Instructions for Reporting PFAS Under
TSCA Section 8(a)(7)
U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics
November 2024
EPA-705-G-2023-3727
-------
DOCUMENT HISTORY
Document Date
Action
October 2023
Creation of original document and posting to docket and TSCA website
May 2024
Clarifying revisions to Section 2.1.2: Is Your Chemical a PFAS?
Removal of references to online reporting guide
Edits to Byproduct Reporting section to clarify CBI substantiation questions
Revisions to Appendix C: Examples of PFAS covered by this rule
November 2024
Update of submission period to begin on July 11, 2025, following direct final rule (89 FR
72340)
Updated organization of the reporting form (Section 4) to align with the reporting
application, added separate sections for the streamlined forms
Added discussion of "possession or control" to the existing information regarding
environmental or health effects (Section 4)
-------
HIGHLIGHTS OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR
PFAS UNDER TSCA 8(a)(7)
• Reporting is required for any manufacturer (including importer) of a per- or poly-
fluoroalkyl substance (PFAS).
• Reporting is required for all PFAS, as defined in 40 CFR 705, that are chemical
substances as defined by TSCA, that have been manufactured (including imported) for
commercial purposes during this rule's lookback period.
• Information on the reportable chemical substance must be reported during the data
submission period (40 CFR 705).
• All reporting sites must report PFAS data electronically, using the section 8(a)(7) web-
based reporting tool within EPA's Central Data Exchange (CDX) system. Prior to
submitting data, submitters must register with CDX. Ensure that your pop-up blocker
is disabled before you begin to use the PFAS section 8(a)(7) tool to complete your
form.
• Streamlined reporting is available for importers of articles and for manufacturers of
less than 10 kg of a substance used solely for research and development.
• No small manufacturer exemptions are in effect for this data call. You may be
required to report under this PFAS data call even if you are not required to report to
under other TSCA requirements such as CDR due to a small manufacturer exemption.
• Information submitted under this data call may be claimed as confidential; however,
such claims must be made at the time of submission and substantiated in accordance
with TSCA and the PFAS data reporting rule. Submitters must provide upfront
substantiation of all confidentiality claims except for claims made for import or yearly
production volume information. Submitters who do not know the underlying identity
of the chemical other than a generic chemical name (i.e., do not know a CASRN, or
TSCA Accession or LVE numbers) are not required to assert and substantiate a CBI
claim for chemical identity. Reporters using the article importer form also are not
required to assert and substantiate a CBI claim for specific chemical identity. Certain
processing and use data elements or a response that is designated as "not known or
reasonably ascertainable" may not be claimed as confidential (40 CFR 705.30).
• Visit the PFAS 8(a)(7) GuideME (https://tscaguideme.epa.gov/ords/tsca-
gme/r/tsca/pfas-8a7/home) forotherguidance materials and contact information for
technical assistance.
ii
-------
TABLE OF CONTENTS
Preface vii
1. Introduction 1-1
1.1 Background and Statutory Authority 1-1
1.2 Duplicative reporting 1-1
2. Reporting Requirements 2-1
2.1 Step I: Is Your Chemical Substance Subject to section 8(a)(7)? 2-1
2.1.1 Is Your Chemical Substance Manufactured for Commercial Purposes During
the Reporting Period? 2-2
2.1.2 Is Your Chemical Substance a PFAS? 2-3
2.2 Step II: Do You Qualify for Streamlined Reporting? 2-5
2.2.1 Did you import an article containing a reportable PFAS? 2-5
2.2.2 Did you manufacture a reportable PFAS in quantities below 10 kg per year
exclusively for purposes of research and development (R&D)? 2-7
2.3 Step III: What Information Must You Report? 2-8
3. When You Must Report 3-1
4. Instructions for Completing Section 8(a)(7) Reporting 4-1
4.1 Certification 4-2
4.2 Reporting Standard 4-2
4.3 Parent Company Information 4-6
4.3.1 U.S. Parent Company Name(s) 4-7
4.3.2 Parent Company Dun & Bradstreet D-U-N-S® Number 4-8
4.3.3 Parent Company Address 4-9
4.4 Site Information 4-10
4.4.1 Confidentiality of Company, Site, and Technical Contact Information .... 4-10
4.4.2 Special Provisions for Certain Sites 4-11
4.4.3 Site Name 4-11
4.4.4 Site Dun & Bradstreet Number D-U-N-S® 4-11
4.4.5 Site Street Address 4-12
4.4.6 NAICS code 4-12
4.4.7 Technical Contact Information 4-12
4.5 How are you reporting the chemical substance? 4-13
4.5.1 Chemical Substance Identification 4-13
4.5.2 Confidentiality of Chemical Substance Information 4-14
4.5.3 Manufacturing a Mixture Or a Chemical Substance of Unknown or Variable
Composition or a Polymer 4-16
4.5.4 How to Report when Chemical Identity is Unknown or is Not in SRS 4-17
4.5.5 Chemical Substance Identifying Number 4-18
4.5.6 Chemical Name 4-19
4.5.7 Trade Name or Common Name 4-20
-------
4.5.8 Generic Chemical Name or Description 4-20
4.5.9 Molecular Structure 4-20
4.5.10 Additional Information on Chemical Identity 4-21
4.5.11 Special Provisions for Joint Submitters of Unknown Chemical Substances. 4-
21
4.6 Standard Form: Domestic Manufactured/Imported PFAS 4-23
4.6.1 Manufacturing/Importing Information 4-23
4.6.2 Byproduct Information 4-30
4.6.3 Exposure Information at the Manufacturing Site 4-35
4.6.4 Industrial Processing and Use 4-41
4.6.5 Consumer and Commercial Use 4-52
4.6.6 All existing information concerning the environmental and health effects of
such substance or mixture 4-64
4.7 Streamlined Form: PFAS in Imported Articles 4-66
4.7.1 Import Information 4-67
4.7.2 Industrial Processing and Use 4-68
4.7.3 Consumer and Commercial Use 4-74
4.8 Streamlined Form: Research and Development (R&D) PFAS (below 10 kg/year) ..4-82
4.8.1 Reporting Manufacturing Information 4-83
4.9 Optional Information 4-84
4.10 Joint Submissions (Standard Form and R&D Substance Form) 4-84
4.10.1 Determining the Need for a Joint Submission 4-84
4.10.2 The Primary Submission is Completed by the PFAS Manufacturer 4-85
4.10.3 The Secondary Submission is Completed 4-86
4.10.4 Confidentiality of Information Jointly Submitted 4-86
4.11 CBI Substantiation 4-87
5. How to Obtain Copies of Documents Cited in This Instructions Document 5-1
5.1 Obtaining Copies of the TSCA Rules 5-1
5.2 Obtaining Copies of Other Information Materials 5-1
iv
-------
APPENDICES
Appendix A. Glossary of Terms A-l
Appendix B. Key Comparisons between Section 8(a)(7) Data Call and CDR B-l
Appendix C. Examples of PFAS covered by this rule C-l
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations,
Industrial Sectors, Function Categories, and Consumer and Commercial Product Categories
D-l
LIST OF FIGURES
Figure 2-1. Decision Logic Diagram for Evaluating Step II 2-6
LIST OF TABLES
Table 1-1. Examples of prior reporting impacts on PFAS data call reporting 1-4
Table 4-1. Examples of the Application of the "Known to or Reasonably Ascertainable" Reporting
Standard for Processing and Use Data 4-4
Table 4-2. Applying Highest-level Parent Company Definition in Different Situations 4-6
Table 4-3. Parent Company Name Standardization 4-7
Table 4-4. Parent Company Street Address Standardization 4-9
Table 4-5. ID Code for Chemical Identifying Numbers 4-19
Table 4-6. Examples of Reporting Manufactured and Imported Volumes 4-25
Table 4-7. Examples of Reporting Recycling 4-27
Table 4-8. Disposal Process codes 4-28
Table 4-9. Release media for disposal codes 4-29
Table 4-10. Examples of Byproducts Reporting 4-34
Table 4-11. Codes for Worker Category and Activity Codes 4-35
Table 4-12. Codes for Reporting Number of Workers Reasonably Likely to be Exposed 4-37
Table 4-13. Example manufacturing worker exposure scenarios 4-40
Table 4-14. Codes for Reporting Types of Industrial Processing or Use Operations 4-42
Table 4-15. Codes for Reporting Industrial Sectors 4-43
Table 4-16. Codes for Reporting Function Categories 4-45
Table 4-17. Examples of Reporting Industrial Processing and Use Information 4-49
Table 4-18. Example industrial worker exposure scenarios 4-51
Table 4-19. Product Category Codes 4-53
Table 4-20. Examples of Products Intended for Use by Children 4-58
Table 4-21. Examples of Reporting Consumer and Commercial Use Information 4-60
Table 4-22. Codes for Reporting Maximum Concentration 4-61
Table 4-23. Example commercial worker exposure scenarios 4-63
Table 4-24. Codes for Reporting Types of Industrial Processing or Use Operations 4-69
v
-------
Table 4-25. Codes for Reporting Industrial Sectors 4-69
Table 4-26. Codes for Reporting Function Categories 4-71
Table 4-27. Product Category Codes 4-76
Table 4-28. Examples of Products Intended for Use by Children 4-81
Table 4-29. Codes for Reporting Maximum PFAS Concentration in an Imported Article 4-82
Table 4-30. Substantiation Questions to be Answered for All Types of Confidentiality Claims
Confidentiality Claims (40 CFR 705.30(e)) 4-88
Table 4-31. Substantiation Questions to be Answered when Asserting Chemical Identity CBI
Claims (40 CFR 705.30(e) and (f)) 4-89
vi
-------
Preface
The primary goal of this document is to help the regulated community comply with the
requirements of the TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for
Perfluoroalkyl and Polyfluoroalkyl Substances rule, hereafter referred to as section 8(a)(7)
reporting. This document does not substitute for that rule, nor is it a rule itself. It does not
impose legally binding requirements on the regulated community or on the U.S. Environmental
Protection Agency (EPA).
