£% United States
Environmental Protection
^1 Mm. Agency
INVENTORY OF MERCURY
SUPPLY, USE, AND TRADE IN THE
UNITED STATES
2020 REPORT
Office of Chemical Safety and Pollution Prevention
Reporting Year 201 8
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table of Contents
Background 1
Global Agreement on Mercury 1
U.S. Laws Affecting Supply and Trade of Elemental Mercury and Mercury Compounds 1
Introduction to the Inventory of Mercury Supply, Use, and Trade 3
Reporting Requirements 4
Information Not Required to Be Reported 5
Overview of Information by Reporting Activity and Type of Reporter 5
Data Quality Considerations 10
Organization of Inventory - Mercury Supply, Use, and Trade 11
Supply of Mercury 12
Mercury Manufactured in the United States 14
Stored Mercury in the United States 15
Use of Mercury 16
Mercury Sold in the United States 17
Products Made in the United States 18
Products Sold in the United States 22
Mercury Used in Manufacturing Processes 26
Trade of Mercury 28
Imported Mercury 30
Imported Mercury-Added Products 31
Exported Mercury 35
Exported Mercury-Added Products 36
Conclusion and Data Interpretation 40
Identified Manufacturing Processes and Products 40
Manufacturing Processes 40
Products 40
Recommended Actions 41
Appendix A: Explanation of Key Terms 42
Appendix B: List of Mercury Compounds in the TSCA Chemical Substance Inventory 46
Appendix C: Categories and Subcategories of Mercury-Added Products 48
Appendix D: Manufacturing Processes for which Mercury is Otherwise Intentionally Used and
Relevant Functional Uses 49
Appendix E: Countries of Origin and Destination of Imported and Exported Mercury and
Mercury-Added Products 50
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
List of Tables
Table 1. Overview of Mercury Information Received Based on Type of Reporters 7
Table 2. Summary of Supply, Use, and Trade of Mercury in 2018 12
Table 3. Supply of Mercury in the United States (2018) 13
Table 4. List of Mercury Compounds Made in the United States (2018) 15
Table 5. Use of Mercury in the United States (2018) 16
Table 6. List of Products Made in the United States and Amount of Elemental Mercury Used,
Distributed, and Exported 19
Table 7. List of Products Made in the United States and Amount of Mercury Compounds Used,
Distributed, and Exported 20
Table 8. List of Products Sold in the United States in 2018 - Elemental Mercury 23
Table 9. List of Products Sold in the United States in 2018 - Mercury Compounds 24
Table 10. Distribution of Mercury-Added Products by Industry - Elemental Mercury 25
Table 11. Distribution of Mercury-Added Products by Industry - Mercury Compounds 26
Table 12. Manufacturing Processes that Used Elemental Mercury in 2018 27
Table 13. Manufacturing Processes that Used Mercury Compounds in 2018 27
Table 14. U.S. Trade of Mercury and Mercury-Added Products (2018) 29
Table 15. Imported Mercury Compounds 31
Table 16. List of Products Imported into the United States and Amount of Elemental Mercury
Used, Distributed, and Exported 33
Table 17. List of Products Imported into the United States and Amount of Mercury Compounds
Used, Distributed, and Exported 34
Table 18. Mercury Compounds Exported from the United States in 2018 36
Table 19. List of Products Exported from the United States and Amount of Elemental Mercury
Used, Distributed, and Exported 38
Table 20. List of Products Exported from the United States and Amount of Mercury Compounds
Used, Distributed, and Exported 39
List of Figures
Figure 1. Percent of Reporters Per Reporting Activity 6
Figure 2. U.S. Mercury Market 9
Figure 3. Amount (lbs) of Mercury Supplied and Stored by Type of Reporter 14
Figure 4. Amount of Mercury Used by Activity in 2018 17
Figure 5. Amount (lbs) and Percent of Total Elemental Mercury Used to Make Products by
Category 21
Figure 6. Amount (lbs) and Percent of Total Mercury Compounds Used to Make Products by
Category 21
Figure 7. Amount of Mercury Traded in 2018 30
Figure 8. Map of Countries of Origin of U.S. Imported Mercury-Added Products in 2018 32
Figure 9. Map of Countries to Where U.S. Exported Mercury-Added Products in 2018 37
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Background
Mercury is a naturally occurring element that originates in the earth's crust and exists as elemental
mercury or mercury compounds. Elemental mercury (CASRN 7439-97-6) is a shiny, silver-white
metal that is liquid at room temperature. Mercury does not degrade, cannot be destroyed, and is a
persistent and bioaccumulative toxicant. Emitted elemental mercury can be transported in the
atmosphere on local, regional, and global scales as it cycles through air, land, and water.1 Some of
the emitted elemental mercury following deposition and transformation into divalent mercury can
be biotransformed into methylmercury.2 Methylmercury can bioaccumulate and biomagnify in
fish, and can be consumed by humans, as well as marine mammals.3
Mercury compounds are formed when elemental mercury reacts with another substance, either in
nature or intentionally by humans. The U.S. Environmental Protection Agency (EPA) Toxic
Substances Control Act (TSCA) Chemical Substance Inventory lists 69 mercury compounds as
commercially available in the United States (see Appendix B of this report).4
Global Agreement on Mercury
The United States is a Party to the Minamata Convention on Mercury (Minamata Convention),
which entered into force on August 16, 2017. The objective of the Minamata Convention is to
protect human health and the environment from the adverse health effects of mercury.5 As of
January 2020, there are 128 signatory countries and 116 countries that have approved, accepted,
ratified, or acceded to the Convention. The Minamata Convention includes a number of provisions
to reduce exposure to mercury, including a ban on new mercury mines and the phase-out of
existing ones, and the phase-out and phase-down of mercury use in a number of specified products
and processes. Some articles of the Convention pertain only to elemental mercury while others
apply to mercury compounds as well. As discussed in the mercury inventory reporting rule, EPA
intends to use the collected information from the mercury inventory to assist in the United States'
national reporting for the Minamata Convention.6
U.S. Laws Affecting Supply and Trade of Elemental Mercury and Mercury
Compounds
Prior to the enactment of the Mercury Export Ban Act of 2008 (MEB A), 7 elemental mercury was
exported from the United States. In passing MEB A, Congress expressed concern about the use of
U.S. mercury in dispersive practices involving mercury in other countries and the impacts of global
1 EPA. Basic Information about Mercury. (No date). Available at https://www.epa.gov/mercurv/basic-information-
about-mercurv.
2 Ibid.
3 EPA. How People are Exposed to Mercury. (No date). Available at https://www.epa.gov/mercurv/how-people-are-
exposed-mercurv.
4 EPA. TSCA Chemical Substance Inventory. (No date). Available at https://www.epa.gov/tsca-inventorv.
5 United Nations Enviromnent Programme (UNEP). Minamata Convention on Mercury. (No date). Available at
http ://www. mercurvconvention. org.
6 "Reporting Requirements for TSCA Mercury Inventory: Mercury." 83 Fed. Reg. 30054 (June 27, 2018).
7 Mercury Export Ban Act of 2008. Pub. L. No. 110-414 (2008).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
mercury releases on the United States. Beginning in 2013, the law prohibited exports of elemental
mercury (with very limited exceptions),8 provided for long-term management and storage of
elemental mercury in the United States,9 and prohibited the sale, distribution or transfer of
elemental mercury held by U.S. federal agencies.10 While the export of pure elemental mercury is
illegal, the export of elemental mercury-added products (including those containing elemental
mercury) is generally not prohibited, except if the intent of the export is to recover elemental
mercury for resale or reuse.11 In 2016, the Frank R. Lautenberg Chemical Safety for the 21st
Century Act (Lautenberg Act) amended TSCA and expanded the export ban to include five
mercury compounds: mercury (I) chloride or calomel; mercury (II) oxide; mercury (II) sulfate;
mercury (II) nitrate; and cinnabar or mercury sulfide.12 The ban took effect on January 1, 2020.
The Lautenberg Act also directed that "[n]ot later than April 1, 2017, and every 3 years thereafter,
the Administrator shall carry out and publish in the Federal Register an inventory of mercury
supply, use, and trade in the United States."13 To assist in the preparation of the inventory, EPA
was also directed to promulgate a rule by June 22, 2018 to establish reporting requirements
applicable to persons who manufacture mercury or mercury-added products or who otherwise
intentionally uses mercury in a manufacturing process.14 In administering this mercury inventory,
the Agency will "identify any manufacturing processes or products that intentionally add mercury;
and . .. recommend actions, including proposed revisions of Federal law or regulations, to achieve
further reductions in mercury use."15 EPA finalized the mercury inventory reporting rule in June
2018.
8 15 U.S.C. § 2611(c)(1) and (4). MEBA authorizes EPA to provide limited essential use exemptions by rule for the
export of no more than 10 metric tons of elemental mercury under specified conditions. There are seven specific
findings EPA must make to grant an essential use exemption from the export ban. Requests for an essential use
exemption would only be granted through notice-and-comment rulemaking. The exemption must contain terms and
conditions that minimize export and ensure that conditions for granting the exemption are met. No exemption shall
last longer than three years or exempt more than ten metric tons of mercury.
9 42 U.S.C. § 6939f(a)(2).
1015 U.S.C. § 2605(f).
11 EPA. Questions and Answers on the Mercury Export Ban Act (MEBA) of 2008. (No date).
https://www.epa.gov/mercurv/auestions-and-answers-mercurv-export-ban-act-meba-2008.
1215 U.S.C. § 261 l(c)(7)(A)(i)-(v). TSCA section 12(c)(7) uses the term "mercury sulphide," which is an alternative
spelling of "mercury sulfide." Throughout this report, EPA is using "mercury sulfide" to be consistent with how the
chemical substance is listed in the TSCA Chemical Substance Inventory.
1315 U.S.C. § 2607(b)(10)(B).
1415 U.S.C. § 2607(b)(10)(D)(i).
1515 U.S.C. § 2607(b)(10)(C).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Introduction to the Inventory of Mercury Supply, Use,
and Trade
EPA prepared this national inventory report of supply, use, and trade of mercury as directed by the
Lautenberg Act, which defines "mercury" as "elemental mercury" or "a mercury compound."16
The Agency promulgated its mercury inventory reporting rule to provide the reporting
requirements, process, and schedule for persons who manufacture mercury or mercury-added
products or who otherwise intentionally use mercury in a manufacturing process. Based on the
information collected under the rule, the Agency, as appropriate, will identify any manufacturing
processes or products that intentionally add mercury and recommend actions to achieve further
reductions in mercury use as required by TSCA (see Conclusion and Data Interpretation section).
In 2017, EPA released its initial mercury inventory report,17 which was a compilation of publicly
available data on commodity mercury and was published prior to the promulgation of the mercury
inventory reporting rule and establishment of the electronic reporting application. The initial
mercury inventory fulfilled the statutory requirement and deadline to publish on or before April 1,
2017,18 but the information and data were notably limited in applicability for many aspects of
supply, use, and trade and, in some cases, were from outdated sources. The Agency also derived
information from other federal and state programs, including EPA's Chemical Data Reporting
(CDR) program, the Interstate Mercury Education and Reduction Clearinghouse (IMERC)
Mercury-added Products Database, and the U.S. International Trade Commission (ITC), as well
as other publicly available sources, and industry responses to EPA subpoenas.
This 2020 report is the first report in which the supply, use, and trade of mercury is presented
based on data collected by EPA under the mercury inventory reporting rule (40 CFR. Part 713).
