposed for the most
days per year and should be
considered the workers with the
maximum annual exposure. Bike
shop workers work up to 10 hours
at a time. Although exposure is
intermittent, these workers may be
exposed throughout the 10 hour
shift. Company KK reports 10
hours as the maximum daily
exposure for the workers with
maximum annual exposure. The
bike shop workers work up to 260
days per year, so Company KK
reports 260 days per year as the
maximum annual exposure.
Example Company LL uses PFAS
LL as a stain-resistant coating for
carpets sold to commercial
customers. Company LL knows
from news reports that PFAS from
coated carpets can be released into
indoor air and dust over time,
resulting in worker exposure.
Company LL assumes that its
commercial customers operate
with 8 hours shifts and that
workers work five days per week,
52 weeks per year.
Example Company LL estimates
that workers in commercial
customers using its carpets are
exposed for eight hours per day,
five days per week. Example
Company LL reports 8 hours as
the maximum daily exposure and
260 days as the maximum annual
exposure for workers with the
maximum daily exposure.
In this case, this Product
Category /Function Category for
Example PFAS LL is only done by
one group of workers, so the
workers with the maximum daily
exposure are also the workers with
the maximum annual exposure.
Company LL reports 8 hours as
the maximum daily exposure and
260 days as the maximum annual
exposure for workers with the
maximum annual exposure.
Example Site MM produces a
PFAS-coated part used in
commercial machines. The PFAS
is not expected to produce any
emissions or migrate from the
coating under normal conditions
of use.
Site MM reports 0 hours per day
and 0 days per year, as workers
are not expected to be exposed for
any amount of time.
Site MM reports 0 hours per day
and 0 days per year, as workers are
not expected to be exposed for any
amount of time.
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Instructions for Completing Section 8(a)(7) Reporting
4.11 Part II - Section G. The manner or method of its
disposal, and in any subsequent report on such substance
or mixture, any change in such manner or method
4.11.1 Confidentiality of Disposal Information
Information reported in the disposal section of the section 8(a)(7) reporting form can be
claimed as confidential if it is not already public information. For all of the data elements in this
section, upfront substantiation of the claim is required.
Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the associated information being submitted. Checking the CBI
box automatically triggers the substantiation questions. See Table 4-13 for substantiation
questions related to these data elements. If you do not check the CBI box for any information
element, then that information is not claimed as CBI and may be made public without
further notice to you. Further, if you fail to substantiate your CBI claims in accordance with the
statute and applicable rules, EPA may make the information available to the public without
further notice to you. For additional information about how to answer substantiation questions,
visit www.ena.gov/tsca-cbi on the EPA website.
4.11.2 Manner or Method of Disposal
If the PFAS is disposed of, report the method of disposal using a code or codes from
Table 4-23. Report all disposal controlled by the site (e.g., include shipments of waste for
disposal to third parties). You are not required to report disposal by downstream users. Provide
additional description of the disposal method as needed; additional description is required for
code D99 "other." For each year, report any disposal methods(s) used during that year. You will
be prompted to and are required to report disposal in any year from 2011 to 2022, even if you did
not manufacture the PFAS in each year. For example, if you manufactured a PFAS in 2014,
2015, and 2016, and disposed of remaining waste containing that PFAS in 2017, you must
include the disposal that occurred in 2017 even though you did not manufacture the PFAS that
year.
If the PFAS is not disposed of in a given year, select "N/A" for that year. If you do not
know and cannot reasonably ascertain whether the PFAS is disposed of, or if you know the
PFAS is disposed of but do not know and cannot reasonably ascertain the method of disposal,
select "NKRA."
Table 4-23. Disposal Process codes
(ode
Description
D1
On-site land disposal: RCRA Class C landfill (hazardous)
D2
On-site land disposal: Other landfill
D3
Other on-site land disposal
D4
On-site underground injection (UIC)
D5
Off-site land disposal: RCRA Class C landfill (hazardous)
D6
Off-site land disposal: Other landfill
D7
On-site incineration
D8
Off-site incineration
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Code
Description
D9
Publicly owned treatment works (POTW)
D10
Other off-site waste transfer
Dll
On-site release to surface water
D12
On-site release to air (stack emissions)
D13
On-site release to air (fugitive emissions)
D99
Other
4.11.3 Changes in Disposal Methods
Use the free text field to describe any changes to the disposal process or methods since
January 1, 2011.
4.11.4 Release Quantity
Report the total weight of the PFAS released to each medium (i.e., air, water, or
land) in pounds. Report the quantity to at least two significant figures; it should be
accurate to the extent known to or reasonably ascertainable by you. Release volumes
should be reported in numeric format, without commas (e.g., 6352000). Report only the
weight of the specific PFAS released. Do not include the weight of any other materials
(e.g., water, solvents, containers, or other chemical substances). Consider all possible
sources of releases, including treated waste streams. For example, incineration of PFAS
waste may not fully destroy the PFAS and there may be air releases of the PFAS
associated with this process.
Table 4-24. Release media for disposal codes
('ode
Description
Kclcitsc Medium
D1
On-site land disposal: RCRA Class C landfill (hazardous)
Land
D2
On-site land disposal: Other landfill
Land
D3
Other on-site land disposal
Land
D4
On-site underground injection (UIC)
Land
D5
Off-site land disposal: RCRA Class C landfill (hazardous)
Land
D6
Off-site land disposal: Other landfill
Land
D7
On-site incineration
If combustion is incomplete, PFAS
may remain in stack air emissions,
ash, or scrubber blowdown, filter
material, etc., and may be released
to any medium
D8
Off-site incineration
Report off-site release media to the
extent known to or reasonably
ascertainable by you.
D9
Publicly owned treatment works (POTW)
Water
D10
Other off-site waste transfer
Report off-site release media to the
extent known to or reasonably
ascertainable by you.
Dll
On-site release to surface water
Water
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(ode
Description
Kclciisi' Medium
D12
On-site release to air (stack emissions)
Air
D13
On-site release to air (fugitive emissions)
Air
D99
Other
4.11.5 Incineration Quantity and Temperature
Report the total weight of the PFAS incinerated on-site each year. If on-site incineration
occurred, also report the incineration temperature (in degrees Celsius). If incineration occurred at
multiple temperatures, indicate the minimum temperature (in degrees Celsius) at which the
PFAS was incinerated. Report only the weight of PFAS destroyed by incineration. Quantities of
PFAS not destroyed (e.g., released to air or remaining in ash) should be reported as releases in
the previous section.
4.12 Optional Information
This section consists of a text field for submitting additional information. Use this field to
provide any additional information about your submission that may be relevant.
4.13 Joint Submissions
4.13.1 Determining the Need for a Joint Submission
Joint submissions are required in those instances where a company (e.g., foreign supplier,
contracting company) will not disclose to the manufacturer (including importer) certain chemical
substance identifiers (i.e., CASRN, Accession number, or LVE number), due to confidentiality
concerns.
This may happen, for instance, when a company is importing a mixture under a trade
name, and the foreign manufacturer refuses to reveal the chemical identity of a confidential
component of the mixture. In this case, the importer and the supplier can each separately report
their portion of the required information, resulting in a joint submission. The importer must ask
the supplier of the confidential chemical substance to directly provide EPA with the correct
chemical identity (see 40 CFR 705.15(b)(iii)).
A manufacturer (including importer) can identify, on a chemical-by-chemical basis, the
supplier for a chemical substance. The reporting tool will generate a unique ID number for each
chemical substance (identified by a trade name). Therefore, a supplier may receive multiple ID
numbers from a manufacturer (including importer). A supplier may also report multiple chemical
substances under one ID number in the case that the ID number refers to a mixture. In that
situation, the supplier will be identifying the PFAS that comprise the mixture.
It is the responsibility of the primary submitter to ask its supplier, or secondary submitter,
to send the information to EPA by the end of the submission period. The reporting tool leads the
primary submitter through this notification process.
If the secondary submitter decides to provide the required trade name product
information directly to you, you should change your submission type and submit a single
submission.
Note that not all submitters are required to initiate joint submissions. Article importers
using the article importer reporting form will not be required or have the option to initiate joint
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submissions. Additionally, if a secondary submitter is not known or reasonably ascertainable to
the PFAS manufacturer (e.g., if a foreign supplier is no longer in business and has no successor
entity), then the manufacturer would indicate that the secondary submitter is NKRA and need not
initiate a joint submission.
4.13.2 The Primary Submission is Completed by the PFAS Manufacturer
The primary submitter for a joint submission is either an importer or a manufacturer of a
PFAS of unknown chemical identity (i.e., CASRN, TSCA Accession number, or LVE number).
For ease of presentation, both types of primary submitters will be referred to as "importer." The
importer, as the primary submitter, is responsible for initiating the joint submission. The importer
uses the reporting tool to notify the secondary submitter (e.g., its supplier or contract
manufacturer) of the need to complete the secondary portion of the joint submission, and
completes the sections related to manufacturing (Part II. A - C), processing and use (Part II.D),
byproducts (Part II.D), environmental and health effects (Part HE), (40 CFR 705.15(f)) and the
processing and use-related section (Part II.D) (40 CFR 705.15(c)) for the imported substance.
Identifying the chemical identity of the unknown chemical substance and its secondary
submitter
In its portion of the joint submission, the primary submitter identifies the proprietary
substance or mixture using the trade name or another name, additional information as needed to
help the secondary submitter correctly identify the substance, and the identity and contact
information for the secondary submitter. See Sections 4.4.2 and 4.5.11 for additional
information.
Notifying the secondary submitter about the joint submission
Using the reporting tool, the importer enters the email address of the secondary submitter,
and any necessary instruction for the secondary submitter to complete its part of the joint
submission, into a system generated email. Also contained within the email is the unique
identifier. The importer will need to click the link to send this information from CDX to the
Secondary Authorized Official. Additional recipients may be added by the importer. The
primary submitter may send the email before it has completed its part of the joint submission.
Completing the primary portion of the joint submission
The importer is responsible for completing the rest of Part II of the form as it relates to
the proprietary substance or mixture. See Sections 4.7 through 4.12 of this document for
additional information about completing Part II.