Manufacturers (including importers) are required by the section 8(a)(7) rule to report to
EPA information concerning the manufacturing, use, disposal, and environmental and health
effects of certain Perfluoroalkyl or Polyfluoroalkyl Substances (PFAS). Manufacturers (including
importers) are subject to the reporting requirements based on manufacturing (including
importing) activities conducted since January 1, 2011. This is a one-time reporting event to
provide greater transparency on the uses and risks associated with PFAS and is mandated by
the Fiscal Year 2020 National Defense Authorization Act (NDAA).
Data submissions are due by the close of the submission period. The submission period
begins on July 11, 2025, and concludes January 11, 2026. However, small manufacturers (per 40
CFR 704.3) whose PFAS reporting obligations are exclusively due to importing articles have an
additional six months to report. The reporting deadline for these small article importers is July
11, 2026. Data must be submitted using the "TSCA Section 8(a)(7)" application in the Chemical
Information Submission System (CIS) via EPA's Central Data Exchange (CDX), hereafter referred
to as the "reporting tool." Submitters are required to use the reporting tool to prepare their
submissions. The reporting tool guides users through a "hands-on" process of creating an
electronic submission. A user guide on how to register for CDX and access the reporting tool is
available at https://www.epa.aov/chemical-data-reportina/cspp-cdx-reaistration-auide. User
role guidance for the TSCA Section 8(a)(7) reporting tool is the same as the guidance for
Chemical Data Reporting (2020), provided in Section 6.3 of the CDX registration guide linked
above.
This instructions document contains the following chapters and appendices:
• Chapter 1 - Introduction to the TSCA section 8(a)(7) PFAS reporting rule.
• Chapter 2 - Reporting requirements to determine which chemical substances are
reportable, who must report, and what information must be reported.
• Chapter 3 - When you must report.
• Chapter 4 - Instructions for completing section 8(a)(7) reporting.
• Chapter 5 - How to obtain copies of documents cited in this Instructions document.
• Appendix A - Glossary.
• Appendix B - Key Comparisons between Section 8(a)(7) Data Call and CDR
vii
-------
• Appendix C - Examples of PFAS covered by this rule.
• Appendix D - Descriptions of codes for reporting Processing or Use Operations, Industrial
Sectors, Industrial Function Categories, and Consumer and Commercial Product and
Function Categories.
viii
-------
Chapter 1
Introduction
1. Introduction
1.1 Background and Statutory Authority
In accordance with obligations underTSCA section 8(a)(7), as amended by the National
Defense Authorization Act for Fiscal Year 2020, EPA is requiring persons that manufacture
(including import) or have manufactured these chemical substances for commercial purposes in
any year since January 1, 2011, to submit information to EPA regarding PFAS uses, production
volumes, byproducts, disposal, exposures, and existing information on environmental or health
effects.
This document provides detailed information and examples to assist manufacturers
(including importers) in reporting underTSCA section 8(a)(7). Appendix A of this document
provides a glossary of terms, which may help you to understand the reporting requirements.
This document is not a substitute for the TSCA section 8(a)(7) PFAS rule in 40 CFR Part
705. To the extent that any inconsistencies exist between the section 8(a)(7) rule and this
document, the requirements as promulgated in the rule should be followed. You should
carefully review 40 CFR Part 705 and the final rule preamble (available in this rule's docket at
www.regulations.gov, docket ID EPA-HQ-OPPT-2020-0549) to determine whether you are
required to report information under the section 8(a)(7) rule.
1.2 Duplicative reporting
Your site may have already reported some section 8(a)(7) data to EPA through another
EPA program. If that is the case, the site should determine whether EPA has identified such
reporting as "duplicative" in the section 8(a)(7) rule. If EPA has identified the reporting as
duplicative, your site is not required to re-report duplicative information, but must submit a
report and include all information required by this data call that has not been previously
reported to EPA. Information that has been reported for some but not all years from 2011 to
2022 must be reported for the "missing" years. Information that has been previously reported,
but not to the level of detail required by this data call, or using exemptions not applicable to
this data call, must be reported under this data call to the level of detail required, if known to or
reasonably ascertainable by you. In the event that new, more accurate, or more detailed
information has become known to or reasonably ascertainable by the site, that information
must be reported under this data call.
The electronic reporting system will allow you to indicate that certain information has
already been reported to EPA. EPA has identified data elements that could have been previously
reported under Chemical Data Reporting (CDR); Toxics Release Inventory (TRI) reporting, also
known as section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA
313); Greenhouse Gas Reporting (GHGRP); and TSCA sections 8(d) and 8(e). Additionally, there
may be limited overlap between forms submitted under section 8(a)(7) reporting in the event
l-l
-------
Chapter 1
Introduction
that a reportable PFAS is produced as a byproduct during manufacture, processing, or disposal
of another reportable PFAS.
The section 8(a)(7) reporting software will identify the data elements that could contain
information already reported to EPA. For these data elements, you may indicate if your
company has already reported the information to EPA. You must clearly indicate where the
information can be found (i.e., which reporting program) and when that information was
submitted (i.e., which year). Information must have been reported as required by the section
8(a)(7) rule; for example, other programs may have exemptions, such as for articles or
impurities, that could mean information reported to those programs was not reported as
required by this data call.
EPA anticipates that the primary program with "duplicative reporting" is Chemical Data
Reporting (CDR). Two other EPA programs that have minor overlap with section 8(a)(7) include
the Toxics Release Inventory (TRI) and the Greenhouse Gas Reporting Program (GHGRP).
Note, however, that these programs both cover only a limited subset of the PFAS
covered by section 8(a)(7) and have thresholds for reporting that do not apply to this data call.
Therefore, you may be required to report under this data call even if you were not required to
report under TRI or GHGRP. Further, due to differences in how data are to be reported to those
programs, reporting to TRI or GHGRP may not fulfill the requirements of this data call. Some
health or environmental information may also have been reported under TSCA section 8(d) or
TSCA section 8(e) or another authority.
Note that information reported on pre-manufacture notices (PMNs) or low volume
exemptions (LVEs) generally does not fulfill requirements under section 8(a)(7), as PMNs and
LVEs reflect information before manufacture of a substance commences.
Information reported to entities other than EPA, such as state agencies, or provided to
EPA outside a formal EPA reporting program (such as comments provided on a proposed rule),
does not fulfill your requirement to report to EPA under section 8(a)(7) and cannot be cited as
duplicative reporting.
EPA expects that even when a company has previously reported some section 8(a)(7)
information, that information will constitute only a minority of information to be reported
under this data call.
Information that may have previously been reported under CDR includes:
(1) Physical state of the PFAS pursuant to § 711.15(b)(3)(C)(ix);
(2) Industrial processing and use type, sector(s), functional category(ies), and percent
of production volume for each use, pursuant to § 711.15(b)(4)(i)(A) through (D);
(3) Consumer and/or commercial indicator, product category(ies), functional
category(ies), percent of production volume for each use, indicator for use in
1-2
-------
Chapter 1
Introduction
products intended for children, and maximum concentration in the product,
pursuant to § 711.15(b)(4)(ii)(A) through (F);
(4) Number of workers reasonably likely to be exposed for each combination of
industrial processing or use operation, sector, and function, pursuant to §
711.15(b)(4)(i)(F), and the number of commercial workers reasonably likely to be
exposed when the substance is used in a commercial product, pursuant to §
711.15(b)(4)(ii)(G).
(5) Production volume (both domestically manufactured and imported), whether the
imported chemical was never physically at site, and the volume directly exported,
pursuant to § 711.15(b)(3)(iii) through (v).
Information that may have been reported to TRI includes:1'2
(1) Total volume recycled on-site, pursuant to § 372.85(b)(16).
(2) Description of disposal process(es), pursuant to § 372.85(b)(14) and (15).
(3) Total volume released to land, pursuant to § 372.85(b)(14)(i)(D) and (E).
(4) Total volume released to water, pursuant to § 372.85(b)(14)(i)(C).
(5) Total volume released to air, pursuant to § 372.85(b)(14)(i)(A) and (B).
(6) Total volume incinerated on site3, pursuant to § 372.85(b)(16).
Information that may have been reported to GHGRP includes:1
(1) Production volume (imported), pursuant to § 98.416(c)(1) and (2).
(2) Volume directly exported, pursuant to § 98.416(d)(1).
1 Due to differences in reporting requirements, exemptions, and other programmatic requirements, reporting to
TRI and GHGRP may not meet the requirements of TSCA section 8(a)(7). Carefully review any previous TRI or
GHGRP submissions and calculation methods to determine if you may claim duplicative reporting. You may claim
duplicative reporting for TRI and/or GHGRP only if the data were reported as required by the section 8(a)(7) rule.
2 Only certain PFAS chemicals are reportable under TRI. Most PFAS were added to the TRI chemical list for 2020
reporting, while some chemicals meeting the definition of PFAS used for PFAS 8(a)(7) reporting have been
reportable since before 2011. Note that the TRI chemical list includes certain chemicals as unspecified isomers,
such as dichloropentafluoropropane, which could include both chemicals considered to be PFAS and chemicals not
considered to be PFAS. In the event you know which isomer(s) were used at the site, you must report the specific
isomers for PFAS 8(a)(7) reporting and may not consider reporting to TRI under a mixed isomer listing as
duplicative.
3 Carefully review any incineration data reported to TRI to determine if it is duplicative. To claim duplicative
reporting, EPA must be able to determine the total volume of the chemical incinerated on site. EPA anticipates that
many reporters' TRI reports will not fulfill the requirements of Section 8(a)(7) for the total volume incinerated on
site.