Persons subject to the reporting requirements in 40 CFR Part 713 submitted information directly
to EPA via the Mercury Electronic Reporting (MER or reporting) application, which is organized
as a fill-in-the-blanks form with drop-down menus and lists of check-box options. The MER
application is accessed through the Agency's Central Data Exchange (CDX). The deadline for
reporting mercury information to EPA was July 1, 2019 for reporting activities that occurred in
the calendar year 2018, and the inventory collection and reporting cycle will continue every three
years thereafter to inform future inventories.19 Given the divergent information collection methods
between the 2017 and the 2020 inventories, the 2020 report intentionally does not draw any
comparisons between the initial 2017 inventory and the information reported in the 2020 report.
The Agency expects to be able to provide such comparisons no later than the 2023 inventory report.
1615 U.S.C. § 2607(b)(10)(A).
17 "Mercury; Initial Inventory Report of Supply, Use, and Trade" 82 Fed. Reg. 15522 (March 29, 2017). See also
https://www.regulations.gov/document?D=EPA-HO-OPPT-2017-0127-00Q2.
1815 U.S.C. § 2607(b)(10)(B).
19 The next report will be published on or before April 1, 2023 and will cover the reporting period of January 1 to
December 31, 2021. The next deadline for reporting is July 1, 2022.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
As set forth in the mercury inventory reporting rule, EPA expected to supplement certain data
elements with information reported to CDR and IMERC, as necessary, in order to avoid
duplicative reporting.20 However, after the 2018 reporting period closed, EPA's assessment found:
(1) the use of supplementary data from the CDR program or ITC was not necessary; and (2)
information updated by IMERC in 2018 (for the amount of mercury in products sold in the United
States in 2016) would be necessary to supplement data presented for domestic distribution in
commerce of mercury-added products (see Products Sold in the United States section).
Reporting Requirements
The reporting requirements for supply, use, and trade of mercury are categorized based on the
following terms: manufacture, import, use, distribution in commerce, storage, and export (refer to
the Explanation of Key Terms in Appendix A). Persons are required to report the amounts of
mercury in pounds (lbs) used in such activities with the purpose of obtaining an immediate or
eventual commercial advantage21 during a designated reporting year. Reporters are also required
to identify specific mercury compounds, mercury-added products, manufacturing processes, and
how mercury is used in manufacturing processes, as applicable, from preselected lists. For certain
activities, reporters are required to provide additional, contextual data (e.g., North American
Industry Classification System (NAICS) codes for mercury or mercury-added products distributed
in commerce). For purposes of this report, the reporting activities are described as follows:
1. Imported mercury
2. Mercury manufactured in the United States
3. Imported products
4. Products made in the United States (including certain assembled products)
5. Mercury used in a manufacturing process other than for manufacturing mercury-added
products or mercury compounds (hereafter referred to as "use in a manufacturing process")
Generally, under each reporting activity, EPA collected the following information in support of
this inventory report:
• Amount of mercury manufactured, imported, stored, used, sold, or exported;
• Types of products made;
• Types of manufacturing processes and how mercury was functionally used;
• Business sectors, or industries, to which mercury or mercury-added products were sold;
• Country of origin of imported mercury or mercury-added products; and
2015 U.S.C. § 2607(a)(5)(a) and 15 U.S.C. § 2607(b)(10)(D)(ii).
21 The Agency incorporated existing TSCA-defined terms "with the purpose of obtaining an immediate or eventual
commercial advantage" (see 15 U.S.C. § 2607(f) and 40 CFR 704.3) to be consistent with the statutory mandate at
15 U.S.C. § 2607(b)(10)(C)(i) to "identify any manufacturing processes or products that intentionally add mercury."
In addition, the Agency interprets "commercial advantage" to extend to benefits beyond profits, such as not
incurring additional operational costs by continuing to use mercury rather than use non-mercury substances or
technologies. Thus, to be required to report to the mercury inventory, persons must intentionally engage in activities
that introduce mercury into supply, use, and trade in the United States with the purpose of obtaining an immediate or
eventual commercial advantage.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
• Destination country for exported mercury (mercury compounds only)22 or mercury-added
products.
Information Not Required to Be Reported
TSCA requires EPA to publish a national inventory of mercury supply, use, and trade. The focus
of this report is on the data provided directly to EPA by those subject to the reporting requirements.
As described in the mercury inventory reporting rule, EPA determined that certain activities are
beyond the scope of the rulemaking (see list below and 40 CFR 713.7) and, therefore, are not
reported to the Agency. This includes amounts of mercury involved in in the following activities
and circumstances:
• An activity that is not for an immediate or eventual commercial advantage;
• The manufacture or import of mercury that exists only as an impurity;
• Activities by companies, organizations, and/or individuals engaged only in the generation,
handling, or management of mercury-containing waste, unless mercury is recovered to be
used in commerce;
• Mercury that is present during a manufacturing process, but was not intentionally added to
the product or process (e.g., mercury in equipment or tools); and
• Assembled products that contain mercury only in a component.
In other instances, reporting requirements were designed to prevent the duplication of information
submitted to other programs.23 For example, the final bullet in the list above describes information
that would be reported to IMERC (i.e., sale of assembled products that contain mercury only in a
component). In certain scenarios (e.g., a person first imports or manufactures a mercury-added
component and then uses it to produce an assembled product), EPA would collect information on
amounts of mercury in an assembled product. In such cases, Agency anticipated coordinating with
IMERC to ensure the completeness of products-related data in the mercury inventory.
Overview of Information by Reporting Activity and Type of Reporter
EPA received a total of 99 individual submissions for reporting year 2018. EPA's reporting
application allows for reporters to provide information on multiple reporting activities within one
submission. As a result, a total of 117 activities were reported among the 99 individual
submissions. Figure 1 illustrates the breakdown of the five reporting activities and the percent of
reports received for each activity.
22 See EPA. Questions and Answers on the Mercury Export Ban Act (MEBA) of 2008. (No date). Available at
https://www.epa.gov/mercurv/auestions-and-answers-mercurv-export-ban-act-meba-2008. See also discussion of
mercury export prohibitions in U.S. Laws Affecting Supply and Trade of Elemental Mercury and Mercury
Compounds and Exported Mercury sections.
23 Reporting requirements are different for submitters that report under the Interstate Mercury Education and
Reduction Clearinghouse or EPA's CDR program. The legal requirements for persons who must report can be found
at 40 CFR 713.7.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Figure 1. Percent of Reporters Per Reporting Activity
Use Mercury in a
Table 1 presents a culmination of data based on three types of reporters: (1) those who manufacture
or import mercury; (2) those who manufacture or import mercury-added products; and (3) those
who otherwise use mercury in a manufacturing process. Values are provided for elemental
mercury, mercury compounds, and the two combined for the total amount of mercury. For each
type of reporter and mercury, the table indicates the number of reporters, the amount of mercury
either manufactured, imported or used, as applicable, the amount of mercury stored, the amount
mercury distributed in commerce, and the amount of mercury exported.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 1. Overview of Mercury Information Received Based on Type of Reporters
Reported
Activities3
Amount (lbs)
Type of Reporter
Mfr'd/
Imp'd/
Usedb
Stored0
Distributed
Exported11
Elemental
Mercury
Mercury Manufacturer or
Importer
4
72,614
105,355
72,103
0
Product Manufacturer or
Importer
43
21,528
N/A
8,546
3,867
Use in a Manufacturing
Process
8
540,538
45,210
N/A
N/A
Mercury
Compound
Mercury Manufacturer or
Importer
5
457
1,382
1,393
148
Product Manufacturer or
Importer
51
3,364
N/A
441
2,052
Use in a Manufacturing
Process
6
34
213
N/A
N/A
Mercury Manufacturer or
Importer
9
73,071
106,737
73,496
148
Total®
Product Manufacturer or
Importer
94
24,892
N/A
8,987
5,919
Use in a Manufacturing
Process
14
540,572
45,423
0
0
a Some submissions contain multiple reporting activities, thus the total number of reported activities (117) is greater than
the total number of individual submissions received in the MER application (99).
b Based on type of reporter, this refers to the amount of mercury manufactured and imported, the amount in manufactured
and imported products, or the amount used in a manufacturing process.
0 Product manufacturers and importers are not required to provide information on stored mercury.
dIt is illegal to export elemental mercury and certain mercury compounds. Processors are not required to provide amounts
of mercury exported in mercury-added products because it is considered an unintended impurity.
e A combined total for elemental mercury and mercury compounds is provided as a snapshot of "mercury supply, use, and
trade in the United States" (15 U.S.C. § 2607(10)(A) and (B)).
The diagram of the U.S. mercury market in Figure 2 provides the overall context for the
commercial activities detailed in the inventory and how those activities relate to one another.
Figure 2 includes sources of commodity mercury and shows the way it moves in the economy.
From initial production ("manufacturing") and import, mercury can be stored, distributed
domestically, or, in the case of mercury compounds, exported. Once distributed, it can be used by
manufacturers of products or by processors in other manufacturing processes. Products can be
distributed in the United States or exported. In some cases, mercury remains in use in a product
until it becomes waste (e.g., dental amalgam). In other cases, a manufacturing process may use a
quantity of mercury on a continuous basis from year to year. For example, facilities producing
chlorine keep elemental mercury in use year after year and add a much smaller amount to the
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
reservoir of continuously used elemental mercury during any given year to replace losses.24 This
explains why the reported amounts of elemental mercury used in manufacturing processes are
substantial.
Because of the ways that amounts of mercury can be accounted for in supply, use, and trade phases,
there are instances where there could be overlap. For example, the same mercury can be
manufactured, stored, distributed in the United States, and used within the same year. In some
cases, mercury can be manufactured in one year and distributed in the next. In others, as mentioned
above in the case of chlor-alkali production, the use of a quantity of mercury could be considered
to be essentially static, which would frustrate an attempt to capture the total flow of mercury
through supply, use, and trade as a linear illustration. Therefore, Figure 2 captures a snapshot of
2018 data based on the three groups of reporters: (1) those who manufacture or import mercury;
(2) those who manufacture or import mercury-added products; and (3) those who otherwise use
mercury in a manufacturing process.
24 Chlor-Alkali Industry 2008 Mercury Use and Emissions in the United States—Twelfth Annual Report (August
2009). Available at https://arcliive.epa.gov/region5/mercurv/web/pdf/12thcl2report.pdf.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Figure 2. U.S. Mercury Market
Mercury Available for Commercial Use
• Mercury manufactured in the United States
• Imported mercury
• Mercury stored for future sale
Exported
(Mercury compounds
only)
Mercury Sold in the
United States
Used in Manufacturing Processes
• Added to process during the year
• Continuously used from prior years
• Stored for future use
Used to Make
Products
*
Exported Products
Products Sold in the
United States
Imported Products
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Data Quality Considerations
EPA issued a compliance guide and held webinars to explain the reporting requirements and how
to use the MER application.25 Despite these outreach efforts and notwithstanding the self-certified
accuracy of that information, information submitted to the EPA's reporting application is subject
to submitter error. For example, while reviewing data quality of the reports, EPA discovered that
several submissions under the reporting activity for use of mercury in a manufacturing process
were misreported and, after contacting the reporter, determined that the reported amount belonged
under the reporting activity of mercury-added products made in the United States. For such
submissions, the Agency manually calculated and transferred the numbers to the appropriate
reporting activity. In other instances, EPA directly contacted the reporters to request amended
submissions when the data provided appeared inaccurate (e.g., extremely high quantities of stored
mercury for several reporting activities within a single submission). EPA worked collaboratively
with the regulated community to ensure the accuracy of the information received and will continue
to do so going forward.