4.13.3 The Secondary Submission is Completed
The secondary submitter is responsible for identifying that it is providing information for
the joint submission using the information (e.g., identification number) provided by the primary
submitter and completing the Secondary Form.
4.13.3.1 Receiving notification from the primary submitter about the joint submission
The secondary submitter receives an email from the primary submitter identifying that a
joint submission has been initiated and providing the unique identification number needed for
the secondary submitter to complete its part of the joint submission.
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4.13.3.2 Completing the Secondary Form, the secondary portion of the joint
submission
The secondary submitter is responsible for completing the Secondary Form of the joint
submission, which includes its company identity, a technical contact, identification of its
customer (i.e., the primary submitter), the product trade name, and the unique identifier supplied
by the primary submitter. The secondary submitter then provides the chemical identity and
percentage of formulation of each PFAS in the product. See Section 4.5 for information about
chemical identity.
For specific instructions on how to report using the reporting tool, see the section 8(a)(7)
Online Reporting Guide, available on the TSCA website at https://www.ena.gov/assessing-and-
managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping.
4.13.3.3 When the Supplier Doesn't Know the Chemical Identity
There may be instances where a foreign supplier (i.e., secondary submitter) purchases a
mixture, under a trade name, from another company (tertiary company) and does not know the
chemical components of the mixture. The foreign supplier can ask the company manufacturing
the trade secret mixture or chemical substance to directly provide EPA with the correct chemical
identity. In this case, the tertiary company would register with CDX and use the Unique
Identifier for Joint Submissions, sent to the foreign supplier by the manufacturer (including
importer), to complete the form.
Under this scenario, the foreign supplier does not have access to any of the information
submitted to EPA by the tertiary company. Likewise, the tertiary company cannot see the
information the foreign supplier reports to EPA. This way, the confidentiality of information for
both the foreign supplier and tertiary company is protected.
4.13.4 Confidentiality of Information Jointly Submitted
All of the confidentiality requirements discussed earlier in these Instructions apply to
information submitted jointly. However, joint submissions include information required to
connect the two reports and their related data. For example, a joint submission requires that the
primary submitter provide a generic chemical name or trade name and secondary submitter's
identity. A secondary submitter would provide the composition of its product.
These data elements specific to joint submissions require that any claims of
confidentiality be asserted at the time of submission, but do not require upfront substantiation
(pursuant to TSCA section 14(c)(2)):
• Joint submission information from the primary submitter consisting of trade name and
supplier identification required pursuant to § 705.15(b)(l)(i) and § 705.18(b)(2)(i).
• Joint submission information from the secondary submitter consisting of the percentage
of formulation required pursuant to § 705.15(b)(l)(i) and (ii).
Because signatures are required by each party of a joint submission, each party must
register with CDX and complete their own sections of the same report. The reporting tool will
match both submissions based upon the unique ID number sent by the manufacturer (including
importer) to notify the secondary submitter of the partial section 8(a)(7) submission. Suppliers do
not have access to any of the information submitted to EPA by the manufacturer (except the
manufacturer's identity and contact information and the submitted trade name or chemical
identifier) . Likewise, manufacturers cannot see the information that the supplier reports to EPA.
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This way, the confidentiality of information for all submitters is protected. The information
provided by both submitters will be combined and processed as one joint submission once they
are received by EPA.
NOTE: In the event that a manufacturer (including importer) actually knows or can
reasonably ascertain the chemical identity (e.g., the CASRN or Accession Number) of a
chemical substance subject to section 8(a)(7) reporting, the manufacturer (including
importer) must provide that information irrespective of a supplier's confidentiality claims.
If such a primary submitter wishes to claim the chemical identity as confidential, to do so
they must check the CBI box and provide upfront substantiation as described in 4.5.1 of
this chapter.
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Chapter 5
How to Obtain Copies of Documents Cited in This Instructions Document
5. How to Obtain Copies of Documents Cited in
This Instructions Document
5.1 Obtaining Copies of the TSCA Rules
The section 8(a)(7) rule, 40 CFR 705, is available on the U.S. Government Publishing Office
website, www.ecfr.sov.
You may also contact the TSCA Hotline by telephone at (202) 554-1404 or by email tsca-
hotline@epa.gov for assistance.
5.2 Obtaining Copies of Other Information Materials
EPA has developed documents to provide additional information on submitting information for
this data call. Except where otherwise noted, materials are available on the section 8(a)(7) website at
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-
recordkeeping. In addition to materials developed specifically for section 8(a)(7) reporting, some
materials developed for TSCA more broadly or for CDR reporting are also applicable to reporting
under this data call.
Reporting Electronically:
• Instructions on CDX regi strati on: CDX Online Registration User Guide
• Section 8(a)(7) reporting tool getting started user guide
Some fact sheets Fact Sheets for CDR are relevant to section 8(a)(7) reporting. These fact sheets are
available at How To Report Under Chemical Data Reporting. CDR fact sheets relevant to reporting
under this data call include:
• Reporting After Changes to Company Ownership or Legal Identity
• Imported Articles (use this fact sheet as guidance in determining if your chemical substance is
contained in an article; other items discussed in this fact sheet, such as references to reporting
thresholds and polymer exemption, do not apply to this data call)
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Appendix A
Glossary of Terms
Appendix A. Glossary of Terms
The definitions and descriptions of terms used in section 8(a)(7) reporting provided
below are taken from 40 CFR Part 711 unless otherwise noted.
Act means the Toxic Substances Control Act, as amended, 15 U.S.C. 2601 etseq.
Administrator means the Administrator of the Environmental Protection Agency. (See
TSCA 3(1))
Article means a manufactured item (1) which is formed to a specific shape or design
during manufacture, (2) which has end-use function(s) dependent in whole or in part upon its
shape or design during end use, and (3) which has either no change of chemical composition
during its end use or only those changes of composition which have no commercial purpose
separate from that of the article, and that result from a chemical reaction that occurs upon end
use of other chemical substances, mixtures, or articles; except that fluids and particles are not
considered articles regardless of shape or design. (40 CFR 704.3)
Byproduct means a chemical substance produced without separate commercial intent
during the manufacture, processing, use, or disposal of another chemical substance(s) or
mixture(s). (40 CFR 704.3)
Central Data Exchange (CDX) means EPA's centralized electronic document receiving
system, or its successors, including associated instructions for registering to submit electronic
documents.
Chemical Information Submission System (CISS) means EPA's electronic, web-based
reporting tool for the completion and submission of data, reports, and other information, or its
successors.
Chemical substance means any organic or inorganic substance of a particular molecular
identity, including any combination of such substances occurring in whole or in part as a result
of a chemical reaction or occurring in nature, and any element or uncombined radical.
"Chemical substance" does not include:
(1) Any mixture;
(2) Any pesticide (as defined in the Federal Insecticide, Fungicide, and Rodenticide Act)
when manufactured, processed, or distributed in commerce for use as a pesticide;
(3) Tobacco or any tobacco product;
(4) Any source material, special nuclear material, or byproduct material (as such terms
are defined in the Atomic Energy Act of 1954 [42 U.S.C. 2011 et seq.] and the regulations
issued under such Act);
(5) Any article the sale of which is the subject to the tax imposed by section 4181 of the
Internal Revenue Code of 1986 [26 U.S.C. 4181] (determined without regard to any exemptions
from such tax provided by section 4182 or 4221 or any other provision of such Code) and any
component of such an article (limited to shot shells, cartridges, and components of shot shells
and cartridges); and
(6) Any food, food additive, drug, cosmetic, or device (as such terms are defined in
section 201 of the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 321]) when manufactured,
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Appendix A
Glossary of Terms
processed, or distributed in commerce for use as a food, food additive, drug, cosmetic, or
device. (See TSCA 3(2))
Commerce means trade, traffic, transportation, or other commerce: (A) between a place
in a State and any place outside of such State, or (B) which affects trade, traffic, transportation,
or commerce described in clause (A). (TSCA 3(3))
Commercial use means the use of a chemical substance or a mixture containing a
chemical substance (including as part of an article) in a commercial enterprise providing
saleable goods or services.
Consumer use means the use of a chemical substance or a mixture containing a
chemical substance (including as part of an article) when sold to or made available to
consumers for their use.
Customs territory of the United States, as referenced in TSCA section 3 and defined
in general note 2 of the Harmonized Tariff Schedule of the United States, includes only the
States, the District of Columbia, and Puerto Rico.
Distribute in commerce and distribution in commerce, when used to describe an
action taken with respect to a chemical substance or mixture or article containing a substance or
mixture mean to sell, or the sale of, the substance, mixture, or article in commerce; to introduce
or deliver for introduction into commerce, or the introduction or delivery for introduction into
commerce of, the substance, mixture, or article; or to hold, or the holding of, the substance,
mixture, or article after its introduction into commerce. (TSCA 3(5))
Environmental or health effects information means any information of any effect of a
chemical substance or mixture containing a chemical substance on health or the environment or
on both. This includes all health and safety studies.
(1) Not only is information that arises as a result of a formal, disciplined study included,
but other information relating to the effects of a chemical substance or mixture containing a
chemical substance on health or the environment is also included. Any information that bears on
the effects of a chemical substance on health or the environment would be included.
(2) Examples are:
(i) Long- and short-term tests of mutagenicity, carcinogenicity, or teratogenicity; data on
behavioral disorders; dermatoxicity; pharmacological effects; mammalian absorption,
distribution, metabolism, and excretion; cumulative, additive, and synergistic effects; and acute,
subchronic, and chronic effects.
(ii) Tests for ecological or other environmental effects on invertebrates, fish, or other
animals, and plants, including: Acute toxicity tests, chronic toxicity tests, critical life-stage tests,
behavioral tests, algal growth tests, seed germination tests, plant growth or damage tests,
microbial function tests, bioconcentration or bioaccumulation tests, and model ecosystem
(microcosm) studies.