1-3
-------
Chapter 1
Introduction
(3) Total volume incinerated on site, pursuant to § 98.
Information that may have been reported under TSCA section 8(d) or 8(e) or another
authority includes:
(1) Environmental and health effects (OECD harmonized template)
(2) Environmental and health effects study report
(3) Environmental and health effects supporting information
Table 1-1 shows some examples of how companies may consider prior reporting.
Table 1-1. Examples of prior reporting impacts on PFAS data call reporting
Previous Reporting
Site section 8(a)(7) responsibilities
A manufacturer previously reported on Example
PFAS A under 2020 CDR. That CDR report included
information required by the
manufacturing/importing information section of
this data call, from 2016 through 2019. Most
information required by the
manufacturing/importing information section was
reported for only the principal reporting year, 2019,
and some information for the
manufacturing/importing information section was
reported for 2016- 2018. The site started
manufacturing the PFAS in 2015 but did not meet
the CDR reporting threshold for that year. The
manufacturer continued to produce Example PFAS
A in the years since its last CDR report.
The manufacturer considers whether any exemptions
applied to the prior CDR reporting that are not available
under this rule. The manufacturer determines that the
data previously submitted to CDR did not exempt any
activities or quantities that would be reportable under
this rule, and therefore may be considered duplicative.
For the manufacturing/importing information section,
the manufacturer indicates that data were already
reported to CDR for the applicable fields for 2019,
completing the fields for "site-limited?" and recycling,
which were not reported to CDR. The manufacturer also
indicates the data were already reported to CDR for the
fields that were reported for 2016-2018. The
manufacturer fills in the remaining information for 2016-
2018 and all manufacturing/importing information for
2015 and 2020-2022. The manufacturer fills in
information for 2015-2022 in all other sections of its
PFAS data call reports, as that information has not been
reported to EPA for any year.
A manufacturer previously reported information
about Example PFAS B, which was manufactured
from 2012-2015, to the 2016 CDR. At the time of
2016 CDR submission, several required data fields
were not known to or reasonably ascertainable by
the company (NKRA). However, the company since
learned additional information about the chemical.
The manufacturer indicates duplicative reporting for the
data that was known to the site and submitted to EPA
for 2012-2015. The manufacturer must report newly
acquired information to this PFAS data call for fields
reported as "NKRA" to CDR for 2012- 2015. The
manufacturer may indicate duplicative reporting for
remaining fields that were originally reported as "NKRA"
and for which the manufacturer has not acquired new
information.
Example Company C manufactures Example PFAS C
and has begun gathering and compiling information
about this chemical for 2024 CDR (for activities
The company must report the 2020-2022 information
under section 8(a)(7) reporting, even if the information
will be reported to EPA in the future.
1-4
-------
Chapter 1
Introduction
Previous Reporting
Site section 8(a)(7) responsibilities
from 2020-2023). The company's 2024 CDR report
will not be submitted before the end of the section
8(a)(7) submission period.
EPA encourages submitters to review their in- progress
CDR submissions in gathering data for section 8(a)(7)
submissions, and vice versa, to reduce overall reporting
burden.
Example Company D imported Example PFAS D at
one site in 2015. 10,000 pounds of Example PFAS D
was imported as a component of an article, and
50,000 pounds was imported in a mixture. The
company reported Example PFAS D to CDR for
2015, reporting on the 50,000 pounds imported in
the mixture. The company did not consider the
10,000 pounds of Example PFAS D imported as
articles, which are exempt for CDR reporting.
The company must newly report all information for
Example PFAS D under this data call. Because
information reported to CDR excluded quantities
imported in articles, which are not exempt under this
data call, the information was not previously reported as
required by this data call. The site may not indicate
duplicative reporting.
Example Company E imported an article containing
Example PFAS E in 2012, 2013, and 2017, but has
not been previously required to report this
information to any EPA programs.
The site reported information about this chemical
to the state of Washington's Department of
Ecology pursuant to the state's requirements for
chemicals in children's products.
The company must report to EPA all information
required by this data call for 2012, 2013, and 2017, and
indicate that Example PFAS E was not produced in the
other years. Reporting to a state program does not fulfill
or reduce any requirements for reporting under this
PFAS data call.
Example Company F manufactured 1,000 pounds of
Example PFAS F each year during 2019, 2020, and
2021. Example PFAS F was added to the TRI
chemical list for 2020 reporting and was not TRI-
reportable for 2019. Each year, 50 pounds of the
PFAS were manufactured and used for quality
control in a laboratory on-site. All Example PFAS F
produced at Example Company D was disposed of
in the site's on-site landfill. After determining that
the quantity of Example PFAS F used in the
laboratory was exempt from TRI reporting,
Company C reported 950 pounds of Example PFAS F
releases to TRI for 2020 and 2021.
The company must enter all information about Example
PFAS F for 2019, because no TRI report was filed for that
year. The site may not indicate duplicative reporting for
release quantities for 2020 and 2021, because the
quantities reported to TRI excluded laboratory uses that
are not exempt under Section 8(a)(7) reporting. The
company instead reports 1,000 pounds of land disposal
for 2020 and 2021. The company may indicate
duplicative reporting for types of disposal processes and
the quantities released to air, water, and recycled on-
site.
1-5
-------
Chapter 2
Reporting Requirements
2. Reporting Requirements
PFAS data reporting rule requirements apply to certain persons that manufacture
(including import) or have manufactured PFAS in any year since January 1, 2011 (i.e., consider
calendar years 2011 through 2022). The term "PFAS" is defined in Appendix A and examples of
PFAS are provided in Appendix B. Please note that any use of the term "manufacture" in this
document will encompass "import" and the term "manufacturer" will encompass "importer."
For reporting to the PFAS data reporting rule, manufacturers (including importers) are
required to use the section 8(a)(7) reporting tool via EPA's CDX to submit information in
response to the requirements of the section 8(a)(7) rule (40 CFR Part 705). You must register
with CDX to submit online, and you must register the name of the company on whose behalf
you are submitting. EPA does not accept paper submissions or electronic media (diskette, CD-
ROM, etc.) for any section 8(a)(7) submission (40 CFR 705).
Note that many aspects of reporting for this PFAS data reporting rule are similar to
Chemical Data Reporting (CDR), but there are important differences. Even if you have reported
previously under the CDR or were exempt from reporting under CDR, you should carefully
review the reporting requirements for this rule to ensure you report correctly. Key comparisons
between section 8(a)(7) and CDR are outlined in Appendix B of this document.
You should consider the following three steps to determine whether you are required
to report for each PFAS chemical substance that you domestically manufacture (including
import) into the United States during any year since 2011 (i.e., consider calendar years 2011
through 2022):
• Step I: Is your chemical substance subject to PFAS 8(a)(7)?
• Step II: Do you qualify for streamlined reporting?
• Step III: What information must you report?
This chapter discusses each of these steps and the associated reporting requirements in
more detail.
2.1 Step I: Is Your Chemical Substance Subject to section 8(a)(7)?
For the purposes of the section 8(a)(7) Reporting Rule, per- and polyfluoroalkyl
substances or PFAS means any chemical substance that contains at least one of these three
structure units:
1) R-(CF2)-CF(R')R", where both the CF2 and CF moieties are saturated carbons
2) R-CF2OCF2-R', where R and R' can either be F, O, or saturated carbons
3) CF3C(CF3)R'R", where R' and R" can either be F or saturated carbons.
2-1
-------
Chapter 2
Reporting Requirements
This definition may not be identical to other definitions of PFAS used within EPA and/or
other organizations. See Section 2.1.2 for further description of these structures. To assist
potential reporters with determining whether certain substances may be covered under this
structural definition, EPA has identified specific PFAS covered by this rule. This non-exhaustive
list is available in EPA's CompTox Dashboard (https://comptox.epa.aov/dashboard/chemical-
Hsts/PFAS8a7) and a limited version including only chemicals on the public TSCA Inventory or
with low-volume exemptions is linked in Appendix C in this guidance document.
Note that the manufacture of PFAS as a byproduct, an impurity, or a non-isolated
intermediate is not exempt for the purpose of this rule, unlike CDR reporting. However, because
entities that import of municipal solid wastes (MSW) for the purpose of disposal or destruction
cannot know or reasonably ascertain that they imported PFAS in the MSW streams, these waste
management activities are not within the scope of this rule's reporting requirements. Per 40
CFR 705.12, "reporting under this part is not required for the import of municipal solid waste
streams for the purpose of disposal or destruction of the waste."
2.1.1 Is Your Chemical Substance Manufactured for Commercial Purposes During the
Reporting Period?
The first step in determining your reporting requirements is to determine whether you
meet the definition of manufacture or manufacturer. The following manufacturing-related
terms are defined below:
• Manufacture -To import into the customs territory of the United States (as defined in
general note 2 of the Harmonized Tariff Schedule of the United States), produce, or
manufacture for commercial purposes. (40 CFR 705.3)
• Manufacture for commercial purposes - (1) To import, produce, or manufacture with
the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer, and includes among other things, such "manufacture" of any amount of a
chemical substance or mixture:
(i) For commercial distribution, including for test marketing.
(ii) For use by the manufacturer, including use for product research and
development, or as an intermediate.
(2) Manufacture for commercial purposes also applies to chemical substances that are
produced coincidentally during the manufacture, processing, use, or disposal of another
chemical substance or mixture, including both byproducts that are separated from that
other substance or mixture and impurities that remain in that chemical substance or
mixture. Such byproducts and impurities may, or may not, in themselves have
commercial value. They are nonetheless produced for the purpose of obtaining a
commercial advantage since they are part of the manufacture of a chemical product for
a commercial purpose (40 CFR 705.3).