The MER application was designed to accurately capture the supply, use, and trade of mercury,
while collecting data in such a way as not only to allow for flexibility in the terms used by reporters
(e.g., manually-typed entries to "other" data fields), but also to allow for the relevant provision of,
and processes regarding, confidential business information (CBI). As a result, in a few limited
cases certain reporting activities relevant to supply, use, and trade may seemingly lack a detailed
account of specific quantities and its uses. In such instances, EPA lists contextual information (e.g.,
sub-categories of products, countries of origin or destination, or NAICS codes) with a generalized
description of a reporting activity and/or total amount of mercury. So, for example, if a reporter
imported multiple products such as lighting, measuring instruments, and formulated products, the
amounts of mercury for each of the three products and any relevant subcategories are unknown
because only one data field is available for the total amount of mercury in imported products. The
same applies to countries; if a reporter imported these products from multiple countries, the
amounts of mercury in products imported from each country are unknown, and again, one total
amount is indicated.
Lastly, EPA learned during an information collection effort in 2015 that companies working with
mercury operate differently from one another and may account for mercury flow in different ways.
For example, a company's business practices may result in mercury being manufactured in a non-
reporting year and stored both during that year and the reporting year (i.e., amount of mercury
reported for storage during the reporting year only). Therefore, as expected, the inventory does not
show that the overall amounts of mercury imported and manufactured equal the amounts of
mercury used, distributed, and exported. For example, the total amount of mercury compounds
used to make products and used in manufacturing processes in 2018 (1,941 lbs) does not equal the
sum of mercury compounds reported as manufactured and imported (457 lbs) during the same
year.
25 To assist in reporting to the mercury inventory, EPA provided outreach materials (see
https://www.epa.gov/mercurv/resources-mercurv-inventorv-reporting-rule). The compliance guide is available at
https://www.epa.gov/sites/production/files/2Q19-
05/documents/reporting requirements for the mercury inventory final.pdf. and the webinars can be found at
https://www.epa.gov/mercurv/webinars-mercurv-inventorv-reporting-rule-0.
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Organization of Inventory - Mercury Supply, Use, and Trade
Following this introduction, the inventory is presented in three sections: supply, use, and trade.
Each section discusses both elemental mercury and mercury compounds. In this report, the term
"mercury" used alone means both elemental mercury and mercury compounds. The five reporting
activities (imported mercury, mercury manufactured in the United States, imported products,
products made in the United States, and mercury used in a manufacturing process) are integrated
with other data to help provide context to the national mercury inventory.
EPA recognizes that the categories of data can be defined in different ways (see Appendix A for a
detailed explanation of key terms). For the purposes of this inventory report, domestic manufacture
and storage of mercury are considered supply because they are the sources of mercury that can
enter the U.S. market for sale. Mercury that was sold (distributed) in the United States could be
considered either: (1) supply of mercury (because it was supplied to purchasers); (2) use of
mercury (because sales information helps to illustrate use of mercury and mercury-added
products); or (3) trade of mercury (because sales are a measure of domestic commerce). In this
inventory, sale of mercury is categorized as use along with the manufacture and sale of mercury-
added products, and the intentional use of mercury in a manufacturing process. As explained in
the final rule, EPA requires contextual information on distribution, storage, and export in support
of the mercury inventory. For the purpose of this report, distribution is discussed under use of
mercury because the Agency is viewing the sale of mercury and mercury-added products through
the lens of the purchaser, who uses the mercury or mercury-added products. In this way, the
distribution of the supplied mercury is similar to the economic term of demand.
Trade in this inventory refers to international trade (i.e., imports and exports). As with distribution
of mercury, there is more than one category in which to place imports. Imported commodity
mercury could be considered part of supply (because the mercury can enter the domestic market
for sale), but because trade is defined as international trade for this report, imported commodity
mercury is placed in the section on trade, along with mercury exports. Limiting the category of
trade to international transactions is consistent with the organization of the 2016 EPA Report to
Congress on Mercury Global Supply and Trade.26 In this inventory, trade also includes import and
export of mercury-added products. Overall, this organization of supply, use, and trade parallels the
presentation of information in EPA's initial mercury inventory report of 2017.
Supply Manufacture (or production) and storage of mercury in the United States
Use Sale of mercury throughout the United States, manufacture and sale of
mercury-added products, and use of mercury in a manufacturing process
Trade Import and export of mercury and mercury-added products
26EPA. Report to Congress on the Global Supply and Trade of Elemental Mercury. December 2016. Available at
https ://www. epa. gov/sites/production/files/2017-
01/documents/mercurv global supply and trade rtc and signed transmittal letters.pdf.
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Table 2 provides a summary of the amount of elemental mercury, mercury compounds, and total
mercury for each reporting activity and contextual detail (e.g., amount stored, distributed, and
exported) as it pertains to supply, use, and trade.
Table 2. Summary of Supply, Use, and Trade of Mercury in 2018
Supply, Use, and Trade of Mercury
Elemental
Mercury
(lbs)
Mercury
Compounds
(lbs)
Total3
(lbs)
Supply
Mercury Manufactured in the United States
72,614
209
72,823
Stored On-site (max)
150,565
1,410
151,975
Stored Off-site (max)
0
185
185
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
mercury waste is recycled.27 Mercury compounds are generally produced by the chemical
manufacturing industry. Stored mercury that is available for commercial use is part of supply,
regardless of whether it was manufactured or imported. The inventory does not include waste,28
such as discarded excess elemental mercury, industrial waste containing mercury, or contaminated
soil. When mercury waste is recycled, elemental mercury is recovered and can be sold; this pure
mercury is considered "manufactured" and reportable. Due to an excess of supply, some privately
held, pure elemental mercury is in long-term storage and by law cannot be placed in commerce.29
In addition, the U.S. Department of Defense (DOD) and the U.S. Department of Energy (DOE)
store thousands of tons of elemental mercury, which are unable to be placed for sale on either the
United States or global market and are not contributing to the available domestic or global mercury
supply.30 This inventory report does not include any of the elemental mercury in such long-term
storage.31
Table 3. Supply of Mercury in the United States (2018)
Supply of Mercury
Elemental
Mercury
(lbs)
Mercury
Compounds
(lbs)
Total3
(lbs)
Manufactured in the United States
72,614
209
72,823
Stored On-site (max)
150,565
1,410
151,975
Stored Off-site (max)
0
185
185
aA combined total for elemental mercury and mercury compounds is provided as a snapshot of "mercury supply,
use, and trade in the United States" (15 U.S.C. § 2607(10)(A) and (B)).
The pie charts in Figure 3 show how much elemental mercury and mercury compounds are
stored by processors, stored by manufactures, and produced by manufactures in the United
States.
27 United States Geological Survey. Mercury Mineral Commodity Data Sheet 2019. Available at https ://prd-wret.s3-
us-west-2.amazonaws.com/assets/palladium/production/atoms/files/mcs-2019-mercu.pdf.
2815 U.S.C. § 2607(b)(10)(D)(iii).
29 42 U.S.C. § 6939(f).
3015 U.S.C. § 2605(f).
31 EPA determined that elemental mercury waste, whether generated from mining or another process, that is being
stored (or accumulated on-site and destined for storage) for eventual transfer to the DOE long-term mercury storage
facility, should, in accordance with TSCA section 8(10)(D)(iii), not be subject to the reporting requirements because
it is waste. If any person manufactures elemental mercury, including recovery from waste or as a byproduct from
mining or any other activity, and has not made the decision to store it for transfer to the DOE storage facility or to
otherwise handle it as waste, then that person must report that mercury. The Agency considers such mercury to be a
commodity, not waste, and, therefore, part of the U.S. mercury supply.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Figure 3. Amount (lbs) of Mercury Supplied and Stored by Type of Reporter
Supply of Elemental Mercury
Manufactured in
the U.S.
72,614
Stored for
Use by
Processors
45,210
Stored by Mercury
Manufacturers
105,355
Supply of Mercury Compounds
Manufactured
in the U.S.
209
Stored for
Use by
Processors
213
Stored by Mercury
Manufacturers
1,382
Mercury Manufactured in the United States
In 2018, a total of 72,823 lbs of mercury were manufactured in the United States. Four companies
manufactured 72,614 lbs of elemental mercury and three companies manufactured 209 lbs of
mercury compounds.
In 2015, the Agency gathered information from facilities engaged in large-scale domestic
recycling of elemental mercury in the years 2010 and 2013. In 2013, a total of 171,581 lbs was
reported for the manufacture of elemental mercury, as compared to the 72,614 lbs reported by
persons subject to the mercury inventory reporting ride in 2018. This represents a decrease of
98,967 lbs (>57percent) between 2013 and2018.
The types of mercury compounds made in the United States are identified in Table 4;32 however,
specific amounts of manufactured, distributed, and exported mercury compounds cannot be
determined due to the listing of multiple compounds within the submission forms.
32 A list of mercury compounds identified as "[m]ercury for which information must be reported"
CFR 713.5(b). See also Appendix B.
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can be found at 40
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 4. List of Mercury Compounds Made in the United States (2018)
CASRN
Mercury Compounds
54-64-8
Mercurate(l-), ethyl[2-(mercapto-.kappa. S)benzoato(2-).kappa.O]-,
sodium (1:1)
6283-24-5
Mercury, (acetato-.kappa.0)(4-aminophenyl)-
7774-29-0
Mercury iodide (Hgh)
13257-51-7
Acetic acid, 2,2,2-trifluoro-, mercury (2+) salt (2:1)
312623-78-2
Perchloric acid, mercury salt (1:1) tetrahydrate
For purposes of the mercury inventory reporting rule, the MER application, and the inventory
report, EPA describes mercury compounds as they are listed in the TSCA Chemical Substance
Inventory. In some contexts, mercury compounds may be more familiar as described by their
International Union of Pare and Applied Chemistry (IUPAC) name, which may be found via the
PubChem chemistry database of the National Institutes of Health (see
Imps: puhchem. ncbi. nlm.nih. gov/).
Stored Mercury in the United States
Mercury storage, either on-site or off-site, was reported by manufacturers, importers, and
processors of mercury. Those who store mercury as waste or manufacture or import mercury-
added products are not required to report mercury storage.33 The manufacturing processes for
which mercury was stored include chlorine production and quality control testing and analysis.
Mercury Stored On-Site
In total, the maximum amount of mercury stored onsite in the United States at any given time
during 2018, as reported by manufacturers, importers, and processors of mercury, was 151,975
lbs. The maximum amount of elemental mercury stored was 150,565 lbs and the maximum amount
of mercury compounds stored was 1,410 lbs.
Mercury Stored Off-Site
Elemental mercury was not reported as stored off-site in 2018. One company reported storing up
to 185 lbs of mercury compounds off-site for use in the quality control test manufacturing process.
<40 CFR 713.9.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
In 2015, the Agency gathered information from facilities engaged in large-scale domestic
recycling of elemental mercury in the years 2010 and 2013. In 2013, a total of 364,539 lbs was
reportedfor the storage of elemental mercury, as compared to the 105,355 lbs reported by persons
subject to the mercury inventory reporting ride in 2018. This represents a decrease of259,184 lbs
(> 71 percent) between 2013 and 2018. Note that this comparison does not include mercury stored
for use by processers (see Figure 3 and Table 2), which explains the difference in the "Stored On-
site (max) " amount shown in Table 3.