(iii) Assessments of human and environmental exposure, including workplace exposure,
and impacts of a particular chemical substance or mixture containing a chemical substance on
the environment, including surveys, tests, and studies of: Biological, photochemical, and
chemical degradation; structure/activity relationships; air, water, and soil transport;
biomagnification and bioconcentration; and chemical and physical properties, e.g., boiling
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Appendix A
Glossary of Terms
point, vapor pressure, evaporation rates from soil and water, octanol/water partition coefficient,
and water solubility.
(iv) Monitoring data, including but not limited to when they have been aggregated and
analyzed to measure the exposure of humans or the environment to a chemical substance or
mixture containing a chemical substance. (40 CFR 705.15)
EPA means the United States Environmental Protection Agency. (40 CFR 704.3)
Health and safety studies means any study of any effect of a chemical substance or
mixture on health or the environment or on both, including underlying information and
epidemiological studies, studies of occupational exposure to a chemical substance or mixture,
toxicological, clinical, and ecological studies of a chemical substance or mixture containing a
chemical substance, and any test performed under TSCA. [15 U.S.C. 2602(8)]
Highest-level Parent Company means the highest-level company of the site's ownership
hierarchy as of the start of the submission period during which data are being reported according
to the following instructions. The highest-level U.S. parent company is located within the United
States while the highest-level foreign parent company is located outside the United States. The
following rules govern how to identify the highest-level U.S. parent company and highest-level
foreign parent company (if applicable):
(1) If the site is entirely owned by a single U.S. company that is not owned by another
company, that single company is the U.S. parent company.
(2) If the site is entirely owned by a single U. S. company that is, itself, owned by another
U.S.-based company (e.g., it is a division or subsidiary of a higher-level company), the highest-
level domestic company in the ownership hierarchy is the United States parent company. If there
is a higher-level parent company that is outside of the United States, the highest-level foreign
company in the ownership hierarchy is the foreign parent company.
(3) If the site is owned by more than one company (e.g., company A owns 40 percent,
company B owns 35 percent, and company C owns 25 percent), the company with the largest
ownership interest in the site is the parent company. If a higher-level company in the ownership
hierarchy owns more than one ownership company, then determine the entity with the largest
ownership by considering the lower-level ownerships in combination (e.g., corporation X owns
companies B and C, for a total ownership of 60 percent for the site).
(4) If the site is owned by a 50:50 joint venture or a cooperative, the joint venture or
cooperative is its own parent company. If the site is owned by a U.S. joint venture or cooperative,
the highest level of the joint venture or cooperative is the U.S. parent company. If the site is
owned by a joint venture or cooperative outside the United States, the highest level of the joint
venture or cooperative outside the United States is the foreign parent company.
(5) If the site is federally owned, the highest-level federal agency or department is the U.S.
parent company.
(6) If the site is owned by a non-federal public entity, that entity (such as a municipality,
State, or tribe) is the U.S. parent company.
Importer means
(1) any person who imports any chemical substance or any chemical substance as part of
a mixture or article into the customs territory of the United States, and includes:
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Appendix A
Glossary of Terms
(1) the person primarily liable for the payment of any duties on the merchandise, or
(ii) an authorized agent acting on his/her behalf.
(2) Importer also includes, as appropriate:
(i) The consignee.
(ii) The importer of record.
(iii) The actual owner if an actual owner's declaration and superseding bond have been
filed in accordance with 19 CFR 141.20.
(iv) The transferee, if the right to draw merchandise in a bonded warehouse has been
transferred in accordance with subpart C of 19 CFR part 144.
(3) For the purposes of this definition, the customs territory of the United States consists
of the 50 States, Puerto Rico, and the District of Columbia. (40 CFR 704.3)
Impurity means a chemical substance which is unintentionally present with another
chemical substance. (40 CFR 704.3)
Industrial function means the intended physical or chemical characteristic for which a
chemical substance or mixture is consumed as a reactant; incorporated into a formulation,
mixture, reaction product, or article; repackaged; or used.
Industrial use means use at a site at which one or more chemical substances or mixtures
are manufactured (including imported) or processed.
Intended for use by children means the chemical substance or mixture is used in a
product that is specifically intended for use by children age 14 or younger. A chemical
substance or mixture is intended for use by children when the submitter answers "yes" to at
least one of the following questions for the product into which the submitter's chemical
substance or mixture is incorporated:
(1) Is the product commonly recognized (i.e., by a reasonable person) as being intended
for children aged 14 or younger?
(2) Does the manufacturer of the product state through product labeling or other written
materials that the product is intended or will be used by children age 14 or younger?
(3) Is the advertising, promotion, or marketing of the product aimed at children age 14
or younger?
Intermediate means any chemical substance that is consumed, in whole or in part, in
chemical reactions used for the intentional manufacture of other chemical substances or
mixtures, or that is intentionally present for the purpose of altering the rates of such chemical
reactions. (40 CFR 704.3)
Known to or reasonably ascertainable by means all information in a person's
possession or control, plus all information that a reasonable person similarly situated might be
expected to possess, control, or know. (40 CFR 704.3)
Manufacture means to manufacture, produce, or import, for commercial purposes.
Manufacture includes the extraction, for commercial purposes, of a component chemical
substance from a previously existing chemical substance or complex combination of substances.
A chemical substance is co-manufactured by the person who physically performs the
manufacturing and the person contracting for such production when that chemical substance,
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Appendix A
Glossary of Terms
manufactured other than by import, is: (1) produced exclusively for another person who
contracts for such production, and (2) that other person dictates the specific identity of the
chemical substance and controls the total amount produced and the basic technology for the
manufacturing process. [15 U.S.C. 2602(9)]
Manufacturer means a person who manufactures a chemical substance.
Manufacture for commercial purposes means: (1) to import, produce, or manufacture
with the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer, and includes among other things, such "manufacture" of any amount of a
chemical substance or mixture:
(i) For commercial distribution, including for test marketing.
(ii) For use by the manufacturer, including use for product research and development, or
as an intermediate.
(2) Manufacture for commercial purposes also applies to substances that are produced
coincidentally during the manufacture, processing, use, or disposal of another substance or
mixture, including both byproducts that are separated from that other substance or mixture and
impurities that remain in that substance or mixture. Such byproducts and impurities may, or
may not, in themselves have commercial value. They are nonetheless produced for the purpose
of obtaining a commercial advantage since they are part of the manufacture of a chemical
product for a commercial purpose. (40 CFR 704.3)
Master Inventory File means EPA's comprehensive list of chemical substances which
constitute the Chemical Substances Inventory compiled under section 8(b) of the Act. It
includes substances reported under 40 CFR Part 710 and substances reported under Part 720 for
which a Notice of Commencement of Manufacture or Import has been received under §
720.120.
Microorganism means any combination of chemical substances that is a living
organism and that meets the definition of microorganism at 40 CFR 725.3. Any chemical
substance produced from a living microorganism is reportable under the CDR regulation unless
otherwise excluded.
Mixture means any combination of two or more chemical substances if the combination
does not occur in nature and is not, in whole or in part, the result of a chemical reaction; except
that such term does include any combination which occurs, in whole or in part, as a result of a
chemical reaction if none of the chemical substances comprising the combination is a new
chemical substance and if the combination could have been manufactured for commercial
purposes without a chemical reaction at the time the chemical substances comprising the
combination were combined. (TSCA 3(10))
Naturally occurring substance is any chemical substance which is naturally occurring
and: (1) which is (i) unprocessed or (ii) processed only by manual, mechanical, or gravitational
means, by dissolution in water, by flotation, or by heating solely to remove water; or (2) which
is extracted from air by any means. (40 CFR 710.4(b))
Non-isolated intermediate means any intermediate that is not intentionally removed
from the equipment in which it is manufactured, including the reaction vessel in which it is
manufactured, equipment which is ancillary to the reaction vessel, and any equipment through
which the substance passes during a continuous flow process, but not including tanks or other
vessels in which the substance is stored after its manufacture. (40 CFR 704.3)
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Appendix A
Glossary of Terms
Parent Company is a company that owns or controls another company. (40 CFR 704.3)
Per- and polyfluoroalkyl substances or PFAS, means any chemical substance or
mixture containing a chemical substance that structurally contains at least one of the following
three sub-structures:
1. R-(CF2)-CF(R')R", where both the CF2 and CF moieties are saturated carbons
2. R-CF2OCF2-R', where R and R' can either be F, O, or saturated carbons
3. CF3C(CF3)R'R", where R' and R"" can either be F or saturated carbons. (40 CFR
705.15)
Person means any individual, firm, company, corporation, joint venture, partnership,
sole proprietorship, association, or any other business entity; any State or political subdivision
thereof, or any municipality; any interstate body; and any department, agency, or
instrumentality of the Federal government. (40 CFR 704.3)
Polymer means any chemical substance described with the word fragments "*polym*",
"*alkyd", or "oxylated" in the Chemical Abstracts (CA) Index Name in the Master Inventory
File, where the asterisk (*) in the listed word fragments indicates that any sets of characters may
precede, or follow, the character string defined. Polymers also include any chemical substance
which is identified in the Master Inventory File as siloxane(s) and silicone(s), silsesquioxane(s),
a protein (albumin, casein, gelatin, gluten, hemoglobin), an enzyme, a polysaccharide (starch,
cellulose, or gum), rubber, or lignin. The polymer exclusion does not apply to a polymeric
substance that has been hydrolyzed, depolymerized, or otherwise chemically modified, except
in cases where the intended product of this reaction is totally polymeric in structure.
Possession or control means in possession or control of the submitter, or of any
subsidiary, partnership in which the submitter is a general partner, parent company, or any
company or partnership which the parent company owns or controls, if the subsidiary, parent
company, or other company or partnership is associated with the submitter in the research,
development, test marketing, or commercial marketing of the chemical substance in question.
(A parent company owns or controls another company if the parent owns or controls 50 percent
or more of the other company's voting stock. A parent company owns or controls any
partnership in which it is a general partner). Information is included within this definition if it
is:
(1) In files maintained by submitter's employees who are:
(1) Associated with research, development, test marketing, or commercial marketing of
the chemical substance in question.
(ii) Reasonably likely to have such data.