2-2
-------
Chapter 2
Reporting Requirements
For purposes of section 8(a)(7) reporting, a chemical substance is manufactured
(including imported) only if it is domestically produced or imported for commercial purposes.
See TSCA section 8(f), TSCA section 3(9), and 40 CFR 704.3, which includes a parallel definition
of "Import for commercial purposes." In the case of chemical substances manufactured
(including imported) by one person on behalf of another person, the manufacturer is the person
actually manufacturing the chemical substance.
As identified above, the term manufacture for commercial purposes means that the
chemical substance is produced for the purpose of obtaining an immediate or eventual
commercial advantage. Manufacture for commercial purposes also applies to chemical
substances that are produced coincidentally during the manufacture, processing, use, or
disposal of another chemical substance or mixture, including both byproducts that are
separated and impurities that remain in a chemical substance or mixture (40 CFR 705.3). Certain
activities are not considered "manufacture for a commercial purpose" (e.g., non-commercial
R&D activities such as scientific experimentation, research, or analysis conducted by academic,
government, or independent not-for-profit research organizations, unless the activity is for
eventual commercial purposes) and are not subject to the reporting requirements in this rule.
2.1.1.1 Changes to Company Ownership or Legal Identity
Under 40 CFR 705, the reporting obligation falls to the "person who manufactured
(including imported)" a chemical substance that is a PFAS. EPA recognizes that in some cases,
business transactions occurring during the reporting period have led to questions about who is
now the "person who manufactured." The scenarios in Fact Sheet: Reporting After Changes to
Company Ownership or Legal Identity are intended to serve as a general aid in appropriately
resolving these questions, but they will not necessarily account for all the relevant
circumstances of a particular transaction (note that while this fact sheet was developed for CDR,
changes in company ownership or legal identity are to be handled the same for section 8(a)(7)
reporting as for CDR). It is ultimately the manufacturer's responsibility to report appropriately
under this data call, notwithstanding the complexity of its own business transactions.
2.1.2 Is Your Chemical Substance a PFAS?
For the purposes of this action, the definition of PFAS includes any chemical substance
that structurally contains at least one of the following three sub-structures. Note that in these
formulas, R refers to the atom directly adjacent to the backbone:
1) R-(CF2)-CF(R')R", where both the CF2 and CF moieties are saturated carbons
(since the R groups are not defined, R, R', and R" may be any substituent).
2) R-CF2OCF2-R', where R and R' can either be F, O, or saturated carbons (i.e., R and
R' may be any of the following: a fluorine atom, an alcohol or ether; or any
substituent bonded to the backbone by a saturated carbon atom such as a CH2
group).
2-3
-------
Chapter 2
Reporting Requirements
3) CF3C(CF3)R'R", where R' and R" can either be F or saturated carbons (i.e., R' and
R" may be a fluorine atom or any substituent bonded to the backbone by a
saturated carbon atom such as a CH2 group).
F-
F-
¦R
¦R'
R"
y
0 F
F—|— R'
F
R1
-F
R"
F
where R, R', R" =
any substituent
Structure 1
where R, R' = F, 0,
or CR1R2R3
Structure 2
where R', R" = F,
or CR1R2R3
Structure 3
This definition may not be identical to other definitions of PFAS used within EPA and/or
other organizations. To assist potential reporters with determining whether certain substances
may be covered under this structural definition, EPA has identified specific PFAS covered by this
rule. This non-exhaustive list is available in EPA's CompTox Dashboard and a limited version
including only chemicals on the public TSCA Inventory or with low-volume exemptions as of the
publication of this guidance document is included as Appendix C in this guidance document.
Note that the CompTox list may change as chemicals are added to the Dashboard.
Manufacturers must consider all manufacturing activities during the reporting period,
which begins January 1, 2011. If a manufacturer has manufactured PFAS for commercial
purposes in any year since January 1, 2011, they would be required to report under this rule
even if they are not currently manufacturing PFAS.
This rule is limited to manufacturers (including importers) of PFAS that are considered a
"chemical substance" under TSCA section 3(2). This rule does not require reporting on activities
that are excluded from the definition of "chemical substance" in TSCA section 3(2)(B).
Under TSCA section 3(2), "chemical substance" means any organic or inorganic
substance of a particular molecular identity, including (1) any combination of such substances
occurring in whole or in part as a result of a chemical reaction or occurring in nature, and (2) any
element or uncombined radical. This rule does not require reporting on activities that are
excluded from the definition of "chemical substance" in TSCA section 3(2)(B). The term
"chemical substance" does not include: "(i) any mixture, (ii) any pesticide (as defined by the
Federal Insecticide, Fungicide, and Rodenticide Act) when manufactured, processed, or
distributed in commerce for use as a pesticide, (iii); tobacco or any tobacco product, (iv) any
source material, special nuclear material, or byproduct material (as such terms are defined in
the Atomic Energy Act of 1954 and regulations issued under such Act), (v) any article the sale of
which is subject to the tax imposed by Section 4181 of the Internal Revenue Code of 1954
2-4
-------
Chapter 2
Reporting Requirements
(determined without regard to any exemptions from such tax provided by section 4182 or 4221
or any other provision of such Code) and any component of such an article (limited to shot
shells, cartridges, and components of shot shells and cartridges), and (vi) any food, food
additive, drug, cosmetic, or device, as defined in section 201 of the Federal Food, Drug, and
Cosmetic Act, when manufactured, processed, or distributed in commerce for use as a food,
food additive, drug, cosmetic or device" [15 USC 2602(2)(B)].
Even though the definition of chemical substance excludes mixtures, PFAS as a chemical
substance may be present in a mixture. Therefore, this rule requires reporting on each chemical
substance that is a PFAS, including as a component of a mixture. This rule does not require
reporting on components of a mixture that do not fall under the structural definition of PFAS.
2.2 Step II: Do You Qualify for Streamlined Reporting?
If you determined from Step I that you manufacture (including import) a reportable PFAS
for commercial purposes, Figure 2-1 presents a decision logic diagram that may help you
determine whether you are a manufacturer (including importer) who must report with the
Standard Form or if you may qualify for streamlined reporting. The following subsections
explain each question in greater detail. Note that unlike CDR reporting, no reporting
exemptions apply to section 8(a)(7).
2.2.1 Did you import an article containing a reportable PFAS?
If you imported an article containing PFAS, you may use a streamlined Imported Article
form. This streamlined form does not require all information required for the standard form;
when you select "PFAS in Imported Articles" in the section 8(a)(7) reporting tool, the program
will show only fields required for this streamlined reporting. Only certain fields of the standard
form are required for the streamlined imported articles form. Further, because importers may
not know or be able to ascertain how much PFAS is contained within the articles, the imported
articles form allows production volume to be reported as the total weight of the imported
articles or as the quantity of articles imported (see Section 4.7.1), rather than weight of the
PFAS. If you have any additional information, such as an SDS or information about disposal,
report that information in the Optional Information section of the form (see Section 4.9).
Some sites may both import a PFAS in an article and otherwise manufacture the same
PFAS (i.e., domestically manufacture or import other than in an article). In that case, you may
choose to either report the imported article and otherwise manufactured PFAS separately, using
the streamlined imported articles form for the imported article and using the standard form for
the otherwise manufactured PFAS, or you may include the information for the imported article
within the standard form, submitting one standard form for all PFAS produced and imported by
the site.
2-5
-------
Chapter 2
Reporting Requirements
YOU DO NOT NEED
TO REPORT
Did you manufacture
(including import), for commercial
purposes, a TSCA chemical substance
that meets the definition of PFAS,
in any year since 2011?
You must report using the
standard form
You may report using the
streamlined article import form
/ You may report using the
W streamlined small quantity R&D
\ form
Figure 2-1. Decision Logic Diagram for Evaluating Step II
2-6
-------
Chapter 2
Reporting Requirements
If you are unsure whether you are importing an article, refer to the CDR "Imported
Articles" factsheet at https://tscaauideme.epa.aov/ords/tsca-ame/r/tsca/cdr-auideme/ad-
title?title=imported-articles. The definition of an article is the same for both CDR reporting, as
referenced in this factsheet, and for PFAS section 8(a)(7) reporting (40 CFR 705.3). However,
recall that while importing an article is exempt from CDR, it is not exempt from section 8(a)(7)
reporting. If you import an article containing a chemical substance that is a PFAS, you may be
eligible to use the streamlined imported articles form, but you are not exempt from reporting.
You have until January 11, 2026, to report. However, if you meet the following two criteria, you
have until July 11, 2026, to report: (1) are considered a small manufacturer pursuant to 40 CFR
704.3 (see Appendix A); and (2) have reporting obligations under this rule exclusively due to
importing articles.
Information on the fields required in the streamlined PFAS in Imported Articles form is
available in Section 40 CFR 705.18(a).
2.2.2 Did you manufacture a reportable PFAS in quantities below 10 kg per year
exclusively for purposes of research and development (R&D)?
Persons who manufacture (including import) PFAS in small quantities solely for research
or analysis for commercial purposes may report using the streamlined Research & Development
PFAS (<10 kg/year) form. The streamlined small quantity R&D form requires reporting only of
the chemical substance identification information, domestic manufacture and imported
volumes, indication of whether the substance was imported but never on site, and an optional
additional information field (see Section 4.8).
Note that any PFAS manufactured for commercial purposes is reportable under this data
call. "Manufacture for commercial purposes" encompasses any importing, production, or other
manufacturing activities with the purpose of obtaining an immediate or eventual commercial
advantage and includes chemicals "for use by the manufacturer, including use for product
research and development." R&D substances which meet the scope of "manufactured for
commercial purposes" are to be reported under this rule, even if the PFAS itself was not later
commercialized. See Section 2.1.1 for additional guidance on determining if a PFAS was
manufactured for commercial purposes."