Use of Mercury
Use of mercury includes the sale of mercury in the United States, the manufacture and sale of
mercury-added products, and the intentional use of mercury in manufacturing processes (see Table
5 and Figure 4). For the purpose of this report, distribution is discussed under use of mercury
because the Agency is viewing the sale of mercury and mercury-added products through the lens
of the purchaser, who uses the mercury or mercury-added products. In this way, the distribution
of the supplied mercury is similar to the economic term of demand. To avoid counting the same
mercury twice, the amounts of mercury used for these four activities are not totaled.
Table 5. Use of Mercury in the United States (2018)
Use of Mercury
Elemental
Mercury
(lbs)
Mercury
Compounds
(lbs)
Totalb
(lbs)
Mercury Sold in the United States
72,103
1,393
73,496
Products Made in the United States
19,840
1,907
21,747
Products Sold in the United States
8,546
441
8,987
Mercury Used in a Manufacturing Process
540,538a
34
540,572
Tn addition to the amount of mercury compounds manufactured, one mercury compound manufacturer also
indicated the amount of elemental mercury used to make the compounds; similarly, one manufacturer of mercury
compound-added products reported the amount of elemental mercury used in addition to the amount of mercury
compounds used to make the products. Therefore, the amount of elemental mercury involved in these two
reporting activities for mercury compounds is included under the reporting activity of "otherwise used mercury in
a manufacturing process."
bA combined total for elemental mercury and mercury compounds is provided as a snapshot of "mercury supply,
use, and trade in the United States" (15 U.S.C. § 2607(10)(A) and (B)).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Figure 4. Amount of Mercury Used by Activity in 201834
Mercury Sold in the United States
Products Made in the United States
Products Sold in the United States
Mercury Used in a Manufacturing Process
1 10 100 1,000 10,000 100,000 1,000,000
Amount of Mercury (lbs)
¦ Elemental Mercury ¦ Mercury Compounds
Mercury Sold in the United States
Elemental mercury that is manufactured or imported into the United States can only be distributed
or sold for use within the United States because it is unlawful to export it. During the reporting
year, mercury compounds were allowed to be exported. In 2018, 72,103 lbs of elemental mercury
and 1,393 lbs of mercury compounds were distributed nationwide, totaling 73,496 lbs of
distributed mercury (see Table 5 and Figure 4). According to reporters, elemental mercury and
mercury compounds were distributed to a variety of industries, which were identified by NAICS
code.
Elemental mercury was distributed to the following industries:
• All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
• All Other Miscellaneous Electrical Equipment and Component Manufacturing (335999)
• Analytical Laboratory Instrument Manufacturing (334516)
• Commercial, Industrial, and Institutional Electric Lighting Fixture Manufacturing
(335122)
• Dental Equipment and Supplies Manufacturing (339114)
• Other Basic Inorganic Chemical Manufacturing (325180)
• Secondary Smelting, Refining, And Alloying of Nonferrous Metal (Except Copper and
Aluminum) (331492)
• Testing Laboratories (541380)
34 As a note to readers, figures in this document are reported in a logarithmic scale to account for a wide range in
mercury quantities. See Explanation of Key Terms section for additional information on logarithmic scales.
Page 17
72,103
1,393
19,840
1,907
8,546
441 ¦
540,538
34
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Mercury compounds were distributed to the following industries:
• Administration of Air and Water Resource and Solid Waste Management Programs
(924110)
• All Other Basic Organic Chemical Manufacturing (325119)
• Biological Product (Except Diagnostic) Manufacturing (325114)
• Colleges, Universities, And Professional Schools (611310)
• Electron Tube Manufacturing (334411)
• Elementary and Secondary Schools (611110)
• General Medical and Surgical Hospitals (622110)
• In-Vitro Diagnostic Substance Manufacturing (325413)
• Medical Laboratories (621511)
• Medicinal and Botanical Manufacturing (325411)
• Other Chemical and Allied Products Merchant Wholesalers (424690)
• Process, Physical Distribution, And Logistics Consulting Services (541614)
• Research and Development in Biotechnology (541715)
Products Made in the United States
In total, 21,747 lbs of mercury were used for the domestic manufacture of mercury-added products
in 2018. Of this total, 19,840 lbs of elemental mercury were used to manufacture elemental
mercury-added products, and 1,907 lbs of mercury compounds were used to manufacture mercury
compound-added products (see Table 5 and Figure 4). The types of mercury-added products
manufactured in the United States are identified in Table 6 for elemental mercury and Table 7 for
mercury compounds.35 For each product category, the amount of mercury used, distributed, and
exported in products is provided. EPA identified "products that intentionally add mercury" 36 and
in the Conclusion and Data Interpretation section noted those products that it was unaware of
prior to receiving the 2018 reporting data.
EPA identified the following additional uses of mercury in mercury-added products through the
information submitted under the mercury inventory reporting ride:
- The "burners " aspect of "low t IV gas discharge lamps and burners "
- Wheel emblem
- Lead in water sensor
- Mercury analyzer
- Air cylinders
- Connector pins
- Mass flow controllers
- Printed circuit board
- Motors
35 A list of mercury-added products identified as "[s]pecific requirements for which information must be reported."
can be found at 40 CFR 713.11(b). See also Appendix C.
3615 U.S.C. § 2607(b)(10)(C).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 6. List of Products Made in the United States and Amount of Elemental Mercury Used,
Distributed, and Exported
Products Made in the United States
- Elemental Mercury
Product Category and Subcategory
Amount in Products (lbs)
Used
Distributed3
Exported
Dental Amalgam
9,287
0
2,624
Lighting, Lamps, and Bulbs
1,637
18
362
Compact Fluorescent
High Pressure Sodium
Linear Fluorescent
Mercury Vapor
Metal Halide
U-Tube and Circular Fluorescent
Miscellaneous/Novelty
1
Plasma Display (Fill Tubes at Seal Pump and
Burst at RTV Operation)
Switches, Relays, Sensors, and Valves
8,915
8,519
315
Displacement Relay
Float Switch
Tilt Switch
Total
19,840
8,537
3,301
aThe range of 2018 data reported to the MER application and 2016 data reported to the IMERC Mercury-added
Products Database is presented in the Products Sold in the United States section.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 7. List of Products Made in the United States and Amount of Mercury Compounds
Used, Distributed, and Exported
Products Made in the United States -
- Mercury Compounds
Product Category and Subcategory
Amount in Products (lbs)
Used
Distributed3
Exported
Batteries
119
0
0
Silver-Zinc
Formulated Products
290
151
121
Preservative (Vaccine Usage)
Other Formulated Products
1,496
85
1,767
In-Vitro Diagnostics
Pharmaceuticals
Preservative (Non-Vaccine Usage)
Reagents (Catalysts, Buffers, and Fixatives)
Testing Kits
Lighting, Lamps, and Bulbs
1
1
Electrodeless Discharge
Miscellaneous/Novelty
1
Plasma Display (Fill Tubes at Seal Pump and
Burst at RTV Operation)
Total
1,907
236
1,889
aThe range of 2018 data reported to the MER application and 2016 data reported to the IMERC Mercury-added
Products Database is presented in the Products Sold in the United States section.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Figures 5 and 6 provide visual representations of the amounts of elemental mercury and mercury
compounds used to make products in the United States.
Figure 5. Amount (lbs) and Percent of Total Elemental Mercury Used to Make Products by
Category
Figure 6. Amount (lbs) and Percent of Total Mercury Compounds Used to Make Products by
Category
Lighting, Lamps, Bulbs
1
0.1%
Miscellaneous
1
0.1%
Preservatives
290
15.2%
Other Formulated
Products
1,496
78.4%
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Products Sold in the United States
Mercury-added products are sold, or distributed, throughout the United States by both product
manufacturers and importers (see Trade of Mercury section for more information on imported
mercury-added products). As described in the mercury inventory reporting rule, EPA sought to
avoid duplicative reporting for persons who traditionally report nationwide sales data to the
IMERC Mercury-Added Products Database.37 As such, the Agency, as necessary, supplements
data reported directly to the MER application with the most recent available data from IMERC. In
this report, the Agency presents nationwide sales data as a range between 2018 data reported to
EPA and data updated by IMERC in 2018 (for the amount of mercury in products sold in the
United States in 2016), as a combined "mercury" total.
In 2018, the total amount of mercury distributed in mercury-added products in the United States
was between 8,987 and 75,619 lbs.38 For amounts reported to the EPA's reporting application,
those products contained 8,546 lbs of elemental mercury and 441 lbs of mercury compounds.
Specific amounts of mercury for each product are not required to be reported by the rule;39
however, analysis of the reports indicates that lighting products were reported by the greatest
number of persons reporting for mercury-added product distributed in the United States. Tables 8
and 9 contain lists of categories and sub-categories of mercury-added products sold in the United
States.40 The number of reporters and the NAICS codes to which elemental mercury-added
products and mercury compound-added products were distributed in the United States are
presented in Tables 10 and 11.
37 83 Fed. Reg. 30062.
38 New England Waste Management Officials' Association, IMERC Fact Sheet: Current Fact Sheets - Updated
December 2018. Accessible at http://www.newmoa.org/prevention/mercurv/imerc/FactSheets/index.cfm.
39 40 CFR 713.9.
411A list of mercury-added products identified as "[s]pecific requirements for which information must be reported."
can be found at 40 CFR 713.11(b). See also Appendix C.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 8. List of Products Sold in the United States in 2018 — Elemental Mercury
Elemental Mercury-Added Products
Product Category
Batteries
Lighting, Lamps, and Bulbs
Measuring Instruments
Switches, Relays, Sensors, and Valves
Miscellaneous and Novelty Products
Product Subcategory
Lithium-ion Manganese Dioxide
Cold Cathode Fluorescent
Compact Fluorescent
External Electrode Fluorescent
High Pressure Mercury Vapor Lamps
High Pressure Sodium
Induction A-Lamps
Linear Fluorescent
Mercury Short Arc
Mercury Vapor
Metal Halide
U-Tube and Circular Fluorescent
UV and Germicidal
Xenon Electric Discharge Lamp
Flow Meter
Hydrometer
Hygrometer/Psychrometer
Mercury Analyzer
Thermometer
Float Switch
Pressure Switch
Temperature Switch
Thermostat
Tilt Switch
Air Cylinders
Connector Pins
Mass Flow Controllers
Printed Circuit Boards
Motors
Plasma Display (Fill Tubes at Seal
Pump and Burst at RTV Operation)
Pumps and Flow Meters
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 9. List of Products Sold in the United States in 2018 -Mercury Compounds
Mercury Compound-Added Products
Product Category
Product Subcategory
Formulated Products
Preservatives (Vaccination Usage)
Reagents (Catalysts, Buffers, Fixatives)
Cold Cathode Fluorescent
Compact Fluorescent
High Pressure Sodium
Linear Fluorescent
Low UV Gas Discharge Lamps and
Burners
Mercury Short Arc
Lighting, Lamps, and Bulbs
Mercury Vapor
Metal Halide
Purifi cati on/Germi ci dal
Scanner Lamps
U-Tube and Circular Fluorescent
Ultra-High Efficiency
UV and Germicidal
UV Curable Lamp
Xenon Electric Discharge Lamps
Plasma Display (Fill Tubes at Seal
Miscellaneous/Novelty
Pump and Burst at RTV Operation)
Wheel Emblem
Switches, Relays, Sensors, and Valves
Lead in Water Sensor
Tilt Switch
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 10. Distribution of Mercury-Added Products by Industry — Elemental Mercury
Industries that Purchased U.S. Manufactured and Imported
Elemental Mercury-Added Products
Industry Sector Number Reported
Accommodation and Food Services 2
Administrative and Support and Waste Management and ^
Remediation Services
Agriculture, Forestry, Fishing and Hunting 2
Arts, Entertainment, and Recreation 4
Construction 2
Educational Services 2
Manufacturing 84
Other Services (except Public Administration) 7
Professional, Scientific, and Technical Services 3
Real Estate and Rental and Leasing 1
Retail Trade 1_3
Utilities 1
Wholesale Trade 9
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 11. Distribution of Mercury-Added Products by Industry - Mercury Compounds
Industries that Purchased U.S. Manufactured and Imported
Mercury Compound-Added Products
Industry Sector
Number Reported
Accommodation and Food Services
5
Agriculture, Forestry, Fishing and Hunting
3
Arts, Entertainment, and Recreation
2
Construction
7
Educational Services
6
Health Care and Social Assistance
5
Information
2
Manufacturing
53
Other Services (except Public Administration)
6
Professional, Scientific, and Technical Services
19
Public Administration
5
Real Estate and Rental and Leasing
1
Retail Trade
25
Transportation and Warehousing
2
Utilities
7
Wholesale Trade 39
Mercury Used in Manufacturing Processes
The otherwise intentional use of mercury in a manufacturing process means to use mercury to
manufacture anything other than a mercury-added product or a mercury compound. Examples
include the use of mercury as a catalyst, cathode, reactant, or reagent. In 2018, 540,538 lbs of
elemental mercury were used in manufacturing processes, the bulk of which was in continuous
use, and 34 lbs of mercury compounds were used. Thus, a total of 540,572 lbs of mercury were
used in manufacturing processes in 2018 (see Table 5 and Figure 4).