(2) Maintained in the files of other agents of the submitter who are associated with
research, development, test marketing, or commercial marketing of the chemical substance in
question in the course of their employment as such agents. (40 CFR 705.15)
Process means to process for commercial purposes. (40 CFR 704.3)
Process for commercial purposes means the preparation of a chemical substance or
mixture after its manufacture for distribution in commerce with the purpose of obtaining an
immediate or eventual commercial advantage for the processor. Processing of any amount of a
chemical substance or mixture is included in this definition. If a chemical substance or mixture
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Appendix A
Glossary of Terms
containing impurities is processed for commercial purposes, then the impurities also are
processed for commercial purposes. (40 CFR 704.3)
Processor means any person who processes a chemical substance or mixture. (40 CFR
704.3)
Reasonably likely to be exposed means an exposure to a chemical substance which,
under foreseeable conditions of manufacture (including import), processing, distribution in
commerce, or use of the chemical substance, is more likely to occur than not to occur. Such
exposures would normally include, but would not be limited to, activities such as charging
reactor vessels, drumming, bulk loading, cleaning equipment, maintenance operations, materials
handling and transfers, and analytical operations. Covered exposures include exposures through
any route of entry (inhalation, ingestion, skin contact, absorption, etc.), but excludes accidental
or theoretical exposures.
Repackaging means the physical transfer of a chemical substance or mixture, as is,
from one container to another container or containers in preparation for distribution of the
chemical substance or mixture in commerce.
Reportable chemical substance means a chemical substance described in § 711.5.
Research and development (R&D) means activities intended solely as scientific
experimentation, research, or analysis. R&D focuses on the analysis of the chemical or physical
characteristics, the performance, or the production characteristics of a chemical substance, a
mixture containing the substance, or an article. R&D encompasses a wide range of activities
which may occur in a laboratory, pilot plant, commercial plant outside the research facility, or at
other sites appropriate for R&D. General distribution of chemical substances to consumers does
not constitute R&D. (40 CFR 705.15)
Site means a contiguous property unit. Property divided only by a public right-of-way
shall be considered one site. More than one plant may be located on a single site.
(a) For chemical substances manufactured under contract, i.e., by a co-manufacturer, the
site is the location where the chemical substance is physically manufactured.
(b) The site for an importer who imports a chemical substance described in § 711.5 is
the U.S. site of the operating unit within the person's organization that is directly responsible for
importing the substance. The import site, in some instances, may be the organization's
headquarters in the United States. If there is no such operating unit or headquarters in the
United States, the site address for the importer is the United States address of an agent acting on
behalf of the importer who is authorized to accept service of process for the importer.
(c) For portable manufacturing units sent out to different locations from a single
distribution center, the distribution center shall be considered the site.
Site-limited means a chemical substance is manufactured and processed only within a
site and is not distributed for commercial purposes as a substance or as part of a mixture or
article outside the site. Imported substances are never site-limited. Although a site-limited
chemical substance is not distributed for commercial purposes outside the site at which it is
manufactured and processed, the substance is considered to have been manufactured and
processed for commercial purposes.
Small government means the government of a city, county, town, township, village,
school district, or special district with a population of less than 50,000. (40 CFR 704.3)
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Appendix A
Glossary of Terms
Small manufacturer means a manufacturer (including importer) that meets either of the
following standards:
(1) First standard. A manufacturer (including importer) of a substance is small if its
total annual sales, when combined with those of its parent company (if any), are less than $120
million. However, if the annual production or importation volume of a particular substance at
any individual site owned or controlled by the manufacturer or importer is greater than 45,400
kilograms (100,000 lbs), the manufacturer (including importer) will not qualify as small for
purposes of reporting on the production or importation of that substance at that site, unless the
manufacturer (including importer) qualifies as small under standard (2) of this definition.
(2) Second standard. A manufacturer (including importer) of a substance is small if its
total annual sales, when combined with those of its parent company (if any), are less than $12
million, regardless of the quantity of substances produced or imported by that manufacturer
(including importer). (40 CFR 704.3)
Small quantities solely for research and development (or "small quantities solely for
purposes of scientific experimentation or analysis or chemical research on, or analysis of, such
substance or another substance, including such research or analysis for the development of a
product") means quantities of a chemical substance manufactured, imported, or processed or
proposed to be manufactured, imported, or processed solely for research and development that
are no greater than reasonably necessary for such purposes. (40 CFR 704.3)
State means any State of the United States, the District of Columbia, the
Commonwealth of Puerto Rico, the Virgin Islands, Guam, the Canal Zone, American Samoa,
the Northern Mariana Islands, or any other territory or possession of the United States. (TSCA
3(16))
Submission period means the period in which data are submitted to EPA.
United States, when used in the geographic sense, means all of the States. (TSCA
3(17))
Use means any utilization of a chemical substance or mixture that is not otherwise
covered by the terms manufacture or process. Relabeling or redistributing a container holding a
chemical substance or mixture where no repackaging of the chemical substance or mixture
occurs does not constitute use or processing of the chemical substance or mixture.
Worker means someone at a site of manufacture, import, or processing who performs
work activities near sources of a chemical substance or mixture or directly handles the chemical
substance or mixture during the performance of work activities. (40 CFR 705.15)
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Appendix B
Key Comparisons between Section 8(a)(7) Data Call and CDR
Appendix B. Key Comparisons between Section
8(a)(7) Data Call and CDR
This PFAS data call is promulgated under TSCA section 8(a)(7) and has many
similarities to Chemical Data Reporting (CDR) required under TSCA section 8(a)(1). You or
someone else at your site or company may have previously reported to CDR. However, it is
important to note that there are certain differences between section 8(a)(7) reporting and
reporting under CDR. You should review the final rule in 40 CFR 705 as well as this document
to ensure you are reporting correctly. To assist you, this section outlines key differences between
section 8(a)(7) reporting and reporting under CDR. Important differences to consider include:
• Absence of certain reporting exemptions and reporting thresholds that exist under CDR
• Differences in what data elements are to be reported
• Timeframe (years covered by the rule)
• Considerations for claiming information as confidential business information (CBI)
• Availability of streamlined reporting options in certain manufacturing scenarios
Reporting Exemptions
PFAS section 8(a)(7) reporting does not provide any exemptions. Do not assume you
qualify for a section 8(a)(7) exemption because you qualify for a CDR exemption. Review
Section 2 of this document for additional guidance on determining if you are required to report.
For example, CDR reporters are not required to report for small manufacture/import quantities,
chemicals imported as part of an article, or chemicals manufactured as byproducts that meet
exemption requirements under 711.10(c), 711.10 (d)(1), or 711.10(d)(2). No such exemptions
apply to section 8(a)(7) reporting —you may be required to submit a section 8(a)(7) report even
if one of these, or any other, CDR exemption applies to your chemical substance.
CDR exemptions that do not apply to PFAS Section 8(a)(7) reporting include, but are not
limited to, exemptions for: articles containing PFAS (including imported articles containing
PFAS such as articles containing PFAS as part of surface coatings), byproducts, impurities,
polymers, and non-isolated intermediates.
Reported Data Elements
Data to be reported under section 8(a)(7) include some fields comparable to data
reporting under CDR and some additional data. For fields comparable to CDR reporting, note
that there may be differences between requirements for how to report to this data call compared
to CDR reporting. In particular, lists of codes (such as codes for reporting industrial uses) may
differ from the codes your site has used to report to CDR in the past. Additional data to be
reported includes information on byproducts, environmental and health effects, worker exposure
during industrial and commercial use, and disposal.
Covered Timeframe
This data call covers activities occurring from January 1, 2011, through December 31,
2022 (i.e., the end of the last calendar year prior to the effective date of this rule), a period of 12
years. Unlike CDR reporting, all years are treated equally for purposes of this data call; there is
no "principal reporting year," and the same data elements must be reported for each year. The
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Appendix B
Key Comparisons between Section 8(a)(7) Data Call and CDR
reporting software allows you to select a subset of years to report on if you did not manufacture
the PFAS every year.
Considerations for CBI claims
Although the process of asserting CBI claims is similar to the process used for CDR
reporting, there are some important differences. Review the section 8(a)(7) rule and this guidance
when asserting CBI claims. It is your responsibility to ensure you are claiming and substantiating
CBI claims as required by the section 8(a)(7) rule. If you fail to substantiate your CBI claims
in accordance with the statute and applicable rules, EPA may make the information available to
the public without further notice to you. However, EPA intends to publish a list of Accession
numbers for which either no chemical identity CBI claim was asserted or the claim was denied as
candidates for moving to the public Inventory and provide opportunity for other claimants of the
chemical identity to appeal. Instructions for claiming and substantiating CBI claims are included
in the instructions for each section. For additional information about how to answer
substantiation questions, visit www.epa.gov/tsca-cbi on the EPA website.
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Appendix C
Examples ofPFAS covered by this rule
Appendix C. Examples ofPFAS covered by this
rule
The requirements of this part apply to all chemical substances and mixtures that are
PFAS, consistent with the definition ofPFAS at § 705.3. This includes, but is not limited to, all
PFAS listed or otherwise described in this section. This section contains 5 listings of examples
of chemical substances or mixtures that meet this definition. Paragraph (a) of this section is a list
of chemical substances on the TSCA Inventory that have an associated Chemical Abstract
Services (CAS) Registry Number. Paragraph (b) of this section is a list of chemical substances
that have an associated TSCA Accession Number. Paragraph (c) of this section is a list of
chemical substances that have both an associated low-volume exemption (LVE) case number
and a nonconfidential CASRN. Paragraph (d) of this section is a list of chemical substances with
an LVE case number but no CASRN. Paragraph (e) of this section is a list of structural diagram
examples ofPFAS and those CASRNs.
A non-exhaustive list ofPFAS is also provided in EPA's CompTox Dashboard. The
CompTox list includes all chemicals with known structures that meet the definition ofPFAS for
section 8(a)(7) reporting. The CompTox list includes all known chemicals, regardless of their
TSCA Inventory status, and is updated as new chemicals are added to the database. The
CompTox list does not include chemicals with undefined (unknown or variable) structures.