Some sites may both manufacture a PFAS in small quantities for R&D and otherwise
manufacture the same PFAS (i.e., domestically manufacture or import). In that case, your site
does not qualify for use of the streamlined form. The streamlined form is limited to persons
manufacturing (including importing) PFAS solely for research or analysis.
Example 2-1. Example Company G produces Example PFAS G at one site. Example
PFAS G was produced in amounts of 3 kg in 2011, 7 kg in 2012, and 6 kg in 2013. Example
PFAS G was not produced during any other year since 2011 and the quantities produced were
used exclusively for research and development.
2-7
-------
Chapter 2
Reporting Requirements
Because Example PFAS G is used only for research and development, and the volume
manufactured was less than 10 kg each year, Example Company G reports using the
streamlined R&D form for Example PFAS G.
Information on the fields required in the streamlined Research & Development PFAS
(<10 kg/year) form is available in 40 CFR 705.18(b).
2.3 Step III: What Information Must You Report?
Once you determine from Steps I and II that you are a manufacturer (including importer)
of a reportable PFAS and are required to report, this section will help you determine what
information you must report.
If you are required to report and do not qualify for either streamlined form, you are
required to report all information described in 40 CFR 705.15. Importers of PFAS-containing
articles and manufacturers (including importers) of small R&D quantities may use streamlined
forms, which include only the data elements that EPA believes will be known to or reasonably
ascertainable to manufacturers in those situations. The online reporting software will guide you
through the data elements required for each form.
All reporters, regardless of reporting form(s) used, must report basic company and site
identification information (described in Sections 4.3 and 4.4) is required by 40 CFR 705.15(a)(1)
and 40 CFR 705.18(a) and (b). After reporting basic company and site identification information,
users will then select which type of reporting form is being used for a reportable PFAS, and then
the chemical identification information. Chemical identification information (described in
Section 4.5) is required by 40 CFR 705.15(a)(2) and 40 CFR 705.18(a) and (b). Note that the basic
company and site information is reported once per site, while the manufacturing information is
reported separately for each reportable PFAS at the site.
If you do not qualify for either streamlined form, you are required to report, for each
year the PFAS was manufactured, information pertaining to: the manufacture (including
import) of chemical substances and their disposal (described in Section 4.6.1); byproducts that
are manufactured during the manufacturing, processing, use, or disposal of the PFAS (described
in Section 4.6.2); worker exposure at the manufacturing site (described in Section 4.6.3);
industrial processing and use, including associated worker exposures (described in Section
4.6.4); and consumer and commercial uses, including associated worker exposures (described
in Section 4.6.5). For each PFAS, manufacturers must also submit all existing information in
their possession or control concerning the environmental or health effects of that PFAS
(described in Section 4.6.6).
Example 2-2. Example Company H manufactures 8 kg of Example PFAS H in 2017 for
on-site R&D operations in development of a new cleaning product. The company scales up
2-8
-------
Chapter 2
Reporting Requirements
R&D for this substance and manufactures 100 kg of Example PFAS H in 2018. The company
then discontinues R&D and does not ultimately commercialize Example PFAS H. Example
PFAS H is not manufactured after 2018.
Example PFAS H is manufactured for commercial purposes because Example Company
H manufactured the chemical with the purpose of obtaining an eventual commercial
advantage, so Example Company H must report the substance, even though it was not
ultimately commercialized. For 2017, the company manufactured < 10 kg of the substance
for R&D and meets the requirements for the R&D form. For 2018, the company
manufactured > 10 kg so exceeds the threshold for the R&D form. The company may take
one of two actions:
1) Use the streamlined R&D form to report for 2017 and the standard form for 2018
2) Report for both 2017 and 2018 on one standard form, completing all fields on the
form for both years.
Example 2-3. Example Company I begins importing an article containing Example PFAS
I in 2017 and continues importing the article through 2022. Example PFAS I provides stain
resistance in a finished textile product. Example Company I does not produce or import any
other products containing Example PFAS I.
Because Example PFAS I is only imported in an article, Example Company I reports for
this chemical using the streamlined imported articles form.
2-9
-------
Chapter 3
When You Must Report
3. When You Must Report
You are required to report information pertaining to each calendar year from January 1,
2011, through December 31, 2022, in which you manufactured a PFAS. The submission period
begins on July 11, 2025, and concludes January 11, 2026. However, small manufacturers (per
40 CFR 704.3) whose PFAS reporting obligations are exclusively due to importing articles have
an additional six months to report. The reporting deadline for these small article importers is
July 11, 2026.
Your report must be submitted to EPA using the electronic section 8(a)(7) reporting tool
("reporting tool") via EPA's Central Data Exchange (CDX) no later than the close of the
submission period. You should note that registration with CDX is required prior to accessing the
reporting tool to submit your PFAS data call information (40 CFR 705.35). To get you started,
guides are available on EPA's website:
• CDX Registration Guide, which covers the specifics of CDX registration
(https://cdx.epa.gov/About/UserGuide)
• CDX Chemical Safety and Pesticides Program (CSPP) registration guide, which explains
the user roles in CSPP (https://www.epa.gov/chemical-data-reporting/cspp-cdx-
registration-guide. see Section 6.3).
If you are required to report, failure to file your report during this period is a violation of
TSCA sections 8(a) and 15 and may subject you to penalties (40 CFR 705.1).
3-1
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4. Instructions for Completing Section 8(a)(7) Reporting
This chapter will help you complete section 8(a)(7) reporting. Section 4.1 describes how
to certify your submission. Section 4.2 discusses the reporting standard - the effort required to
comply with the PFAS data call. Sections 4.3 through 4.11 provide information to help you
complete each required section of the reporting form. Section 4.6 describes the Standard Form,
Section 4.7 describes the streamlined imported articles form, and Section 4.8 describes the
streamlined R&D form.
You are required to use the section 8(a)(7) online reporting tool in CDX to complete and
submit a reporting form for each reportable PFAS. If you are reporting information for more
than one PFAS at your site, you must report information for each reportable PFAS on its own
form. If you are reporting for multiple sites, you must submit separate forms for each site. In
most cases, you will submit exactly one form per chemical at the site. However, in certain cases
if you are an article importer, you may submit multiple forms for the same chemical at one site;
see Section 2.2.
The standard reporting form is comprised the following sections:
• The certification statement (Section 4.1), parent company information (Section 4.3),
and site information (Section 4.4) are completed once per reporting site, some of
which is pre-populated based on the information in your CDX account for the site.
Once this information has been completed for a reporting site, the reporting tool will
automatically populate any additional forms for other reportable PFAS the site.
• For each reportable PFAS at the site, information are reported regarding:
• the identity and properties of the PFAS (Section 4.5).
• manufacture and/or import of the PFAS (Section 4.6.1.2)
• byproducts produced during manufacture of each PFAS (Section 4.6.2).
• workers' exposure to the PFAS (Section 4.6.3).
• industrial processing and use (Section 4.6.4)
• consumer and commercial use (Section 4.6.5)
• existing information concerning the environmental and health effects of the
PFAS (Section 4.6.6).
• disposal of the PFAS (Section 4.6.1.3).
• an optional free text field that allows submittal of any additional information
(Section 4.9).
• For when confidentiality claims are made for one or more data elements,
substantiations of the confidentiality claims are required at the time of data
submission (Section 4.11).
4-1
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
The streamlined imported articles form (Section 4.7) and small-quantity R&D form
(Section 4.8) reduce the number of fields to be reported. The imported articles form includes a
subset of the standard form's fields related to importing information, industrial processing and
use, and consumer and commercial use. The R&D form includes a subset of the standard form's
fields related to manufacturing/importing information. If any other information beyond those
fields on the streamlined form is known to you, you may report that information in the free text
field (Section 4.9).
Note: Items such as the validation page and the SRS search page will appear in separate
windows. Ensure that your pop-up blocker is disabled before you begin to complete PFAS
section 8(a)(7) reporting.
4.1 Certification
Your submission(s) must be certified, indicating that your submitted information has
been completed in compliance with the PFAS data call requirements, such as all information
known or reasonably ascertainable is submitted, and that the confidentiality claims made in this
report are true and correct. To certify, the certification statement must be electronically signed
and dated by an authorized official at your company. The authorized official typically is a senior
official with management responsibility for the person (or persons) completing the form(s). You
must include the printed name, title, and email address for the person signing the certification.
See the CDX User Guide for information on how to complete an electronic signature
agreement.
This certification statement applies to all the information supplied on the form(s) for
your site. The certification statements appear when the submission process has been initiated,
at which time the submitter must either certify or cancel the submission process. If you are
completing forms for multiple sites, one submission certification will be created and must be
submitted for each site. Note that knowingly providing false or misleading information or
concealing required information may be punishable by fine or imprisonment or both under
TSCA section 16(b)(1).
4.2 Reporting Standard
Submitters are required to exercise certain levels of due diligence in gathering the
information required by the section 8(a)(7) rule. You must report your information to the extent
that the information is known to or reasonably ascertainable by you and your company.
The term "known to or reasonably ascertainable by" is defined in 40 CFR 705.3, meaning
all information in a person's possession or control, plus all information that a reasonable person
similarly situated might be expected to possess, control, or know.
Under TSCA section 8(a), EPA may collect information associated with chemical
substances to the extent that it is known to or reasonably ascertainable by the submitter. This
includes, but is not limited to, information that may be possessed by employees or other agents
4-2
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
of the company reporting under the section 8(a)(7) rule, including persons involved in the
research, development, manufacturing, or marketing of a chemical substance and includes
knowledge gained through discussions, symposia, and technical publications. For purposes of
section 8(a)(7), the known to or reasonably ascertainable by standard applies to all the
information required by the rule.