In a manufacturing process, mercury performs a specific function and is used for a particular
purpose. For elemental mercury and mercury compounds, Tables 12 and 13 respectively list the
types of manufacturing processes, how mercury was functionally used, and the industries, if any,
to which end products of that manufacturing process were distributed in the United States.41 In
some cases, end products that result from these manufacturing processes may contain trace
amounts of mercury, but are not considered mercury-added products. No exports were reported by
these processors.
41 Lists applicable to manufacturing processes for which mercury is otherwise intentionally used identified as
"[s]pecific requirements for which information must be reported." can be found at 40 CFR 713.11(c). See also
Appendix D.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 12. Manufacturing Processes that Used Elemental Mercury in 2018
Use of Elemental Mercury in Manufacturing Processes
Manufacturing Process
Functional Use
Industry of Distribution
Bonding Weld Head
Catalyst
None
Catalyst Porosity Testing
Catalyst
None
Chlorine Production (e.g.,
mercury-cell chlor-alkali
process)
Cathode
Other Basic Inorganic
Chemical Manufacturing
Molecular Beam Epitaxy
Molecular Beam Epitaxy
Guided Missile and Space
Vehicle Manufacturing;
Guided Missile and Space
Vehicle Propulsion Unit and
Propulsion Unit Parts
Manufacturing;
Semiconductor and Related
Device Manufacturing
Quality Analysis
Density Measurement of
Tungsten Bars
None
Table 13. Manufacturing Processes that Used Mercury Compounds in 2018
Use of Mercury Compounds in Manufacturing Processes
Manufacturing Process
Functional Use
Industry of Distribution
Impurity, Catalyst
Impurity, Catalyst, Reagent
None
Inactivation
Inactivation
Biological Product (Except
Diagnostic) Manufacturing
Laboratory Test
Catalyst
All Other Miscellaneous
Chemical Product and
Preparation Manufacturing
Pharmaceutical Manufacture
and Storage for Lab Quality
Control
Reagent
None
Quality Control Test
Small Arms Ammunition
Case-Mercury Stress Crack
None
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
The Minamata Convention identifies the following manufacturing processes in which elemental
mercury or mercury compounds are used:
• Chlor-alkali production
• Acetaldehyde production in which elemental mercury or mercury compounds are used as
a catalyst
• Vinyl chloride monomer production
• Sodium or Potassium Methylate or Ethylate
• Production of polyurethane using mercury containing catalysts
In developing the mercury inventory reporting requirements, the Agency incorporated these
processes in "[sjpecific requirements for which information must be reported" at 40 CFR
713.11(c). 42 These processes are subject to be phased out in those countries that are party to the
Minamata Convention, beginning in 2018. With one exception, chlorine production (e.g., mercury-
cell chlor-alkali process), the processes identified in the Convention have ceased to be used in the
United States for several years.
Chlor-alkali production (labelled as "Chlorine production (e.g., mercury-cell chlor-alkali
process) " in the Mercury Inventory Reporting Ride and the MER application) is the only process
from the above list that was identified as actively practiced in the United States in 2018. There are
two remaining facilities using this process, of which one began the process of converting to non-
mercury processes in 2017.
EPA identified "manufacturing processes . . . that intentionally add mercury" 43 in the box below
and in the Conclusion and Data Interpretation section those products that it was unaware of prior
receiving the 2018 reporting data.
EPA identified the following additional uses of mercury in manufacturing processes through the
information submitted under the mercury inventory reporting ride:
- Bonding weld head (catalyst)
- Molecular beam epitaxy
- Quality analysis (density measurement of tungsten bars)
- Inactivation
- Quality control test (small arms ammunition case-mercury stress crack)
Trade of Mercury
Elemental mercury and mercury compounds are commodities that are bought and sold worldwide,
although the United States prohibits the export of certain mercury (see Exported Mercury section).
42 After considering the public comments received on the Mercury Inventory Reporting Rule, EPA removed the term
"Vinyl chloride monomer production" from the options of categories of manufacturing processes for which mercury
may be intentionally used. See Response to Comments (RIN 2070-AK22; Final Rule); EPA-HQ-OPPT-2017-0421-
0102). See also Appendix D.
4315 U.S.C. § 2607(b)(10)(C).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Mercury-added products in which elemental mercury or mercury compounds are used are also
imported to and exported from the United States. Table 14 and Figure 7 illustrate the amounts of
mercury imported and exported for these reporting activities.
Trade in this inventory refers to international rather than domestic commerce, despite there being
other ways to define it. Imported commodity mercury could be considered part of supply (because
the mercury can enter the domestic market for sale), but because trade is defined as international
trade for this report, imported commodity mercury is placed in the section on trade, along with
mercury exports. Limiting the category of trade to international transactions is consistent with the
organization of the 2016 EPA Report to Congress on Mercury Global Supply and Trade.44
Table 14. U.S. Trade of Mercury and Mercury-Added Products (2018)
Trade of Mercury
Elemental
Mercury
(lbs)
Mercury
Compounds
(lbs)
Total3
(lbs)
Imported Mercury
0
248
248
Imported Products
1,548
1,458
3,006
Exported Mercury
0
148
148
Exported Products
3,867
2,052
5,919
aA combined total for elemental mercury and mercury compounds is provided as a snapshot of "mercury supply,
use, and trade in the United States" (15 U.S.C. § 2607(10)(A) and (B)).
44 See https://www.epa. gov/sites/production/files/2017-
01/documents/mercurv global supply and trade rtc and signed transmittal letters.pdf.
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Inventory of Mercury Supply, Use, and Trade in the United States -
Figure 7. Amount of Mercury Traded in 201845
2020 Report
Imported Mercury
*No elemental mercury was imported
Elemental Mercury
I Mercury Compounds
Imported Products
1,548
1,458 |
Exported Mercury
*No elemental mercury was exported
Exported Products
3,867
10 100
Amount of Mercury (lbs)
1000
10000
Imported Mercury
Elemental mercury was not imported in 2018. Only 248 lbs of mercury compounds were imported
to the United States from seven countries: Armenia, Czech Republic, Germany, India, Switzerland,
Spain, and the United Kingdom (see Appendix E). The specific mercury compounds imported into
the United States are identified in Table 15.46
45 As a note to readers, figures in this document are reported in a logarithmic scale to account for a wide range in
mercury quantities. See Explanation of Key Terms section for additional information on logarithmic scales.
46 A list of mercury compounds identified as "[m]ercury for which information must be reported" can be found at 40
CFR 713.5(b). See also.ippenclix B.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 15. Imported Mercury Compounds
CASRN
Mercury Compound
54-64-8
Mercurate(l-), ethyl[2-(mercapto-.kappa. S)benzoato(2-).kappa.O]-,
sodium (1:1)
59-85-8
Mercurate(l-), (4-carboxylatophenyl)chloro-, hydrogen
62-38-4
Mercury, (acetato-.kappa.0)phenyl-
115-09-3
Chloromethylmercury
129-16-8
Mercurochrome Practical Grade
138-85-2
Mercurate(l-), (4-carboxylatophenyl)hydroxy-, sodium (1:1)
592-04-1
Mercury cyanide (Hg(CN)2)
592-85-8
Thiocyanic acid, mercury(2+) salt (2:1)
1344-48-5
Mercury sulfide (HgS)
1600-27-7
Acetic acid, mercury(2+) salt (2:1)
7774-29-0
Mercury iodide (Hgh)
7783-33-7
Mercurate(2-), tetraiodo-, potassium (1:2), (T-4)-
7783-34-8
Mercury(II) nitrate monohydrate
7783-35-9
Sulfuric acid, mercury(2+) salt (1:1)
8003-05-2
Basic phenylmercury nitrate
10045-94-0
Nitric acid, mercury(2+) salt (2:1)
145889-57-2
4,5,-Dimethyl-3-6-dioctyloxy-o-phenylene-
bis(mercurytrifluoroacetate)
304656-34-6
Mercury(II) perchlorate hydrate
UNKNOWN
Estuarine sediment (total Hg and methylmercury) ERM® certified
Reference Material
Imported Mercury-Added Products
In 2018, the United States imported mercury-added products from the following 23 counties:
Belgium, Canada, China, Denmark, Germany, Hungary, India, Indonesia, Israel, Italy, Japan, the
Republic of Korea, Mexico, the Netherlands, New Zealand, Poland, Russia, Singapore, Spain,
Sweden, Switzerland, Taiwan, and the United Kingdom (see Figure 8).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Figure 8. Map of Countries of Origin of U.S. Imported Mercury-Added Products in 2018
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The total amount of elemental mercury imported into the United States in mercury-added products
was 1,548 lbs, while the total amount of mercury compounds in imported mercury-added products
was 1,458 lbs. Thus, the total amount of mercury imported into the United States in mercury-added
products was 3,006 lbs for reporting year 2018 (see Table 14). The types of imported mercury-
added products are listed by category and subcategory in Tables 16 and 17 for elemental mercury
and mercury compounds, respectively. Where available, values are provided for each product
category; however, some reporters imported multiple products and the amount of mercury per
product category is not available. Therefore, a combined total amount imported for multiple
products is depicted.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 16. List of Products Imported into the United States and Amount of Elemental Mercury
Used, Distributed, and Exported
Imported Products -
Elemental Mercury
Product Category and Subcategory
Amount in Products (lbs)
Used
Distributed3
Exported
Batteries
1
0
0
Lithium-Ion and Manganese Dioxide
Lighting, Lamps, and Bulbs
948
8
276
Cold Cathode Fluorescent
Compact Fluorescent
External Electrode Fluorescent
High Pressure Mercury Vapor Lamps
High Pressure Sodium
Induction A-lamps
Linear Fluorescent
Mercury Vapor
Metal Halide
Mercury Short Arc
U-Tube and Circular Fluorescent
UV and Germicidal
Xenon Electric Discharge Lamp
Switches, Relays, Sensors, and Valves
Temperature Switch
Measuring Instruments
Mercury Analyzer
Flow Meter
Hydrometer
Hygrometer/Psychrometer
Miscellaneous/Novelty Products
Air Cylinders
Connector Pins
Flow Meters
Mass Flow Controllers
Motors
Printed Circuit Boards
Pumps
Other Imported Products Combined13 599 1 290
Total 1,548 9 566
aThe range of 2018 data reported to the MER application and 2016 data reported to the IMERC Mercury-added
Products Database is presented in the Products Sold in the United States section.