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Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Appendix D. Descriptions of Codes for
Reporting Processing or Use Operations,
Industrial Sectors, Function Categories, and
Consumer and Commercial Product Categories
The following descriptions were developed by EPA to assist persons submitting
information in response to 40 CFR 711.15(c) and reported in Part II.D of the section 8(a)(7)
reporting. Table D-3, Table D-4, Table D-5, and Table D-6 include crosswalks between OECD
standardized codes to be used for section 8(a)(7) reporting and codes used for reporting to CDR.
For more information, see the Technical Support Document: "Harmonizing CDR
Functional and Product codes with OECD Functional, Product, and Article Codes," located in
the rulemaking record (EPA-HQ-OPPT-2018-0321).
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Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Table D-l provides the type of processing or use operation (TPU) codes with descriptions
of the types of operations. These codes are used to report in Part II, Section B.
Table D-l. Type of Processing or Use Operation and Descriptions
('ode
T\ |H' of Opci'iilion
Description
PC
Processing as a reactant
Chemical substance is used in chemical reactions for the
manufacturing of another chemical substance or product.
PF
Processing—incorporation
into formulation, mixture, or
reaction product
Chemical substance is added to a product (or product
mixture) prior to further distribution of the product.
PA
Processing—incorporation
into article
Chemical substance becomes an integral component of an
article distributed for industrial, trade, or consumer use.
PK
Processing—repackaging
Preparation of a chemical substance for distribution in
commerce in a different form, state, or quantity. This includes
transferring the chemical substance from a bulk container into
smaller containers. This definition does not apply to sites that
only relabel or redistribute the reportable chemical substance
without removing the chemical substance from the container
in which it is received or purchased.
U
Use—non-incorporative
activities
Chemical substance is otherwise used (e.g., as a chemical
processing or manufacturing aid).
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Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Table D-2 provides a crosswalk between Industrial Sector (IS) codes used to report in
Part II Section B with North American Industrial Classification System (NAICS) codes
commonly used to classify businesses.
Table D-2. Industrial Sector (IS) Code Descriptions with NAICS Crosswalk
NAICS
IS ( oik-
IS 1 ilk-
11
IS1
Agriculture, Forestry, Fishing and Hunting
211
IS2
Oil and Gas Drilling, Extraction, and Support Activities
213
212
IS3
Mining (except Oil and Gas) and Support Activities
22
IS4
Utilities
23
IS5
Construction
311
IS6
Food, beverage, and tobacco product manufacturing
312
313
IS7
Textiles, apparel, and leather manufacturing
314
315
316
321
IS8
Wood Product Manufacturing
322
IS9
Paper Manufacturing
323
IS10
Printing and Related Support Activities
32411
IS11
Petroleum Refineries
32412
IS12
Asphalt Paving, Roofing, and Coating Materials Manufacturing
324191
IS13
Petroleum Lubricating Oil and Grease Manufacturing
324199
IS14
All Other Petroleum and Coal Products Manufacturing
32511
IS15
Petrochemical Manufacturing
32512
IS16
Industrial Gas Manufacturing
32513
IS17
Synthetic Dye and Pigment Manufacturing
325182
IS18
Carbon Black Manufacturing
32518
IS19
All Other Basic Inorganic Chemical Manufacturing
325192
IS20
Cyclic Crude and Intermediate Manufacturing
32519
IS21
All Other Basic Organic Chemical Manufacturing
325211
IS22
Plastic Material and Resin Manufacturing
325212
IS23
Synthetic Rubber Manufacturing
32522
IS24
Organic Fiber Manufacturing
3253
IS25
Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing
3254
IS26
Pharmaceutical and Medicine Manufacturing
32551
IS27
Paint and Coating Manufacturing
32552
IS28
Adhesive Manufacturing
3256
IS29
Soap, Cleaning Compound, and Toilet Preparation Manufacturing
D-3
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Y\l( S
IS ( oik-
IS 1 ilk-
32591
IS30
Printing Ink Manufacturing
32592
IS31
Explosives Manufacturing
325991
IS32
Custom Compounding of Purchased Resin
325992
IS33
Photographic Film Paper, Plate, and Chemical Manufacturing
325998
IS34
All Other Chemical Product and Preparation Manufacturing
3261
IS35
Plastics Product Manufacturing
3262
IS36
Rubber Product Manufacturing
327
IS37
Nonmetallic Mineral Product Manufacturing (includes clay, glass, cement,
concrete, lime, gypsum, and other nonmetallic mineral product manufacturing)
331
IS38
Primary Metal Manufacturing
332
IS39
Fabricated Metal Product Manufacturing
333
IS40
Machinery Manufacturing
334
IS41
Computer and Electronic Product Manufacturing
335
IS42
Electrical Equipment, Appliance, and Component Manufacturing
336
IS43
Transportation Equipment Manufacturing
337
IS44
Furniture and Related Product Manufacturing
339
IS45
Miscellaneous Manufacturing
42
IS46
Wholesale and Retail Trade
44
45
48
49
51
IS47
Services
52
53
54
55
56
61
62
71
72
81
92
IS48
Other (requires additional information)
D-4
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Table D-3 provides the 2020 CDR Product Category codes (based on OECD harmonized
codes) to be used for section 8(a)(7) reporting, with corresponding product category codes from
2016 CDR reporting. The 2016 CDR codes are provided only as a reference to assist you if your
company has used these codes in past reporting. Do not use 2016 CDR codes for section 8(a)(7)
reporting.
Table D-3. Product Category Codes
I so column A for ;ill reporting. Column IS slums 201(> CDR codes, which m;i\ ha\c boon used lor CDR
Column A: Sod ion X(;i)(7) codes
Column IS: 20H> CDR codes
(ode
Ciilejion
(ode
Ciileiion
( hcmiciil Suhsliinces in I'lirnishiiiu. ( lonninu. Trciilmcnl Cure Products
CC101
Construction and building materials covering large
surface areas including stone, plaster, cement, glass and
ceramic articles; fabrics, textiles, and apparel
C101
Floor coverings
CC102
Furniture & furnishings including plastic articles (soft);
leather articles
C102
Foam seating and bedding
products
CC103
Furniture & furnishings including stone, plaster, cement,
glass and ceramic articles; metal articles; or rubber
articles
C103
Furniture and furnishings not
covered elsewhere
CC104
Leather conditioner
C104
Fabric, textile, and leather
products not covered
elsewhere
CC105
Leather tanning, dye, finishing, impregnation and care
products
CC106
Textile (fabric) dyes
CC107
Textile finishing and impregnating/surface treatment
products
CC108
All-purpose foam spray cleaner
C105
Cleaning and furnishing care
products
CC109
All-purpose liquid cleaner/polish
CC110
All-purpose liquid spray cleaner
CC111
All-purpose waxes and polishes
CC112
Appliance cleaners
CC113
Drain and toilet cleaners (liquid)
CC114
Powder cleaners (floors)
CC115
Powder cleaners (porcelain)
CC116
Dishwashing detergent (liquid/gel)
C106
Laundry and dishwashing
products
CC117
Dishwashing detergent (unit dose/granule)
CC118
Dishwashing detergent liquid (hand-wash)
CC119
Dry cleaning and associated products
CC120
Fabric enhancers
CC121
Laundry detergent (unit-dose/granule)
CC122
Laundry detergent (liquid)
CC123
Stain removers
CC124
Ion exchangers
C107
Water treatment products
CC125
Liquid water treatment products
CC126
Solid/Powder water treatment products
D-5
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I sc colli 111 ii A lor ;ill roportinvi- Column li shows 20Hi ( l)R codes, which ma\ ha\e heen used for ( l)k
Column A: Section S(;i)(7J codes
Column li: 20Hi ( I)R codes
(ode
Caletion
Code
Caleiion
CC127
Liquid body soap
C108
Personal care products
CC128
Liquid hand soap
CC129
Solid bar soap
CC130
Air fresheners for motor vehicles
C109
Air care products
CC131
Continuous action air fresheners
CC132
Instant action air fresheners
CC133
Anti-static spray
C110
Apparel and footwear care
products
CC134
Apparel finishing, and impregnating/surface treatment
products
CC135
Insect repellent treatment
CC136
Pre-market waxes, stains, and polishes applied to
footwear
CC137
Post-market waxes, and polishes applied to footwear
(shoe polish)
CC138
Waterproofing and water-resistant sprays
Chemical Substances in Construction. Paint. Electrical, and Metal Products
CC201
Fillers and putties
C201
Adhesives and sealants
CC202
Hot-melt adhesives
CC203
One-component caulks
CC204
Solder
CC205
Single-component glues and adhesives
CC206
Two-component caulks
CC207
Two-component glues and adhesives
CC208
Adhesive/Caulk removers
C202
Paints and coatings
CC209
Aerosol spray paints
CC210
Lacquers, stains, varnishes and floor finishes
CC211
Paint strippers/removers
CC212
Powder coatings
CC213
Radiation curable coatings
CC214
Solvent-based paint
CC215
Thinners
CC216
Water-based paint
CC217
Construction and building materials covering large
surface areas, including wood articles
C203
Building/ construction
materials - wood and
engineered wood products
CC218
Construction and building materials covering large
surface areas, including paper articles; metal articles;
stone, plaster, cement, glass and ceramic articles
C204
Building/ construction
materials not covered
elsewhere
CC219
Machinery, mechanical appliances, electrical/electronic
articles
C205
Electrical and electronic
products
CC220
Other machinery, mechanical appliances,
D-6
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I sc colli 111 ii A lor ;ill roportinvi- Column li shows 20Hi ( l)R codes, which ma\ ha\e heen used for ( l)k
Column A: Section S(;i)(7J codes
Column li: 20Hi ('I)R codes
(ode
Caletion
Code
Caleiion
electronic/electronic articles
CC221
Construction and building materials covering large
surface areas, including metal articles
C206
Metal products not covered
elsewhere
CC222
Electrical batteries and accumulators
C207
Batteries
Chemical Substances in Packauinu, Pai)er. Plastic. Tovs. Hobbv Products
CC990
Non-TSCA use
C301
Food packaging
CC301
Packaging (excluding food packaging), including paper
articles
C302
Paper products
CC302
Other articles with routine direct contact during normal
use, including paper articles
CC303
Packaging (excluding food packaging), including rubber
articles; plastic articles (hard); plastic articles (soft)
C303
Plastic and rubber products
not covered elsewhere
CC304
Other articles with routine direct contact during normal
use including rubber articles; plastic articles (hard)
CC305
Toys intended for children's use (and child dedicated
articles), including fabrics, textiles, and apparel; or
plastic articles (hard)
C304
Toys, playground, and
sporting equipment
CC306
Adhesives applied at elevated temperatures
C305
Arts, crafts, and hobby
materials
CC307
Cement/concrete
CC308
Crafting glue
CC309
Crafting paint (applied to body)
CC310
Crafting paint (applied to craft)
CC311
Fixatives and finishing spray coatings
CC312
Modelling clay
CC313
Correction fluid/tape
C306
Ink, toner, and colorant
products
CC314
Inks in writing equipment (liquid)
CC315
Inks used for stamps
CC316
Toner/Printer cartridge
CC317
Liquid photographic processing solutions
C307
Photographic supplies, film,
and photochemicals
Chemical Substances in Automotive. Fuel. Agriculture. Outdoor Use Products
CC401
Exterior car washes and soaps
C401
Automotive care products
CC402
Exterior car waxes, polishes, and coatings
CC403
Interior car care
CC404
Touch up auto paint
CC405
Degreasers
C402
Lubricants and greases
CC406
Liquid lubricants and greases
CC407
Paste lubricants and greases
CC408
Spray lubricants and greases
CC409
Anti-freeze liquids
C403
Anti-freeze and de-icing
products
CC410
De-icing liquids
D-7
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I sc colli 111 ii A lor ;ill roportinvi- Column li shows 20Hi ( l)R codes, which ma\ ha\e heen used for ( l)k
Column A: Section S(;i)(7J codes
Column li: 20Hi CI)R codes
(ode
Caletion
Code
Caleiion
CC411
De-icing solids
CC412
Lock de-icers/releasers
CC413
Cooking and heating fuels
C404
Fuels and related products
CC414
Fuel additives
CC415
Vehicular or appliance fuels
CC416
Explosive materials
C405
Explosive materials
CC417
Agricultural non-pesticidal products
C406
Agricultural products (non-
pesticidal)
CC418
Lawn and garden care products
C407
Lawn and garden care
products
Chemical Substances in Products not Described bv Other Codes
CC980
Other (specify)
C909
Other (specify)
CC990
Non-TSCA use
C980
Non-TSCA use
D-8
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Table D-4 provides the Function Category codes based on OECD harmonized codes to be
used for section 8(a)(7) reporting, with corresponding Function Category codes from 2016 CDR
reporting. The CDR codes are provided only as a reference to assist you if your company has
used these codes in past reporting. Do not use CDR codes for section 8(a)(7) reporting.