Examples of types of information that are considered to be in a person's possession or
control, or that a reasonable person similarly situated might be expected to possess, control, or
know include:
• Files maintained by the manufacturer, such as marketing studies, sales reports, or
customer surveys,
• Information contained in standard references, such as a safety data sheet (SDS) or a
supplier notification, and
• Information from the Chemical Abstracts Service (CAS) and from Dun & Bradstreet D-U-
N-S® (DUNS Number).
The hypothetical examples in Table 4-1 illustrate the anticipated application of the
"known to or reasonably ascertainable" reporting standard, in the specific context of the
collection of processing and use data under section 8(a)(7). Because the standard applies on a
case-by-case basis, however, these examples cannot substitute for a complete analysis of a
submitter's particular circumstances.
This reporting standard does not confer a testing requirement on manufacturers. But, if
manufacturers have previously tested their products for the presence of PFAS, then that
information may be considered known to or reasonably ascertainable to them and should be
submitted to EPA as appropriate.
4-3
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Table 4-1. Examples of the Application of the "Known to or Reasonably Ascertainable"
Reporting Standard for Processing and Use Data
Scenarios, Actions, and Outcomes
Scenario: Example Company J discovers that it has no knowledge of how a particular PFAS (Example PFAS J) is
processed or used by its customers. Example Company J usually maintains marketing data documenting
customers' use of its chemicals, in line with the reasonable business practices typical of comparable
manufacturers, but it irrevocably lost these data for Example PFAS J due to an inadvertent computer
malfunction. Example Company J has many customers, but it expects that it could substantially reconstruct this
missing information by briefly contacting its largest customer and asking that customer what Example PFAS J is
generally used for.
Application of KRA Reporting Standard:
If:
Then:
Example Company J contacts its largest customer and
reports on the basis of the processing and use data that the
customer was willing to provide.
Duties Likely Fulfilled
Example Company J did not endeavor to supplement the
information it already knew.
Duties Not Fulfilled
Scenario: Example Company K has never maintained information on how a particular PFAS (PFAS K) is processed
or used by its customers. However, it is typical for comparable manufacturers to collect such information as part
of their reasonable business practices. Example Company K has many customers, who it believes process and
use the particular PFAS in a similar manner and it expects that it could substantially fill this data gap by
reviewing the public website of its largest customer.
Application of KRA Reporting Standard:
If:
Then:
Example Company K reviews its largest customer's website,
and of the information contained on the website
Duties Likely Fulfilled
Example Company K did not endeavor to supplement the
information it already knew.
Duties Not Fulfilled
Scenario: Example Company L maintains seasonal marketing data on changes in use patterns for a particular
PFAS (Example PFAS L). Comparable manufacturers typically only maintain such data on an annual basis, in line
with reasonable business practices. Example Company L irrevocably loses its summer marketing data for
Example PFAS L, due to an inadvertent computer malfunction. Example Company L expects that it could
substantially reconstruct the missing summer marketing data by contacting its largest customer and asking the
customer what it used or processed Example PFAS L for in the past summer.
Application of KRA Reporting Standard:
If:
Then:
Instead of attempting to reconstruct the summer data by
contacting its largest customer, Example Company L
reports on the basis of the processing and use data that it
Duties Likely Fulfilled
4-4
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
already knows (regarding the winter, spring, and fall of the
year).
Example Company L designated the information as "not
known or reasonably ascertainable" simply because one of
the seasonal marketing reports was missing
Duties Not Fulfilled
Scenario: Example Company M has never maintained information on how a particular PFAS (Example PFAS M) is
processed or used by its customers. However, it is typical for comparable manufacturers to collect such
information as part of their reasonable business practices. Example Company M has one major customer and
ten minor customers.
Application of KRA Reporting Standard:
If:
Then:
Example Company M asks its major customer to supply
information about how Example PFAS M is processed and
used, but that customer is unwilling to supply this
information. Example Company M reasonably expects that
the only remaining way to substantially fill this data gap
would be to send a survey to its ten minor customers.
Example Company M reports that the information is "not
known or reasonably ascertainable" to it.
Duties Likely Fulfilled
Example Company M did not endeavor to obtain
processing and use information from its customers and
designated the information as "not known or reasonably
ascertainable."
Duties Not Fulfilled
Scenario: Example Company N imports an article with a water repellant "fluoropolymer" surface. However,
Example Company N does not know the chemical identity or molecular structure of the fluoropolymer coating.
Application of KRA Reporting Standard:
If:
Then:
Example Company N contacts their supplier to determine
the name, CASRN, and molecular structure of the
fluoropolymer. The supplier provides this information or a
joint submission is initiated.
Duties Likely Fulfilled
Example Company N did not contact their supplier to obtain
information on the fluoropolymer coating
Duties Not Fulfilled
Scenario: Example Company O imports stain-resistant garments. Example Company O does not know
specifically what chemical is used to impart stain resistance, but Example Company O does know that
4-5
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
chemicals used to impart stain resistance are often fluorinated chemicals and could meet the definition of
PFAS.
Application of KRA Reporting Standard:
If:
Then:
Example Company 0 contacts their supplier to determine
the name, CASRN, and molecular structure of the stain-
resistant chemical. The supplier provides this information
or a joint submission is initiated.
Duties Likely Fulfilled
Example Company 0 did not contact their supplier to
obtain Duties Not Fulfilled information on the stain-
resistant chemical.
Duties Not Fulfilled
4.3 Parent Company Information4
You must provide information about your parent company. For purposes of section
8(a)(7), a parent company is the highest-level company of your site's ownership hierarchy as of
the start of the submission period according to the definition of highest- level parent company
at 40 CFR 705.3. Report your highest-level parent company located in the United States.
Provide the company name, address, and D&B number (if applicable) following the instructions,
including the naming conventions, provided below. Table 4-2 contains examples of how to
identify the parent company in different situations.
Note that although CDR requires you to report your U.S. parent company and your
foreign parent company, section 8(a)(7) reporting requires only the U.S. parent to be reported.
Table 4-2. Applying Highest-level Parent Company Definition in Different Situations
Site Ownership
U.S. Parent Company
(1) If the site is entirely owned by a single U.S.
company that is not owned by another company
Then that single company is the U.S. parent company.
(2) If the site is entirely owned by a single U.S.
company that is, itself, owned by another U.S.-
based company (e.g., it is a division or subsidiary of
a higher- level company)
The highest-level domestic company in the ownership
hierarchy is the U.S. parent company.
4 See Section 4.4.1 for information concerning CBI claims for Parent Company Information.
4-6
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Site Ownership
U.S. Parent Company
(3) If the site is owned by more than one company
(e.g., company A owns 40 percent, company B
owns 35 percent, and company C owns 25 percent
of the site)
The company with the largest ownership interest in the
site is the parent company. Under this scenario, this
would be either company A itself (if it doesn't have a
U.S.-based parent company), company A's parent, or, if it
exists, a single parent company that owns both company
B and company C, in which case that single parent
company would have the largest ownership interest (e.g.,
corporation X owns companies B and C, for a total
ownership of 60 percent for the site).
If the parent company is a U.S. company owned by another
U.S. company, then the highest-level domestic company
in the ownership hierarchy is the U.S. parent company.
If the parent company is a foreign company, then the site is
its own U.S. parent company.
(4) If the site is ultimately owned by a 50:50 joint
venture or a cooperative
The joint venture or cooperative is its own U.S. parent
company.
If the site is owned by a U.S. joint venture or cooperative,
the highest level of the joint venture or cooperative is the
U.S. parent company.
(5) If the site is entirely owned by a foreign
company (i.e., without a U.S.-based subsidiary
within the site's ownership hierarchy)
The site is the U.S. parent company.
(6) If the site is a federally owned site
The highest-level federal agency or department is the U.S.
parent company.
(7) If the site is owned by a non-federal public entity
That entity (such as a municipality, State, or tribe) is the
U.S. parent company.
4.3.1 U.S. Parent Company Name(s)
All sites must enter the full name of the U.S. parent company. EPA requires that parent
companies be referenced consistently by the same name so that site-level information can be
aggregated to the associated parent company. This can be challenging because filers within the
same parent company often submit names with small variations (e.g., Exopack vs. Exopack
Holdings Corp). When reporting your parent company name, eliminate all periods, commas,
and all leading, trailing, and duplicate spaces. Replace commonly used acronyms and corporate
terms according to Table 4-3.
Table 4-3. Parent Company Name Standardization
Use This
Not This
&
AND
CORP
CORPORATION
4-7
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
ASSOC
ASSOCIATION
CO
COMPANY
COS
COMPANIES
DIV
DIVISION
INC
INCORP
INC
INCORP.
INC
INCORPORATED
INC
INCORPERATED
LP
LIMITED PARTNERSHIP
LTD
LIMITED
LLC
LIMITED LIABILITY COMPANY
LLC
LIMITED LIABILITY CO.
PTNR
PARTNERSHIP
USA
U.S.A.
USA
U.S.A
USA
USA
USA
UNITED STATES OF AMERICA
USA
UNITED STATES
4.3.2 Parent Company Dun & Bradstreet D-U-N-S® Number
Enter the 9-digit Dun & Bradstreet D-U-N-S® number (D&B number) associated with
your parent company name, if applicable. The number may be obtained from the treasurer or
financial officer of the company.
D&B assigns separate numbers to subsidiaries and parent companies; you should make
sure that the number you provide EPA belongs to your U.S. parent company. To verify the
accuracy of your site and parent company D&B number and name, go to
www.dnb.com/product/dlw/form cc4.htm or call 1-800-234-3867. Callers to the toll-free phone
number should understand that the D&B support representatives will need to verify that callers
requesting the D&B number are an agent of the business. D&B recommends knowing basic
information such as when the business originated, officer names, and the name, address, and
phone number for the site.