bReporters indicated imported products under multiple product categories: lighting, switches, measuring instruments,
and miscellaneous products; therefore, amounts for each category are not discernible and a combined total is provided.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 17. List of Products Imported into the United States and Amount of Mercury
Compounds Used, Distributed, and Exported
Imported Products - Mercury Compounds
Product Category and Subcategory
Amount in Products (lbs)
Used
Distributed3
Exported
Formulated Products
13
7
1
Preservative (Vaccine Usage)
/
Other Formulated Products
Reagents (Catalysts, Buffers,
Fixatives)
Lighting, Lamps, and Bulbs
1,369
196
142
Cold Cathode Fluorescent
Compact Fluorescent
High Pressure Sodium
Linear Fluorescent
Low UV Gas Discharge Lamps and Burners
Mercury Short Arc
Mercury Vapor
Metal Halide
Purifi cati on/Germi ci dal
Scanner Lamps
U-Tube and Circular Fluorescent
Ultra-High Efficiency
UV and Germicidal
UV Curable Lamp
Miscellaneous/Novelty
1
1
Wheel Emblem
Switches, Relays, Sensors, and Valves
1
1
1
Lead in Water Sensor
Tilt Switch
Other Imported Products Combined13
74
1
20
Total
1,458
206
164
aThe range of 2018 data reported to the MER application and 2016 data reported to the IMERC Mercury-added
Products Database is presented in the Products Sold in the United States section.
bReporters indicated imported products under multiple product categories: lighting, switches, measuring instruments,
and miscellaneous products; therefore, amounts for each category are not discernible and a combined total is provided.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Exported Mercury
Under the MEBA, it is illegal to export elemental mercury from the United States47 and effective
January 1, 2020, five mercury compounds are, like elemental mercury, also prohibited from
export.48 Those compounds are:
• Mercury (I) chloride or calomel (CASRN 10112-91-1)
• Mercury (II) oxide (CASRN 21908-53-2)
• Mercury (II) sulfate (CASRN 7783-35-9)
• Mercury (II) nitrate (CASRN 10045-94-0)
• Cinnabar or mercury sulfide (CASRN 1344-48-5)
For the 2018 reporting year, an aggregated total of 148 lbs of over twenty types of mercury
compounds were exported from the United States (see Table 14). Specific amounts of each
exported mercury compound cannot be differentiated due to the listing of multiple compounds
within the submission forms. However, based on reports, most of the mercury compounds that are
made in and imported into the United States are also exported. The specific mercury compounds
imported into the United States are identified in Table 18.49
Only two of the five mercury compounds now prohibitedfi'om export (as reported "Sulfuric acid,
mercury(2^) salt (1:1)" and "Nitric acid, mercury(2+) salt (2:1)") were reported as exported
during the 2018 reporting period (i.e., prior to the export prohibition taking effect).
4715 U.S.C. 2611(c)(1).
4815 U.S.C. 261 l(c)(7)(A)(i)-(v). However, the statute provides an exception to the export prohibition for export of
listed mercury compounds to member countries of the Organization for Economic Co-operation and Development
for environmentally sound disposal, on the condition that no mercury or mercury compounds so exported are to be
recovered, recycled, or reclaimed for use, or directly reused, after such export. 15 U.S.C. 2611(c)(7)(D). Currently
the United States is only able to export such waste to Canada in accordance with Article 11 of the Basel Convention.
The statute also provides that EPA, on determining that exporting any additional mercury compound for the purpose
of regenerating elemental mercury is technically feasible, may add by rule such mercury compound to the published
list (15 U.S.C. 261 l(c)(7)(A)(vi)). In addition, any person may petition EPA to issue a rule to add a mercury
compound to this published list (15 U.S.C. 2611(c)(7)(C)).
49 A list of mercury compounds identified as "[mjercury for which information must be reported" can be found at 40
CFR 713.5(b). See also Appendix B.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 18. Mercury Compounds Exported from the United States in 2018
CASRN
Mercury Compound
54-64-8
Mercurate(l-), ethyl[2-(mercapto-.kappa. S)benzoato(2-).kappa.O]-,
sodium (1:1)
59-85-8
Mercurate(l-), (4-carboxylatophenyl)chloro-, hydrogen
62-38-4
Mercury, (acetato-.kappa.0)phenyl-
138-85-2
Mercurate(l-), (4-carboxylatophenyl)hydroxy-, sodium (1:1)
115-09-3
Chloromethylmercury
129-16-8
Mercurochrome Practical Grade
592-85-8
Thiocyanic acid, mercury(2+) salt (2:1)
592-04-1
Mercury cyanide (Hg(CN)2)
1344-48-5
Mercury sulfide (HgS)
1600-27-7
Acetic acid, mercury(2+) salt (2:1)
6283-24-5
Mercury, (acetato-.kappa.0)(4-aminophenyl)-
7783-35-9
Sulfuric acid, mercury(2+) salt (1:1)
7783-34-8
Mercury(II) nitrate monohydrate
7783-33-7
Mercurate(2-), tetraiodo-, potassium (1:2), (T-4)-
7774-29-0
Mercury iodide (Hgh)
8003-05-2
Basic phenylmercury nitrate
10045-94-0
Nitric acid, mercury(2+) salt (2:1)
13257-51-7
Mercury bis(trifluoracetate)
145889-57-2
4,5,-Dimethyl-3-6-dioctyloxy-o-phenylene-
bis(mercurytrifluoroacetate)
304656-34-6
Mercury(II) perchlorate hydrate
UNKNOWN
Estuarine sediment (total Hs and methylmercury) ERM® certified
Reference Material
Exported Mercury-Added Products
While the export of pure elemental mercury is illegal, the export of elemental mercury-added
products (including those containing elemental mercury) is generally not prohibited. Therefore,
mercury-added products generally may be exported from the United States after first being
manufactured domestically or imported, except if the intent of the export is to recover
elemental mercury for resale or reuse.50 The United States exports mercury-added products to 82
countries, which are depicted in the map in Figure 9, as well as in Appendix E.
511 EPA. Questions and Answers on the Mercury Export Ban Act (MEBA) of 2008. (No date). Available at
https://www.epa.gov/mercurv/questions-and-answers-mercurv-export-ban-act-meba-2008.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Figure 9. Map of Countries to Where U.S. Exported Mercury-Added Products in 2018
In total, for reporting year 2018, 5,919 lbs of mercury were exported in mercury-added products.
Elemental mercury used in mercury-added products that were exported from the United States
totaled 3,867 lbs. Mercury compounds used in mercury-added products that were exported from
the United States totaled 2,052 lbs (see Table 14). The types of exported mercury-added products
are listed by category and subcategory in Tables 19 and 20 for elemental mercury and mercury
compounds respectively.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 19. List of Products Exportedfrom the United States and Amount of Elemental Mercury
Used, Distributed, and Exported
Products Exported from the United Stal
tes - Elemental Mercury
Product Category and Subcategory
Amount in Products (lbs)
Used
Distributed3
Exported
Dental Amalgam
9,287
0
2,624
Lighting, Lamps, and Bulbs
2,084
20
638
Compact Fluorescent
External electrode fluorescent
High Pressure Mercury Vapor Lamps
High Pressure Sodium
Linear Fluorescent
Mercury Vapor
Metal Halide
Mercury Short Arc
U-Tube and Circular Fluorescent
Measuring Instruments
Flow Meter
Hydrometer
Hygrometer/Psychrometer
Miscellaneous/Novelty Products
Air Cylinders
Connector Pins
Flow Meters
Mass Flow Controllers
Motors
Printed Circuit Boards
Pumps
Switches, Relays, Sensors, and Valves
8,915
8,519
315
Displacement Relay
Float Switch
Temperature Switch
Tilt Switch
Combined Exported Products'3
581
1
290
Total
20,867
8,540
3,867
aThe range of 2018 data reported to the MER application and 2016 data reported to the IMERC Mercury-added
Products Database is presented in the Products Sold in the United States section.
bReporters indicated exported products under multiple product categories; therefore, amounts for each category
are not discernible and a combined total is provided.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Table 20. List of Products Exportedfrom the United States and Amount of Mercury
Compounds Used, Distributed, and Exported
Products Exported from the United States
- Mercury Compound
s
Product Category and Subcategory
Amount in Products (lbs)
Used
Distributed3
Exported
Formulated Products:
292
152
122
Preservative (Vaccine Usage)
Other Formulated Products
1,568
85
1,785
In-Vitro Diagnostics
Pharmaceuticals
Preservative (Non-Vaccine Usage)
Reagents (Catalysts, Buffers, and Fixatives)
Lighting, Lamps, and Bulbs
1,160
153
142
Cold Cathode Fluorescent
Compact Fluorescent
Electrodeless Discharge
High Pressure Sodium
Linear Fluorescent
Low UV Gas Discharge Lamps and Burners
Mercury Short Arc
Mercury Vapor
Metal Halide
U-Tube and Circular Fluorescent
UV and Germicidal
UV Curable Lamp
Switches, Relays, Sensors, and Valves
1
1
1
Lead in Water Sensor
Tilt Switch
Other Exported Products Combined13
2
1
2
Total
3,023
392
2,052
aThe range of 2018 data reported to the MER application and 2016 data reported to the IMERC Mercury-added
Products Database is presented in the Products Sold in the United States section.
bReporters indicated exported products under multiple product categories; therefore, amounts for each category
are not discernible and a combined total is provided
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Conclusion and Data Interpretation
The Lautenberg Act requires EPA to "identify any manufacturing processes or products that
intentionally add mercury; and . . . recommend actions, including proposed revisions of Federal
law or regulations, to achieve further reductions in mercury use."51
Identified Manufacturing Processes and Products
When developing the reporting requirements for the mercury inventory, EPA identified products
and manufacturing processes via analysis of accumulated Agency resources and programs, as well
as a review of other federal, state, and international materials. Through the information submitted
under the mercury inventory reporting rule, EPA has identified the following additional uses of
mercury through the information submitted under the mercury inventory reporting rule:
Manufacturing Processes
• Bonding weld head (catalyst)
• Molecular beam epitaxy
• Quality analysis (density measurement of tungsten bars)
• Inactivation
• Quality control test (small arms ammunition case-mercury stress crack)
Products
• The "burners" aspect of "low UV gas discharge lamps and burners"
• Wheel emblem
• Lead in water sensor
• Mercury analyzer
• Air cylinders
• Connector pins
• Mass flow controllers
• Printed circuit board
• Motors
As noted in earlier sections, complete lists of mercury-added products and manufacturing
processes known at the time of the publication of the rule that established reporting requirements
for the mercury inventory are listed at 40 CFR 713.11(b) and (c). These lists are also available for
reference in Appendices B and C, respectively.