Table D-4. Function Category Descriptions and Crosswalk: Section 8(a)(7) reporting and
2016-2020 CDR
I se column A lor till reporting. Column B shows 2(11(> CI)R codes, which m;i\ h;i\c heen used lor CDR
Column A: Section X(;i)C) codes
Column B: 2016 CDR codes
(ode
Description
(ode
Description
F001
Abrasives
U001
Abrasives
F002
Etching agent
F003
Adhesion/cohesion promoter
F004
Binder
U002
Adhesives and Sealant Chemicals
F005
Flux agent
F006
Sealant (barrier)
F007
Absorbent
F008
Adsorbent
F009
Dehydrating agent (desiccant)
U003
Adsorbents and Absorbents
F010
Drier
F011
Humectant
F012
Soil amendments (fertilizers)
U004
Agricultural Chemicals (non-pesticidal)
F013
Anti-adhesive/cohesive
U005
Anti-Adhesive Agents
F014
Dusting agent
F015
Bleaching agent
U006
Bleaching Agents
F016
Brightener
F017
Anti-scaling agent
U007
Corrosion inhibitors and antiscaling agents
F018
Corrosion inhibitor
F019
Dye
U008
Dyes
F020
Fixing agent (mordant)
F021
Hardener
U009
Fillers
F022
Filler
F023
Anti-static agent
F024
Softener and conditioner
F025
Swelling agent
F026
Tanning agents not otherwise specified
U010
Finishing agents
F027
Waterproofing agent
F028
Wrinkle resisting agent
F029
Flame retardant
U011
Flame retardants
D-9
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I se column A lor till reporting. Column B shows 2(11(> CI)R codes, which m;i\ h;i\c heen used for CI)R
( olu in it A: Section S( ii K 7) codes
Column 1$: 2(11(> CI)R codes
(ode
Description
Code
Description
F030
Fuel agents
U012
Fuels and fuel additives
F031
Fuel
F032
Heat transferring agent
F033
Hydraulic fluids
U013
Functional fluids (closed systems)
F034
Insulators
F035
Refrigerants
F036
Anti-freeze agent
U014
Functional fluids (open systems)
F037
Intermediate
U015
Intermediates
F038
Monomers
F039
Ion exchange agent
U016
Ion exchange agents
F040
Anti-slip agent
U017
Lubricants and lubricant additives
F041
Lubricating agent
F042
Deodorizer
U018
Odor agents
F043
Fragrance
F044
Oxidizing agent
U019
Oxidizing/reducing agents
F045
Reducing agent
F046
Photosensitive agent
F047
Photosensitizers
U020
Photosensitive chemicals
F048
Semiconductor and photovoltaic agent
F049
UV stabilizer
F050
Opacifer
U021
Pigments
F051
Pigment
F052
Plasticizer
U022
Plasticizers
F053
Plating agent
U023
Plating agents and surface treating agents
F054
Catalyst
F055
Chain transfer agent
F056
Chemical reaction regulator
U024
Process regulators
F057
Crystal growth modifiers (nucleating agents)
F058
Polymerization promoter
F059
Terminator/Blocker
F060
Processing aids, specific to petroleum
production
U025
Processing aids, specific to petroleum production
D-10
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I se column A lor till reporting. Column B shows 2(11(> CI)R codes, which m;i\ h;i\c heen used for CI)R
( olu in it A: Section S( ii K 7) codes
Column 1$: 2(11(> CI)R codes
(ode
Description
Code
Description
F061
Antioxidant
F062
Chelating agent
F063
Defoamer
U026
Processing aids, not otherwise listed
F064
pH regulating agent
F065
Processing aids not otherwise specified
F066
Energy Releasers (explosives, motive
propellant)
F067
Foamant
U027
Propellants and blowing agents
F068
Propellants, non-motive (blowing agents)
F069
Cloud-point depressant
F070
Flocculating agent
U028
Solids separation agents
F071
Flotation agent
F072
Solids separation (precipitating) agent, not
otherwise specified
F073
Cleaning agent
U029
Solvents (for cleaning or degreasing)
F074
Diluent
U030
Solvents (which become part of product
F075
Solvent
formulation or mixture)
F076
Surfactant (surface active agent)
U031
Surface active agents
F077
Emulsifier
F078
Thickening agent
U032
Viscosity adjusters
F079
Viscosity modifiers
F080
Laboratory chemicals
U033
Laboratory chemicals
F081
Dispersing agent
F082
Freeze-thaw additive
U034
Paint additives and coating additives not
F083
Surface modifier
described by other codes
F084
Wetting agent (non-aqueous)
D-ll
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I se column A lor till reporting. Column B shows 2(11(> CI)R codes, which m;i\ h;i\c heen used for CDR
Column A: Section S(iiK7) codes
Column 1$: 2(11(> CDR codes
(ode
Description
(ode
Description
F085
Aerating and deaerating agents
F086
Explosion inhibitor
F087
Fire extinguishing agent
F088
Flavoring and nutrient
F089
Anti-redeposition agent
F090
Anti-stain agent
F091
Anti-streaking agent
F092
Conductive agent
F093
Incandescent agent
F094
Magnetic element
F095
Anti-condensation agent
F096
Coalescing agent
F097
Film former
F098
Demulsifier
F099
Stabilizing agent
F100
Alloys
F101
Density modifier
U999
Other (specify)
F102
Elasticizer
F103
Flow promoter
F104
Sizing agent
F105
Solubility enhancer
F106
Vapor pressure modifiers
F107
Embalming agent
F108
Heat stabilizer
F109
Preservative
F110
Anti-caking agent
Fill
Deflocculant
F112
Dust suppressant
F113
Impregnation agent
F114
Leaching agent
F115
Tracer
F116
X-ray absorber
F999
Other (specify)
NOTE: For codes F085 - F116, no comparable crosswalk code existed in 2016 CDR
D-12
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Table D-5 provides the Consumer and Commercial Product Category codes based on
OECD harmonized codes to be used for section 8(a)(7) reporting, with corresponding consumer
and commercial product category codes from 2016 CDR reporting. The CDR codes are provided
only as a reference to assist you if your company has used these codes in past reporting. Do not
use CDR codes for section 8(a)(7) reporting.
Table D-5. Consumer and Commercial Product Category Descriptions and Crosswalk
I so coin 111 ii A lor iill report in::. Column B slums 2010 ( l)R codes, which ma\ h;i\c heen used lor CDR reporting.
Column A: Section SciX"7) codes
Column B: 20l(> CDR codes
(ode
Niime
Description
(ode
Niime
Chemical Suhsianccs in I'miiishiim. Clcaiiiim. Tieaimciil Care I'mducls
CC101
Construction and building
materials covering large surface
areas including stone, plaster,
cement, glass and ceramic
articles; fabrics, textiles, and
apparel
Cement flooring, stone tile, mirrors,
flooring or wall materials, carpets,
rugs, tapestries
C101
Floor coverings
CC102
Furniture & furnishings including
plastic articles (soft); leather
articles
Foam armchair, couch/sofa, mattress
(adult), mattress (infant), mattress
(child), sleeping bag, beanbag chair
C102
Foam seating and
bedding products
CC103
Furniture & furnishings including
stone, plaster, cement, glass and
ceramic articles; metal articles; or
rubber articles
Tables, chairs, benches, outdoor
furniture, or furniture feet
C103
Furniture and
furnishings not covered
elsewhere
CC104
Leather conditioner
Products applied to leather surfaces
to preserve and/or restore strength,
appearance, and flexibility.