For the purpose of responding to the section 8(a)(7) rule, you are not required to obtain
a D&B number for your parent company if none exists. However, if your parent company does
not have a D&B number, you can request one from your local office of D&B if desired. There is
no charge for this service, and you are not required to disclose sensitive financial information to
4-8
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
get a number. For more information on obtaining a D&B number, see www.dnb.com. If you are
already listed with D&B, but do not know your number, you can call 1-800-234-3867 for
assistance.
4.3.3 Parent Company Address
Enter the mailing address of each parent company, including the appropriate county or
parish, using standard addressing techniques as established by the U.S. or international postal
services. Post office box numbers should be accompanied by a street address. If a post office
box is listed, it must be entered after the street address. Standardized conventions for listing a
street address should be used to account for common formatting discrepancies, such as
punctuation (by eliminating all periods, commas, and all leading, trailing, and duplicate spaces),
capitalization, and abbreviations in orderto increase the reliability and usability of the data.
Replace commonly used acronyms and street abbreviations according to Table 4-4:
Table 4-4. Parent Company Street Address Standardization
Use This
Not This
AVE
AVENUE
AVE
AVE.
BLVD
BOULEVARD
BLVD
BLVD.
DR
DRIVE
DR
DR.
HWY
HIGHWAY
HWY
HWY.
JCT
JUNCTION
JCT
JCT.
LN
LANE
LN
LN.
PL
PLACE
PL
PL.
PO BOX
P.O. BOX
RD
ROAD
RD
RD.
RTE
ROUTE
ST
STREET
4-9
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Use This
Not This
ST
ST.
4.4 Site Information
EPA requires the following information to be reported for each site at which a
reportable chemical substance is manufactured: the site name, site D&B number, street
address, city, county (or parish), state, and zip code, and six-digit North American Industry
Classification System (NAICS) code(s) of the site.
4.4.1 Confidentiality of Company, Site, and Technical Contact Information
Check the appropriate CBI box in this block and complete the substantiation questions
to assert a confidentiality claim for the link between the chemical substance and the company
or site identity or the technical contact identity reported. Checking the CBI box automatically
triggers the substantiation questions to appear later in the CBI Substantiation portion of the
form. See Table 4-30 for substantiation questions related to these data elements. If you do not
check the CBI box for any information element, then that information is not claimed as CBI
and may be made public without further notice to you. Further, if you fail to substantiate your
CBI claims in accordance with the statute and applicable rules, EPA may make the information
available to the public without further notice to you. For additional information about how to
answer substantiation questions, visit www.epa.gov/tsca-cbi on the EPA website.
You may assert a claim of confidentiality for a site, company, or technical contact
identity to protect the link between that information and the reported chemical substance.
Such a claim may only be asserted where the linkage of that information to a reportable PFAS is
confidential and not publicly available. You may claim the connection between chemical
substance and company, site, or technical contact as confidential for some PFAS for which you
are reporting, while not making the claim for others. Any confidentiality claims need to be
made on a chemical-by-chemical basis. For example, if you claimed as confidential the link
between chemical A and your company information and do not claim the link as confidential for
chemical B, EPA may make the link between your company and chemical B public without
notice. If the chemical identity is confidential, your company may instead claim the chemical
identity as confidential to protect the link between the company, site, or technical contact
information and the chemical identity. Ensure you are claiming the correct data elements as CBI
to protect confidential data.
EPA also has observed that submitters sometimes claim only their company identity, but
not their site identity, as confidential. EPA will not impute the existence of a CBI claim for site
identity from a CBI claim for company identity, even if the company name appears within the
site identity information. In other words, if your intent is to claim company name as
confidential you must claim all data elements that reference or allude to company name as CBI.
The failure to do this will likely result in a denial of a CBI claim for company name.
4-10
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.4.2 Special Provisions for Certain Sites
For PFAS that are domestically manufactured, the site is the location where the PFAS is
physically manufactured.
For importers, the site where you import a chemical substance is considered the site of
the operating unit within your organization that is directly responsible for importing the
chemical substance and that controls the import transaction. For section 8(a)(7), all importers
must provide a U.S. address for the controlling site; this site may be your company's
headquarters in the United States. If there is no such operating unit or headquarters in the
United States, the site address for the importer is the U.S. address of an agent acting on the
importer's behalf who is authorized to accept service of process for the importer (40 CFR
704.3). In the event that more than one person may meet the definition of "importer" (40 CFR
704.3) for a given import transaction, only one person should report.
Example 4-1. The headquarters of your company is located in New Town. Your
company owns a plant site located in Old Town, which is in a different state. A headquarters
employee purchases and arranges to have 50,000 lb of Example PFAS P imported from Japan
to the Old Town plant site. The headquarters site in New Town controls the import
transaction and is the site reported.
Example 4-2. The headquarters of your company is located in New Town. Your
company owns three manufacturing sites, Sites 1, 2, and 3, all located in different states. An
employee based at headquarters purchases and arranges to have 50,000 lb of Example PFAS
R imported from Japan. The chemical is distributed as follows: 2,000 lb is delivered to Site 1;
18,000 lb is delivered to Site 2; and 30,000 lb is delivered to Site 3. The headquarters in New
Town controls the import transaction for all three sites, and therefore is responsible for
reporting all 50,000 lb of Example PFAS R. The site reported is New Town.
4.4.3 Site Name
The section 8(a)(7) reporting tool will automatically populate the site name from the site
used for CDX registration. If you need to change this information, you will need to make
corrections or create a new site in CDX and create a new form for the corrected or new site.
4.4.4 Site Dun & Bradstreet Number D-U-N-S®
D&B assigns separate numbers to subsidiaries and parent companies; make sure that
the number you provide EPA belongs to the individual site for which you are reporting. If the
site does not have a D&B number, you can request one from your local office of D&B if desired.
Please refer to Section 4.3.2 for information on obtaining a D&B number.
4-11
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.4.5 Site Street Address
The reporting tool will automatically populate the site address from the site used for
CDX registration. If you need to change this information, you will need to make corrections or
create a new site in CDX and create a new form for the corrected or new site.
4.4.6 NAICS code
Enter the appropriate six-digit North American Industry Classification System (NAICS)
code or choose the correct code for each site reported. The NAICS code is the standard used by
Federal statistical agencies in classifying business establishments for the purpose of collecting,
analyzing, and publishing statistical data related to the U.S. business economy. Information
about NAICS codes can be obtained from the U.S. Census website at
www, census, gov/eos/www/naics/.
In some circumstances it may be challenging to identify a single NAICS code for the site.
In those circumstances, you may report up to three NAICS codes to more appropriately
describe your site. For example, headquarters sites that import for other sites may have
difficulty identifying a single NAICS code.
4.4.7 Technical Contact Information
This section requests information about the person whom EPA may contact for
clarification of the information in your submission. The technical contact should be a person
who can answer questions about the reported PFAS. Typically, a person located at the
manufacturing site is best able to answer such questions. However, companies may use their
discretion in selecting a technical contact or multiple technical contacts, as provided by the
section 8(a)(7) online reporting tool. In selecting the technical contact, submitters should
consider that EPA may have follow-up questions about a PFAS data submission years after the
submission date. The technical contact need not be the person who signed the certification
statement.
4.4.7.1 Technical Contact Name and Company Name
Enter the name of the person whom EPA may contact for clarification of information
submitted. Enter the name of the company employing the technical contact. You may use the
same technical contact for all chemicals submitted or you may use a different technical contact
for each chemical.
4.4.7.2 Technical Contact Telephone Number and Email Address
Enter the technical contact's telephone number, including the area code, and the
contact's email address. If the technical contact is outside of the United States, include the
country code.
4-12
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.5 How are you reporting the chemical substance?
For each PFAS you have manufactured (including imported), select the appropriate form you
are using to report:
1) Domestically Manufactured/Imported PFAS ("Standard Form")
2) PFAS in Imported Articles streamlined form
3) Research & Development (R&D) PFAS (<10 kg/year) streamlined form
See Section 2.2 for guidance to determine whether any of your reportable PFAS qualify
for reporting using one of the two streamlined form options. Depending on which form is
selected for a PFAS, the application will walk you through reporting the chemical identity
(including joint submissions in cases of unknown chemical identity, if applicable), and then the
data fields required of the respective form.
4.5.1 Chemical Substance Identification
Regardless of form type used, you must report the identity of PFAS to the extent you
know or can reasonably ascertain. If you are reporting a PFAS identity (e.g., CAS name or
number, or TSCA Inventory Accession name or number or Low-Volume Exemption number),
you must use the Agency's Substance Registry Services (SRS). In the reporting application, select
"Click here to add chemical" to use the SRS search widget to report the chemical substance
identification information consisting of the currently correct Chemical Abstracts (CA) Index
Name and the correct corresponding Chemical Abstracts Service (CAS) Registry Number
(CASRN), as described in Sections 4.5.5 and 4.5.6. The SRS is EPA's central system for
information about chemical substances that are tracked or regulated by EPA or other sources. It
is the authoritative resource for basic information about chemicals, biological organisms, and
other chemical substances of interest to EPA and its state and tribal partners.
The correct CA Index Name and CASRN (if available) must be reported for each
reportable PFAS at your site. Using the SRS search widget in the application enables reporters
to provide these fields at once. If you wish to report a PFAS listed on the confidential portion of
the TSCA Inventory, you will need to report the PFAS using a TSCA Accession Number (the
generic chemical name corresponding to the Accession Number will automatically be
incorporated into your form). Similarly, the SRS widget allows reporters to search by generic
name or Accession number to select PFAS on the confidential TSCA Inventory. See Section 4.5.2
for details on how to report confidential chemical substances. If you have a low-volume
exemption (LVE) case number for the chemical substance, that number may be searched or
reported if a CASRN or Accession Number is not known to or reasonably ascertainable by you. If
you know the CASRN or Accession Number for the chemical substance, report that number
instead of an LVE case number.