51 15 U.S.C. § 2607(b)(10)(C).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Traditionally, the Agency has relied on IMERC data for the amount of mercury in many products
sold in the United States. Dae to state laws in certain IMERC member states, the number for
switches, relays, sensors, and valves has not been updated since 2010. At that point, the amount
of mercury for switches, relays, sensors, and valves sold in the United States was 39,242 lbs.
In designing the mercury inventory reporting requirements, EPA sought not only to collect more
recent data, but also to differentiate between the amounts of mercury that such products are made
in, imported into, and exported from the United States. Based on the data submitted in the 2018
reporting period:
- 8,915 lbs of elemental mercury was used to make switches, relays, sensors, and valves in the
United States
- 8,519 lbs of elemental mercury was contained in switches, relays, sensors, and valves sold in the
United States
- 315 lbs of elemental mercury was contained in switches, relays, sensors, and valves exported
from the United States
- 1 lb of mercury compounds was contained in switches, relays, sensors, and valves imported into,
distributed in, and exportedfrom the United States
Recommended Actions
As noted in the previous section, after identifying processes and products that intentionally add
mercury, EPA is to make recommendations for actions to further reduce mercury use. EPA will
carefully consider the reporting results in light of such factors as quantities of use and availability
of safer, cost-effective alternatives and, as appropriate, will not hesitate to recommend future legal
or regulatory actions in accordance with the statute. In addition, EPA will continue to implement
U.S. obligations under the Minamata Convention on Mercury and to participate in the UNEP
Global Mercury Partnership, both of which are designed to reduce the adverse effects of mercury.
In addition, based on information received, as well as feedback from reporters, the Agency is
considering the following actions that would enhance the administration of the mercury inventory
and the MER application:
• Amending regulatory text of the mercury inventory reporting rule to complement expected
changes in the forthcoming CDR program amendments.
• Improving the level of detail for imported, manufactured, distributed, and exported
products and mercury compounds (e.g., amending the reporting form to allow for reporters
to provide a greater level of detail on such contextual information).
• Continuing to coordinate with IMERC and directly comparing/contrasting information
received via EPA's reporting application with information received via IMERC's Mercury-
Added Products Database.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Appendix A: Explanation of Key Terms
The explanations in this appendix pertain only to certain key terms as used in this document. The
U.S. Environmental Protection Agency (EPA) is providing explanations of terms in simplified
informal language to improve the readability of this mercury inventory report.52 To see the formal,
legal definitions of some of these terms, EPA recommends consulting section 2 of the Toxic
Substances Control Act (TSCA),53 the mercury inventory reporting rule,54 and particular citations
provided. In addition, the explanations in this report were developed to apply to key terms as they
are used in this mercury inventory report and may vary from definitions for the same terms used
elsewhere by EPA. Examples of such terms are: "component," "import," "manufacture," and
"mercury-added product."
Assembled product is a product that was manufactured with the inclusion of a component that is a
mercury-added product. An example is a watch containing a mercury-added battery.
CASRN is the Chemical Abstracts Service Registry Number.
Commercial advantage refers to activities undertaken intentionally to create an immediate or
eventual benefit (e.g., sale of goods, generation of profits, reduction of costs, etc.). If a company
manufactures mercury or a mercury-added product, then uses it rather than placing it in commerce,
it is considered to result in a commercial advantage.55
Component refers to a mercury-added product that is installed as part of the manufacture of an
assembled product.
Distribute in commerce means selling or transferring mercury or mercury-added products within
the United States.56 Sales or transfers to another country are categorized separately here as exports.
Elemental mercury is a shiny, silver-white metal that is liquid at room temperature; its CASRN is
7439-97-6. The Harmonized Tariff Schedule Code for mercury is 2805.40.00.
Export means to determine and control the sending of mercury and mercury-added products for a
destination outside of the customs territory of the United States.57 In this report, exports are
categorized as trade and considered separately from distribution in commerce, which here
encompasses only domestic activities.
Import means to bring mercury, mercury added products, and assembled products into the customs
territory of the United States.58 In this report, imports will be considered separately from other
52 Note: These explanations are not legally-binding on EPA.
5315 U.S.C. § 2601 et seq.
54 EPA. "Reporting Requirements for TSCA Mercury Inventory: Mercury." 83 Fed. Reg. 30054 (June 27, 2018).
55 See 40 CFR 704.3 for definition in the context of manufacturing, importing, and processing "for commercial
purposes."
56 See 15 U.S.C. §2602(5).
57 See 40 CFR 707.63(b).
58 See 15 U.S.C. §2602(9).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
manufacture, which here encompasses only domestic production. While import is part of the
statutory definition of manufacture, import is categorized separately from other manufacture in
this mercury import report and the Mercury Electronic Reporting (MER or reporting) application,
in order to more effectively distinguish between activities that constitute mercury supply, use, and
trade for purposes of TSCA section 8(b)(10)(B). In this report, import is categorized as trade.
Impurity refers to mercury that is present unintentionally in a final product of a manufacturing
process.
Logarithmic scale is a non-linear scale, which means that distances between certain values are not
the same as would be a linear scale. These non-linear scales are easier to visualize for data
containing a range of values. For example, in a linear scale, the distance between a value of 10 and
11 are equal to the distance between 11 and 12. In a non-linear scale, this distance is not equal.
Rather, each interval is increased by a factor of the base, which for this report, is a base of ten (e.g.,
1, 10, 100, 1,000, 10,000, and so on). As a note to readers, some figures in this document are
reported in a logarithmic scale to account for a wide range in mercury quantities. Readers should
be aware of this scale when comparing different factors and values.
Manufacture means to produce.59 The manufacture of elemental mercury occurs through
secondary production (recovery). Materials from which elemental mercury is recovered include
byproducts from mining or mineral processing, residuals from air pollution control, industrial
waste, contaminated media, discarded products, and other materials. Other terms for recovery of
elemental mercury include reclamation, retorting, distillation, separation, and purification.
Recovered elemental mercury may be either a commodity or a waste. If it is a waste, elemental
mercury is not reported in EPA's reporting application. A mercury compound is generally
produced as a commercial chemical product (see also "mercury-added product"). In this report and
in the MER application, import will be categorized as a separate activity from other manufacture,
in order to more effectively distinguish between activities that constitute mercury supply, use, and
trade for purposes of TSCA section 8(b)(10)(B).
MER is the Mercury Electronic Reporting application where information is submitted to EPA
directly by persons who must report under the mercury inventory reporting rule.
Mercury means elemental mercury and mercury compounds.60 The term "mercury" also includes
mixtures that include mercury and/or mercury compounds. An example of a mercury mixture is
dental amalgam, a mixture of mercury with other metals such as silver. An example of a mercury
compound mixture is a vaccine that contains the mercury-compound, thimerosal, which is used as
a preservative.
Mercury-added product is an item to which mercury is intentionally added when a product is
manufactured. The mercury remains present in the final product for a particular purpose. The final
mercury-added product can be a formulated product such as a vaccine or an article such as a
59 See 15 U.S.C. §2602(9).
60 See 15 U.S.C. § 2607(b)(10)(A).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
fluorescent light bulb, thermostats, or dental amalgam capsules. In regard to a component and an
assembled product, the Agency views the inclusion of a mercury-added product that is a
component within an assembled product differently from the act of intentionally inserting mercury
(i.e., chemical substance) into the component itself.61 As a result, the Agency does not require
information to be reported on the manufacture (including import) of assembled products that
include a component that is a mercury-added product.62
Mercury compound is formed when elemental mercury reacts with another substance, either in
nature or intentionally by humans.63
NAICS refers to the North American Industry Classification System, which 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.64
Otherwise intentionally use mercury in a manufacturing process means to use mercury to
manufacture anything other than a mercury-added product or a mercury compound. General
examples are use of mercury as a catalyst, cathode, reactant, or reagent, and as a specific example,
mercury-cell diaphragms are used in the chlorine production process. Otherwise intentional use of
mercury in a manufacturing process does not include the use of tools or equipment that contain
mercury nor the installation of a component that contains mercury as part of the manufacture of
an assembled product.
Person is used in this report consistent with its use in TSCA and refers to any individual, firm,
company, corporation, joint venture, partnership, sole proprietorship, association, or any other
business entity; any state or political subdivision thereof; any municipality; any interstate body;
and any department, agency, or instrumentality of the federal government.65
Processor is a manufacturer who uses mercury in a process other than making a mercury-added
product (e.g., using elemental mercury as catalyst to make final product in which any remaining
mercury has no functional purpose).
Reporting activity refers to any commercial activity involving mercury that must be reported to
EPA under the mercury inventory reporting rule (e.g., intentionally using mercury to manufacture
a product). EPA divided reporting activities into the following five categories: import of mercury,
manufacture of mercury in the United States, import of mercury-added products, manufacture of
mercury-added products in the United States, and use of mercury in a manufacturing process.
Reporter is a person (i.e., manufacturer, processor, or importer) that submitted information through
EPA's reporting application, as required by the mercury inventory reporting rule.
61 83 Fed. Reg. 30061.
62 See 40 CFR 713.7(b).
63 See 40 CFR 713.5.
64 See https://www.census.gov/eos/www/naics.
65 See 40 CFR 704.3
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Supply are the sources of mercury that can enter the market for sale which, for the purposes of this
inventory report, include domestically manufactured and stored mercury (see box on page 11). In
this report and in the MER application, import is categorized as a separate activity from other
manufacture in order to more effectively distinguish between activities that constitute mercury
supply, use, and trade for purposes of TSCA section 8(b)(10)(B).
Trade means the international import and export of mercury, mercury compounds, and mercury-
added products (see box on page 11). In this report and in the MER application, import is
categorized as a separate activity from other manufacture and domestic distribution is categorized
as a separate activity from other distribution in order to more effectively distinguish between
activities that constitute mercury supply, use, and trade for purposes of TSCA section 8(b)(10)(B).
Limiting the category of trade to international transactions is consistent with the organization of
the 2016 EPA Report to Congress on Mercury Global Supply and Trade.
Use of mercury for this inventory includes domestic distribution or sale of mercury and mercury-
added products and the intentional use of mercury to manufacture products or in a manufacturing
process (see box on page 11). In this report and in the MER application, domestic distribution is
categorized as a separate activity from other distribution in order to more effectively distinguish
between activities that constitute mercury supply, use, and trade for purposes of TSCA section
8(b)(10)(B). More specifically, distribution is discussed under use of mercury because the Agency
is viewing the sale of mercury and mercury-added products through the lens of the purchaser, who
uses the mercury or mercury-added products. In this way, the distribution of the supplied mercury
is similar to the economic term of demand.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Appendix B: List of Mercury Compounds in the TSCA
Chemical Substance Inventory
CASRN
Mercury Compound
10045-94-0
Nitric acid, mercury(2+) salt (2:1).
100-57-2
Mercury, hydroxyphenyl-.
10112-91-1
Mercury chloride (Hg2C12).
10124-48-8
Mercury amide chloride (Hg(NH2)Cl).
103-27-5
Mercury, phenyl(propanoato-.kappa.O)-.
10415-75-5
Nitric acid, mercury(l+) salt (1:1).
104-60-9
Mercury, (9-octadecenoato-.kappa.0)phenyl-.