C104
Fabric, textile, and
leather products not
covered elsewhere
CC105
Leather tanning, dye, finishing,
impregnation and care products
Products applied to the surfaces of
leather articles to impart desirable
properties.
CC106
Textile (fabric) dyes
Products applied to impart color(s) to
textiles.
CC107
Textile finishing and
impregnating/surface treatment
products
Products applied to the surfaces of
textiles to impart water or stain
resistances, flame resistance, but not
dyes.
D-13
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( olu 111 11
A: Section X(a)(7) codes
Column B: 20l(> ( l)K codes
(ode
Name
Description
(ode
Name
CC108
All-purpose foam spray cleaner
Foams that are spray applied to
surfaces such as countertops, tables,
windows, and surfaces of appliances.
CC109
All-purpose liquid cleaner/polish
Liquids that are not spray applied
and are applied to surfaces of
furniture, silverware, sinks, tubs,
carpeted floors, and hard-surface
floors. Note: distinguish between
"neat" and "dilute" products.
CC110
All-purpose liquid spray cleaner
Liquids that are spray applied to
surfaces such as countertops, tables,
windows, and surfaces of appliances.
CC111
All-purpose waxes and polishes
Waxes and other semi-solids that are
not spray applied and are applied to
the surfaces of furniture (generally
wooden furniture) to improve shine
and/or impart stain resistance.
C105
Cleaning and furnishing
care products
CC112
Appliance cleaners
Cleaners that are applied to the
interior of appliances such as
dishwashers, washing machines,
electronic appliances, disposals, and
ovens).
CC113
Drain and toilet cleaners (liquid)
Liquids applied to toilets and/or
drains that may remain in the sewer
line for a time but ultimately go
down the drain.
CC114
Powder cleaners (floors)
Powders that are applied to carpets
and rugs to clean or deodorize.
CC115
Powder cleaners (porcelain)
Powders applied to sinks, showers,
and tubs to remove dirt, soap scum,
and mold.
D-14
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( olu 111 11
A: Section X(a)(7) codes
Column B: 20l(» ( l)K codes
(ode
Name
Description
(ode
Niime
CC116
Dishwashing detergent
(liquid/gel)
Liquid cleaners added to
dishwashing machines to remove
food residue from dishes.
CC117
Dishwashing detergent (unit
dose/granule)
Powder or powder/liquid tablet
cleaners added to washing machines
to remove dirt from clothing and
other textiles.
CC118
Dishwashing detergent liquid
(hand-wash)
Liquid cleaners added to sinks and
combined with water to remove food
residue from dishes.
CC119
Dry cleaning and associated
products
Products used to remove dirt from
clothing and other textiles in non-
aqueous cleaning processes.
CC120
Fabric enhancers
Products which enhance fabrics.
Examples include liquid products
added to washing machines or sheets
added to driers, bleach, film, lime
and rust removers.
C106
Laundry and
dishwashing products
CC121
Laundry detergent (unit-
dose/granule)
Powder or powder/liquid tablet
cleaners added to washing machines
to remove dirt from clothing and
other textiles.
CC122
Laundry detergent (liquid)
Liquid cleaners added to washing
machines to remove dirt from
clothing and other textiles.
CC123
Stain removers
Applied to clothing before addition
to laundry machine to remove stains
(can be gels, liquids, or spray
applications).
CC124
Ion exchangers
Point of use filters which may be
used by consumers in homes (e.g.,
refrigerator filters or pitcher filters)
or in commercial and industrial
settings to treat water for use in these
processes.
C107
Water treatment
products
CC125
Liquid water treatment products
Water treatment drops
CC126
Solid/powder water treatment
products
pH adjusters, filter media, water
treatment tablets
CC127
Liquid body soap
Liquid soap used for washing entire
body.
CC128
Liquid hand soap
Liquid soap used for washing hands.
C108
Personal care products
CC129
Solid bar soap
Solid soap used for washing hands
and body.
D-15
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( olu 111 11
A: Section X(a)(7) codes
Column B: 20l(> ( l)K codes
(ode
Name
Description
(ode
Name
CC130
Air fresheners for motor vehicles
Aerosol spray and continuous action
air products used to odorize or
deodorize motor vehicles.
CC131
Continuous action air fresheners
Liquid, solid, gel diffuser, solid
incense products and scented candle
products that odorize or deodorize
air in indoor environments.
C109
Air care products
CC132
Instant action air fresheners
Aerosol spray and incense products
that odorize or deodorize air in
indoor environments.
CC133
Anti-static spray
Spray applied to eliminate or reduce
static electricity on apparel.
CC134
Apparel finishing, and
impregnating/surface treatment
products
Products applied to the surfaces of
apparel to impart water or stain
resistances, flame resistance, but not
dyes.
CC135
Insect repellent treatment
Product applied to clothing to repel
insects.
C110
Apparel and footwear
care products
CC136
Pre-market waxes, stains, and
polishes applied to footwear
Waxes, stains, and polishes applied
to footwear to impart water
resistance, improve appearance and
impart other desirable properties.
CC137
Post-market waxes, and polishes
applied to footwear (shoe polish)
Waxes and polishes applied to
footwear.
CC138
Waterproofing and water-
resistant sprays
Spray applied to impart water
resistance to apparel or footwear.
D-16
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Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( olu 111 11
A: Section X(a)(7) codes
Column B: 20l(» ( l)K codes
(ode
Name
Description
(ode
Name
( hemic;i
Suhsi;iik.vs mi Ci»iMmclk»ii. 1 J;nill. I!k
vliical. and Melal hoducls
CC201
Fillers and putties
Highly malleable materials used to
repair, smooth over, or fill minor
cracks and holes in building
surfaces.
CC202
Hot-melt adhesives
Adhesives (supplied in solid
cylindrical sticks and intended for
small applications) designed to be
melted and dispensed through an
electric hot glue gun.
CC203
One-component caulks
Caulks (sealants) which are
premixed with their final product
formulation. Examples include
acrylic solvent-based, butyl solvent-
based, latex water-based, silicone
and polyurethane.
CC204
Solder
Metal alloys melted down to
permanently bond metal parts
together. Commonly used in
electronics, plumbing and sheet
metal work.
CC205
Single-component glues and
adhesives
Adhesives (packaged less than 8
ounces per bottle and intended for
small amount per use applications
such as bookbinding) which are
premixed with their final product
formulation. Product use and
exposure to light, humidity, or
temperature initiates chemical
reaction and cure. Examples include
anaerobic, cyanoacrylates, heat-cure,
moisture-cure, radiation-cure, and
silicones.
C201
Adhesives and sealants
CC206
Two-component caulks
Caulks (sealants) which are stored in
two separate parts, generally a base
and an activator. The activator is
added to the base and mixed before
application. Examples include
epoxy-solvent based silicone and
polyurethane.
CC207
Two-component glues and
adhesives
Adhesives (packaged in containers
smaller than 8 ounces per container
and intended for small applications)
which are stored in two separate
containers, generally a resin and a
hardener which are then mixed
together to initiate chemical reaction
and cure. Examples include epoxies,
D-17
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Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( olu 111 11
A: Section X(a)(7) codes
Column B: 20l(> ( l)K codes
(ode
Name
Description
(ode
Niime
methyl methacrylates, silicon
adhesives, and polyurethanes.
CC208
Adhesive/caulk removers
Products applied to surfaces to
unbind substances or remove
sealants and to clean the underlying
surface by softening adhesives,
caulks and other glues so they can be
removed.
CC209
Aerosol spray paints
Pressurized one-component paint
released with a propellant and spray
applied as a fine mist.
CC210
Lacquers, stains, varnishes and
floor finishes
Liquids applied to surfaces such as
floors, countertops, appliances,
furnishings, decking, and patios to
impart coloring or resistance to fade,
scuffing, marking, or wear.
CC211
Paint strippers/removers
Liquid product applied to surfaces to
remove paint, coatings and other
finishes and also to clean the
underlying surface.
C202
Paints and coatings
CC212
Powder coatings
Dry powder coating that does not
contain solvents and is cured under
heat to create a coating film.
CC213
Radiation curable coatings
Coatings designed to cure onto
surface when exposed to radiation
such as ultraviolet or electron beam
radiation.
CC214
Solvent-based paint
Paints that have been formulated to
have a solvent as the vehicle.
CC215
Thinners
Liquids to dilute paints and coatings
to obtain suitable viscosity for paint
application.
CC216
Water-based paint
Paints that have been formulated to
have water as the main vehicle.
CC217
Construction and building
materials covering large surface
areas, including wood articles
Floor decking, claddings, toys
outdoor equipment, walls, flooring
C203
Building/ construction
materials - wood and
engineered wood
products
D-18
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Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( oluin 11 A: Section X(a)(7) codes
Column B: 20l(> ( l)K codes
(ode
Name
Description
(ode
Name
CC218
Construction and building
materials covering large surface
areas, including paper articles;
metal articles; stone, plaster,
cement, glass and ceramic articles
Construction and building materials;
e.g. insulation panels, wall papers,
roof sheets, drinking water pipes,
sewer pipes, cement flooring,
mirrors
C204
Building/ construction
materials not covered
elsewhere
CC219
Machinery, mechanical
appliances, electrical/electronic
articles
Refrigerators, washing machines,
vacuum cleaners, computers,
telephones, drills, saws, smoke
detectors, thermostats, radiators
C205
Electrical and electronic
products
CC220
Other machinery, mechanical
appliances, electronic/electronic
articles
Large-scale stationary industrial
tools
CC221
Construction and building
materials covering large surface
areas, including metal articles
Roof sheets, drinking water pipes,
sewer pipes
C206
Metal products not
covered elsewhere
CC222
Electrical batteries and
accumulators
Batteries
C207
Batteries
Chemical Substances in Packat£int£, Pauer, Plastic, Tovs, Hobbv Products
CC990
Non-TSCA use
Items included under non-TSCA use
include food contact articles, such as
plastic wrap, plastic dinner ware,
food storage, packaging containers.