1191-80-6
9-Octadecenoic acid (9Z)-, mercury(2+) salt (2:1).
12068-90-5
Mercury telluride (HgTe).
13170-76-8
Hexanoic acid, 2-ethyl-, mercury(2+) salt (2:1).
13302-00-6
Mercury, (2-ethylhexanoato-.kappa.O)phenyl-.
1335-31-5
Mercury cyanide oxide (Hg2(CN)20).
1344-48-5
Mercury sulfide (HgS).
1345-09-1
Cadmium mercury sulfide.
13876-85-2
Mercurate(2-), tetraiodo-, copper(l+) (1:2), (T-4)-.
138-85-2
Mercurate(l-), (4-carboxylatophenyl)hydroxy-, sodium (1:1).
141-51-5
Mercury, iodo(iodomethyl)-.
14783-59-6
Mercury, bis[(2-phenyldiazenecarbothioic acid-.kappa.S) 2-
phenylhydrazidato-.kappa.N2]-, (T-4)-.
15385-58-7
Mercury, dibromodi-, (Hg-Hg).
15785-93-0
Mercury, chloro[4-[(2,4-dinitrophenyl)aminolphenyl]-.
15829-53-5
Mercury oxide (Hg20).
1600-27-7
Acetic acid, mercury(2+) salt (2:1).
1785-43-9
Mercury, chloro(ethanethiolato)-.
19447-62-2
Mercury, (acetato-.kappa.O)[4-[2-[4-
(dimethyl amino)pheny 1 ] di azeny 1 ] phenyl ] -.
20582-71-2
Mercurate(2-), tetrachloro-, potassium (1:2), (T-4)-.
20601-83-6
Mercury selenide (HgSe).
21908-53-2
Mercury oxide (HgO).
22450-90-4
Mercury(l+), amminephenyl-, acetate (1:1).
24579-90-6
Mercury, chloro(2-hydroxy-5-nitrophenyl)-.
24806-32-4
Mercury, [,mu.-[2-dodecylbutanedioato(2-
).kappa.01:.kappa.04]ldiphenyldi-.
26545-49-3
Mercury, (neodecanoato-.kappa.O)phenyl-.
27685-51-4
Cobaltate(2-), tetrakis(thiocyanato-.kappa.N)-, mercury(2+) (1:1), (T-4)-.
29870-72-2
Cadmium mercury telluride ((Cd,Hg)Te).
3294-57-3
Mercury, phenyl(trichloromethyl)-.
33770-60-4
Mercury, [3,6-dichloro-4,5-di(hydroxy-.kappa.O)-3,5cyclohexadiene-l,2-
dionato(2-)]-.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
CASRN
Mercury Compound
3570-80-7
Mercury, bis(acetato-.kappa.O)[.mu.-(3',6'-dihydroxy-
3oxospiro[isobenzofuran-l(3H),9'-[9Hlxanthenel-2',7'diyl)ldi-.
537-64-4
Mercury, bis(4-methylphenyl)-.
539-43-5
Mercury, chloro(4-methylphenyl)-.
54-64-8
Mercurate(l-), ethyl[2-(mercapto-.kappa.S)benzoato(2-).kappa.O]-,
sodium (1:1).
55-68-5
Mercury, (nitrato-.kappa. 0)pheny 1 -.
56724-82-4
Mercury, phenyl[(2-phenyldiazenecarbothioic acid.kappa.S) 2-
phenylhydrazidato-.kappa.N2]-.
587-85-9
Mercury, diphenyl-.
592-04-1
Mercury cyanide (Hg(CN)2).
592-85-8
Thiocyanic acid, mercury(2+) salt (2:1).
593-74-8
Mercury, dimethyl-.
59-85-8
Mercurate(l-), (4-carboxylatophenyl)chloro-, hydrogen.
623-07-4
Mercury, chloro(4-hydroxyphenyl)-.
62-38-4
Mercury, (acetato-. kapp a. 0)pheny 1 -.
62638-02-2
Cyclohexanebutanoic acid, mercury(2+) salt (2:1).
627-44-1
Mercury, diethyl-.
6283-24-5
Mercury, (acetato-.kappa.O)(4-aminophenyl)-.
628-86-4
Mercury, bis(fulminato-.kappa.C)-.
629-35-6
Mercury, dibutyl-.
63325-16-6
Mercurate(2-), tetraiodo-, (T-4)-, hydrogen, compd. with 5-iodo-2-
pyridinamine (1:2:2).
63468-53-1
Mercury, (acetato-.kappa.O)(2-hydroxy-5-nitrophenyl)-.
63549-47-3
Mercury, bis(acetato-.kappa.O)(benzenamine)-.
68201-97-8
Mercury, (acetato-.kappa.0)diamminephenyl-, (T-4)-.
72379-35-2
Mercurate(l-), triiodo-, hydrogen, compd. with 3-methyl2(3H)-
benzothiazolimine (1:1:1).
7439-97-6
Mercury.
7487-94-7
Mercury chloride (HgC12).
7546-30-7
Mercury chloride (HgCl).
7616-83-3
Perchloric acid, mercury(2+) salt (2:1).
7774-29-0
Mercury iodide (HgI2).
7783-33-7
Mercurate(2-), tetraiodo-, potassium (1:2), (T-4)-.
7783-35-9
Sulfuric acid, mercury(2+) salt (1:1).
7783-39-3
Mercury fluoride (HgF2).
7789-47-1
Mercury bromide (HgBr2).
90-03-9
Mercury, chloro(2-hydroxyphenyl)-.
94070-93-6
Mercury, [,mu.-[(oxydi-2,l-ethanediyl l,2benzenedicarboxylato-
.kappa.02)(2-)l]diphenyldi-.
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Appendix C: Categories and Subcategories of
Mercury-Added Products
Category
Subcategory
Batteries
—Button cell, silver. —Button cell, zinc-air. —Button cell,
alkaline. —Stacked button cell batteries. —Manganese
oxide. —Silver oxide. —Mercuric oxide, non-button cell. —
Button cell, mercuric oxide. —Button cell, zinc carbon. —
Other [Manufacturer(s) specifies!.
Dental amalgam
[No subcategories].
Formulated products
(includes uses in cosmetics,
pesticides, and laboratory
chemicals)
—Skin-lightening creams. —Lotions. —Soaps and
sanitizers. —Bath oils and salts. —Topical antiseptics. —
Preservatives (e.g., for use in vaccines and eye-area
cosmetics when no preservative alternatives are available).
—Pharmaceuticals (including prescription and over-the-
counter drug products). —Cleaning products (not registered
as pesticides under the Federal Insecticide, Fungicide, and
Rodenticide Act). —Pesticides. —Paints. —Dyes. —
Reagents (e.g., catalysts, buffers, fixatives). —Other
[Manufacturer(s) specifies].
Lighting, lamps, bulbs
—Linear fluorescent. —Compact fluorescent. —U-tube and
circular fluorescent. —Cold cathode fluorescent. —External
electrode fluorescent. —Mercury vapor. —Metal halide. —
High pressure sodium. —Mercury short arc. —Neon, —
Other [Manufacturer(s) specifies].
Measuring instruments
—Barometer. —Fever thermometer. —Flow meter. —
Hydrometer. —Hygrometer/psychrometer. —Manometer.
Non-fever thermometer. —Pyrometer. —
Sphygmomanometer. —Other [Manufacturer(s) specifies].
Pump seals
[No subcategories].
Switches, relays, sensors,
valves
—Tilt switch. —Vibration switch. —Float switch. —
Pressure switch. —Temperature switch. —Displacement
relay. —Wetted reed relay. —Contact relay. —Flame sensor.
—Thermostat. —Other [Manufacturer(s) specifies use].
Miscellaneous/novelty
mercury-added products
—Wheel weights. —Wheel rotation balancers/stabilizers.
Firearm recoil suppressors. —Carburetor synchronizers. -
Joint support/shock absorption bands. —Other
[Manufacturer(s) specifies].
Note: The mercury-added product categories and sub-categories reflect the list of such products known at the time of
the promulgation of the mercury inventory reporting rule. See 83 Fed. Reg. 30054 (June 27, 2018) and 40 CFR
713.11(b).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Appendix D: Manufacturing Processes for which
Mercury is Otherwise Intentionally Used and Relevant
Function Uses
Manufacturing Process
Chlorine production (e.g., mercury-cell chlor-alkali process)
Acetaldehyde production
Sodium/potassium methylate/ethylate production.
Polyurethane/plastic production
Other [Manufacturer(s) specifies process]
Functional Use
Catalyst
Cathode
Reactant
Reagent
Other [Manufacturer(s) specifies use"|
Note: The manufacturing processes and relevant function uses reflect the list of such products known at the time of
the promulgation of the mercury inventory reporting rule. See 83 Fed. Reg. 30054 (June 27, 2018) and 40 CFR
713.11(c).
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Appendix E: Countries of Origin and Destination of Imported and
Exported Mercury and Mercury-Added Products
Imported*
Exported*
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Argentina
X
X
X
Armenia
X
Aruba
X
Australia
X
X
X
Austria
X
Bahamas
X
Bahrain
X
Belarus
X
Belgium
X
X
X
X
Belize
X
Bolivia
X
X
X
Brazil
X
X
X
Cambodia
X
Canada
X
X
X
X
Chile
X
X
X
China
X
X
X
X
Colombia
X
X
X
Costa Rica
X
X
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Imported*
Exported*
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Czech Republic
X
Denmark
X
X
X
Dominican Republic
X
X
Ecuador
X
X
Egypt
X
X
El Salvador
X
Ethiopia
X
Fiji
Finland
X
X
France
X
X
Germany
X
X
X
X
X
Guam
X
Guatemala
X
X
Honduras
X
Hong Kong
X
X
Hungary
X
X
X
India
X
X
X
X
Indonesia
X
X
X
Ireland
X
X
Israel
X
X
X
Italy
X
X
X
Jamaica
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Imported*
Exported*
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Japan
X
X
X
X
X
Jordan
X
Korea, Republic of
X
X
X
X
X
Kuwait
X
X
Latvia
X
Lebanon
X
Luxembourg
X
Malaysia
X
X
X
Mauritius
X
Mexico
X
X
X
X
X
Mongolia
X
Morocco
X
X
Netherlands
X
X
X
New Zealand
X
X
X
Nicaragua
X
Oman
X
X
Pakistan
X
Panama
X
X
X
Paraguay
X
X
X
Peru
X
X
X
Philippines
X
X
X
Poland
X
X
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Imported*
Exported*
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Portugal
X
Puerto Rice
X
X
Qatar
X
Russia
X
X
X
Saint Kitts And Nevis
X
Saudi Arabia
X
X
Singapore
X
X
X
X
South Africa
X
X
X
Spain
X
X
X
Sri Lanka
X
Sweden
X
X
X
Switzerland
X
X
X
X
Taiwan
X
X
X
X
X
Thailand
X
X
X
Trinidad And Tobago
X
X
Tunisia
X
Turkey
X
X
Ukraine
X
United Arab Emirates
X
X
United Kingdom
X
X
X
X
X
United States
X
X
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Inventory of Mercury Supply, Use, and Trade in the United States - 2020 Report
Imported*
Exported*
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Mercury
Compounds
Elemental
Mercury-
Added
Products
Mercury
Compound-
Added Products
Uruguay
X
X
Venezuela
X
Vietnam
X
X
X
Virgin Islands, U.S.
X
*Elemental mercury is neither imported to nor exported from the United States.
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