C301
Food packaging
CC301
Packaging (excluding food
packaging), including paper
articles
Paper packaging
C302
Paper products
CC302
Other articles with routine direct
contact during normal use,
including paper articles
Nappies, feminine hygiene products,
adult incontinence products, tissues,
towels, toilet paper, newspapers,
books, magazines, photographic
paper and negatives
CC303
Packaging (excluding food
packaging), including rubber
articles; plastic articles (hard);
plastic articles (soft)
Phone covers, personal tablet covers,
styrofoam packaging, bubble wrap
C303
Plastic and rubber
products not covered
elsewhere
CC304
Other articles with routine direct
contact during normal use
including rubber articles; plastic
articles (hard)
Gloves, boots, clothing, rubber
handles, gear lever, steering wheels,
handles, pencils, handheld device
casing
CC305
Toys intended for children's use
(and child dedicated articles),
including fabrics, textiles, and
apparel; or plastic articles (hard)
Stuffed toys, blankets, comfort
objects, dolls, car, animals, teething
rings
C304
Toys, playground, and
sporting equipment
D-19
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( olu 111 11
A: Section X(a)(7) codes
Column B: 20l(» ( l)R codes
(ode
Name
Description
(ode
Niime
CC306
Adhesives applied at elevated
temperatures
Used at elevated temperatures to
melt and apply adhesive which when
cooled, hardens and adheres the two
substances to one another. Examples
include solder and hot-melt adhesive,
see adhesive definitions.
CC307
Cement/concrete
Used to create and support structures
and pathways.
CC308
Crafting glue
Used to adhere two substances to
one another, see adhesives
definitions.
Arts, crafts, and hobby
materials
CC309
Crafting paint (applied to body)
Used to add color to fingers, faces,
or other body parts.
C305
CC310
Crafting paint (applied to craft)
Used to add color to crafting
substances, see paints definitions.
CC311
Fixatives and finishing spray
coatings
Fixatives, shellacs, or other spray
applied coatings intended to cover or
hold other arts and crafts materials to
a surface.
CC312
Modelling clay
Used to mold or sculpt.
CC313
Correction fluid/tape
Fluids used to cover up permanent
ink so that corrections can be made.
CC314
Inks in writing equipment (liquid)
Liquids used in pens, markers, or
other writing instruments.
CC315
Inks used for stamps
Inks incorporated into stamp or ink
pads used to apply ink to paper and
other substrates.
C306
Ink, toner, and colorant
products
CC316
Toner/printer cartridge
Pigmented liquids, toners or powders
contained in cartridges, bottles, or
other dispensers used in printers and
copy machines. This category
includes printing inks for
commercial applications.
CC317
Liquid photographic processing
solutions
Chemicals used in the stop bath,
fixing bath, hardener, or stabilizer to
develop photographs.
C307
Photographic supplies,
film, and
photochemicals
D-20
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Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( olu 111 11
A: Section S(a)(7) codes
Column B: 20l(> ( l)K codes
(ode
Name
Description
(ode
Name
Chemical Suhslances in Aulomoti\c. l-'uel. Agriculture. Outdoor I se Products
CC401
Exterior car washes and soaps
Cleaning agents used to remove dirt
and grime.
CC402
Exterior car waxes, polishes, and
coatings
Used to increase the shine, add UV
protection and scratch resistance to
automotive paints, or provide
waterproofing/resistant properties to
windshields and automotive window
glass.
C401
Automotive care
products
CC403
Interior car care
Cleaning agents used to remove
stains from interior carpets and
textiles, rubber, vinyl, or plastic.
CC404
Touch up auto paint
Used to paint over scratches or cover
up dent marks on automotive paints.
CC405
Degreasers
Product that remove greases or oils
from hard surfaces, machinery, or
tools.
CC406
Liquid lubricants and greases
Liquids that reduce friction, heat
generation and wear between
surfaces.
C402
Lubricants and greases
CC407
Paste lubricants and greases
Pastes that reduce friction, heat
generation and wear between
surfaces.
CC408
Spray lubricants and greases
Sprays that reduce friction, heat
generation and wear between
surfaces.
CC409
Anti-freeze liquids
Reduce the freezing point of
surfaces.
CC410
De-icing liquids
Reduce the freezing point of surfaces
in order to remove ice.
C403
Anti-freeze and de-icing
products
CC411
De-icing solids
Ice melting crystals, rock salts
CC412
Lock de-icers/releasers
Applied within locks to remove ice
so that doors can be opened.
CC413
Cooking and heating fuels
Pressurized liquid fuels generally
contained within metal containers
and released directly into an
appliance in a controlled way to
prevent direct release.
C404
Fuels and related
products
CC414
Fuel additives
Added to fuels to improve properties
such as stability, corrosion,
oxygenation, and octane rating.
D-21
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CDR codes, which m;i\ ha\c been used lor CDR report in«.
( oluin 11 A: Section X(a)(7) codes
Column B: 20l(» CDR codes
(ode
Name
Description
(ode
Name
CC415
Vehicular or appliance fuels
Liquid fuels stored in containers and
refilled into vehicles or appliances as
needed.
CC416
Explosive materials
Chemical substances capable of
producing a sudden expansion
usually accompanied by the
production of heat and large changes
in pressure upon initiation, that are
intended for consumer or
commercial use. Examples include
pyrotechnics, high explosives and
propellants, igniter, primer,
initiatory, illuminants, smoke and
decoy flares, and incendiaries.
C405
Explosive materials
CC417
Agricultural non-pesticidal
products
Products used to increase the
productivity of crops, or aid in the
harvesting of crops. Examples
include fertilizers, colorants, and
application aids, and soil
amendments (e.g. products added to
soil to adjust pH, retain water or alter
other properties).
C406
Agricultural products
(non-pesticidal)
CC418
Lawn and garden care products
Chemical substances contained in
lawn, garden, outdoor or potted
plant, and tree care products that are
intended for consumer or
commercial use should be reported
under this code. Examples of lawn
and garden care products include
fertilizers and nutrient mixtures, soil
amendments, mulches, pH adjusters,
water retention beads, vermiculite,
and perlite. Excludes any substance
that is manufactured, processed, or
distributed in commerce for use as a
pesticide as defined in the Federal
Insecticide, Fungicide, and
Rodenticide Act.
C407
Lawn and garden care
products
Chemical Substances in Products not Described bv Other Codes
CC980
Other (specify)
Provide description of use.
C909
Other (specify)
D-22
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
I so coin in n A lor all reporting. Column B slums 2U1(> CI)R codes, which m;i\ ha\c been used lor ('I)K report in«.
( oluin 11 A: Section X(a)(7) codes
Column B: 20l(» ( l)K codes
(ode
Name
Description
(ode
Name
CC990
Non-TSCA use
Chemical substances contained in
products intended for consumer or
commercial use that are not
regulated by TSCA should be
reported under this code. Examples
of products with non-TSCA uses
include pesticide, insecticide,
rodenticide and fungicide
formulations; food or drink for
humans or animals; articles intended
for use in the diagnosis, cure,
mitigation, treatment, or prevention
of disease in humans or animals;
substances intended to be applied to
the human body other than soap; any
radioactive source material, special
nuclear material, or byproduct
material; pistols, revolvers, fire arms,
or ammunition; and tobacco or
tobacco products.
C980
Non-TSCA use
D-23
-------
Appendix D Descriptions of Codes for Reporting Processing or Use Operations, Industrial
Sectors, Function Categories, and Consumer and Commercial Product Categories
Table D-6 provides examples of products intended for use by children, including 2020
CDR (OECD-based) codes to be used for section 8(a)(7) reporting as well as 2016 CDR codes.
This table is meant to help you identify products intended for use by children and may not
include all products intended for use by children. The 2016 CDR codes in this table are provided
only as a reference to assist you if your company has used these codes in past reporting. Do not
use 2016 CDR codes for section 8(a)(7) reporting.
Table D-6. Examples of Products Intended for Use by Children
I se coin ill ii A lor all reporting. Column IS shows 20l(> CDR codes, which m;i\ ha\c heen used lor CDR reporting.
Column A: scclion Xia)C) codes
Column IJ: 20l(» CDR
codes
l-'.\amplcs
Codes
Calciion
Code
Calciion
Chemical Suhslances in l-'iirnishinus. Cleanings. 1 realinenl ( are Producls
CC102
Furniture & furnishings including Plastic
articles (soft); Leather articles
C102
Foam seating and
bedding products
Child's car seat, children's
sheets
CC103
Furniture & furnishings including Stone,
plaster, cement, glass and ceramic articles;
Metal articles; or Rubber articles
C103
Furniture and
furnishings not
covered elsewhere
Baby cribs, changing tables
CC106
Textile (fabric) dyes
C104
Fabric, textile, and
leather products
not covered
elsewhere
Children's clothing
CC107
Textile finishing and impregnating/surface
treatment products
Children's clothing,
children's sheets, child's car
seat
CC127
Liquid body soap
C108
Personal care
products
Baby shampoo, children's
bubble bath
Chemical Suhslances in Construction. Pa int. I'.leclrical and Mclal Producls
CC219
Machinery, mechanical appliances,
electrical/electronic articles
C205
Electrical and
electronic
products
Electronic games, remote
control cars
CC222
Electrical batteries and accumulators
C207
Batteries
Batteries used in toys
Chemical Suhslances in I'ackauinu. Pancr. Plaslic. Ilohln Producls
CC302
Other articles with routine direct contact
during normal use, including paper articles
C302
Paper products
Diapers, baby wipes,
coloring books
CC305
Toys intended for children's use (and child
dedicated articles), including Fabrics,
textiles, and apparel; or Plastic articles (hard)
C304
Toys, playground,
and sporting
equipment
Pacifiers, toy trucks, dolls,
toy cars, wagons, action
figures, balls, swing sets,
slides, skates, baseball
gloves, kid's rake
CC306
Adhesives applied at elevated temperatures
C305
Arts, crafts, and
hobby materials
Craft glue for a hot glue gun
CC308
Crafting glue
Craft glue
CC309
Crafting Paint (applied to body)
Chemicals used to add color
to body paint, finger paints
D-24
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