You will be able to connect directly to the SRS database from the reporting tool to report
the correct CA Index Names and CASRNs for all of your non-confidential chemical substances on
4-13
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
the TSCA Inventory. TSCA Accession Numbers and generic chemical names will be listed instead
of CA Index Names and CASRNs for chemical substances on the confidential portion of the TSCA
Inventory. The use of the SRS to obtain the identities for all reportable chemical substances is a
convenient way to meet the chemical nomenclature requirement and will help to prevent
errors in the reporting of chemical identification information for section 8(a)(7).
If you are reporting a PFAS whose identity is not in SRS (e.g., has not been required to
be reported to TSCA prior to this rule), or reporting a PFAS for which you do not know nor can
reasonably ascertain certain identifying information (i.e., CAS name or number, or TSCA
Accession or LVE numbers), the application will allow you to manually enter chemical
identification information. See Section 4.5.4 for information on reporting the PFAS identity in
the application in these scenarios.
4.5.2 Confidentiality of Chemical Substance Information
If you wish to report a chemical substance listed on the confidential portion of the TSCA
Inventory, you will need to report the chemical substance using a TSCA Accession Number.
Accession numbers are only assigned to Inventory chemicals and not to other chemicals
authorized to be in US commerce, like LVEs. The generic chemical name corresponding to the
TSCA Accession Number will also be automatically incorporated into your report.
The identities of chemical substances listed on the public version of the TSCA Inventory
are already publicly known. Therefore, claims for confidential treatment of the identity of a
chemical substance which is listed on the public section of the TSCA Inventory are not valid and
will not be allowed (40 CFR 705.30(a)(2)(i)). This includes claims for confidential treatment of
the chemical name, ID, and molecular structure.
You may claim as confidential the identity (chemical name, CAS registry number, and
molecular structure) of a chemical substance that is already listed as confidential on the TSCA
Inventory (40 CFR 705.30(f)). To assert a claim of confidentiality for a PFAS currently listed as
confidential on the TSCA Inventory, you must check the appropriate CBI box in the Chemical
Identification portion of the form (i.e., below the generic chemical name, click the statement
that "I wish to maintain an existing claim for the confidentiality of the chemical substance
identity, as listed on the confidential portion of the TSCA Inventory.") indicating in the reporting
application you wish to maintain that claim of confidentiality and submit detailed written
answers to the substantiation questions listed in Table 4-30 in the CBI Substantiation portion of
the form. If you report on a chemical with a TSCA confidentiality claim, you must select the
appropriate statement in the application to indicate whether you intend to maintain an existing
claim for the confidentiality of the chemical substance identity or not. The confidentiality claim
is only applicable to the information as it is listed on the confidential portion of the TSCA
Inventory; the corresponding accession number and generic chemical name listed on the public
portion of the TSCA Inventory is already public and cannot be claimed as confidential. You may
also claim as confidential the identity of a chemical substance that is not listed on the TSCA
4-14
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Inventory, e.g., LVE substances. CBI claims for trade names or common names are allowed but
may not be valid if the trade name or common name is public.
CBI claims for chemical identity will be accepted only when accompanied by a separate
written substantiation for the chemical substances claimed as CBI, except for chemicals
reported on article importer forms. Article importers are not required to assert CBI claims for
chemical identity. Additionally, PFAS manufacturers (except article importers) who do not know
nor can reasonably ascertain one of the following chemical-specific identifiers, are not required
to assert and substantiate a CBI claim for the PFAS identity: CASRN, TSCA Accession number, or
LVE number. Checking the CBI box automatically triggers the substantiation questions to appear
later in the CBI Substantiation portion of the form. If you fail to click the checkbox next to "CBI
for Chemical Identification" or fail to substantiate the claim for confidentiality of the chemical
identity in accordance with applicable rules, EPA may make the information available to the
public. Note that checking this box does not protect the link between your company and the
chemical substance; it only asserts a CBI claim for the specific identity of the chemical substance
as listed on the confidential portion of the TSCA Inventory.
Following the conclusion of the reporting period for this rule, EPA intends to compile a
list of reported confidential Inventory substances for which either no chemical identity CBI
claim was asserted or for which the claim was denied. Similar to past compilations, EPA will
publish this list of candidates for disclosure on the public version of the Inventory, by TSCA
accession number, on the EPA website for several months in advance of any update to the
Inventory itself. Interested parties will have an opportunity to review the list for possible errors
and contact EPA with any questions or concerns about specific candidates. In some cases, there
may be assertions by a company that a mistake has been made (e.g., an incorrect chemical was
reported), in which case EPA will undertake appropriate factual investigation as necessary to
confirm whether there were any errors that would cause EPA to reconsider whether the
chemical is no longer entitled to confidential Inventory protection. This investigation would
take place prior to the point that the specific chemical identity would be disclosed on the public
Inventory.
The requirements to report by Accession number, assert a CBI claim, and to substantiate
such claims to maintain confidential Inventory treatment do not apply to submissions
concerning imported articles. Such reporters may assert a CBI claim for trade name (if not
already public) or other non-public identifiers, but need not report by Accession number or
assert a CBI claim to maintain the confidential status of any chemical(s) associated with the
trade name or generic chemical name. EPA will not determine the CBI status of a chemical
identity based on imported article reporting.
Additional information about making and substantiating confidentiality claims is
available on EPA's website, at www,epa.aov/tsca-cbi.
4-15
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.5.3 Manufacturing a Mixture Or a Chemical Substance of Unknown or Variable
Composition or a Polymer
You should report for PFAS that are chemical substances as defined by TSCA. Note that a
mixture is not considered a chemical substance. Mixture means any combination of two or
more chemical substances if the combination does not occur in nature and is not, in whole or in
part, the result of a chemical reaction; except that such term does include any combination
which occurs, in whole or in part, as a result of a chemical reaction if none of the chemical
substances comprising the combination is a new chemical substance and if the combination
could have been manufactured for commercial purposes without a chemical reaction at the time
the chemical substances comprising the combination were combined. (TSCA 3(10)).
If you manufacture a mixture, you must determine whether you manufactured any
components of the mixture and report for each individual PFAS component of the mixture using
the information known to or reasonably ascertainable by you.
If you manufacture a PFAS as a result of a chemical reaction, you may manufacture a
chemical substance of unknown or variable composition (UVCB). A UVCB substance is an
indefinite combination of chemicals, that does not meet the statutory definition of "mixture" at
TSCA section 3(10), whose number and individual identities and/or composition are not
precisely or completely known. A UVCB combination of chemicals is subject to reporting under
section 8(a)(7) and is considered a single chemical substance.
• If you imported a mixture, you will need to report the individual PFAS components of the
mixture.
• If you domestically manufactured a mixture, you will need to determine whether any
PFAS chemical substances were formed from a chemical reaction that occurred as part
of manufacturing the mixture. If a chemical reaction has occurred, a PFAS formed from
the chemical reaction may be a chemical substance subject to reporting. If a chemical
reaction has not occurred, you have not manufactured any reportable chemical
substances in the production of the mixture. In such a case, the production of the
mixture has not triggered any requirement to report under the PFAS data call.
• Domestic manufacturers and importers should also consider whether the combination
of the chemicals they have domestically manufactured or imported (respectively) should
be chemically identified for TSCA purposes as a single UVCB chemical substance instead
of a mixture.
EPA has developed two Inventory nomenclature guidance documents related to the
mixture-UVCB determination:
• Toxic Substances Control Act Inventory Representation for Chemical Substances of
Unknown or Variable Composition, Complex Reaction Products and Biological Materials:
UVCB Substances. Available online at: www.epa.gov/sites/production/files/2015-
05/documents/uvcb.pdf;
4-16
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
• Toxic Substances Control Act Inventory Representation for Combinations of Two or More
Substances: Complex Reaction Products. Available online at:
www.epa.eov/sites/production/files/2015-05/documents/rxnprods.pdf
Polymers are a specific type of chemical that may have unknown or variable
composition. Polymers often consist of a mixture of molecules with varying degree of
polymerization, so that individual polymer molecules have different chain lengths and/or
branching and therefore have different molecular structures. For copolymers (polymers formed
from multiple monomer species), there may also be variance in the ratio and connectivity of the
monomer subunits. In that case, report the identity of each monomer and average ratios for
each copolymer. A polymer should be reported as a single PFAS. Provide any known
information about the structure and variability of the structure in the chemical description and
molecular structure data fields.
4.5.4 How to Report when Chemical Identity is Unknown or is Not in SRS
In some cases, you may know that you are manufacturing (including importing) a PFAS
but not know the identity of the PFAS. For instance, this can occur if you import a PFAS and
your supplier will not disclose the identity of the chemical, or if you do not know the identity of
reaction products or byproducts.
You must use all information known to or reasonably ascertainable by you to determine
if you are manufacturing a PFAS. For example, if you import a type of product known to
sometimes include PFAS, this could include reviewing purchase records, SDS or product data
sheets, or contacting your supplier. Additionally, you may consider the generic or trade name
provided by your supplier, published studies, results of testing or other analysis, or any other
information known to or reasonably ascertainable by you, in determining whether you have a
reportable PFAS. If you determine that the chemical substance is unlikely to be a PFAS as
defined by section 8(a)(7), you are not required to report.
If you determine that the chemical substance meets the definition of PFAS at 40 CFR
705.3, you must report the chemical even if you do not know its specific chemical identity. In the
SRS chemical search widget, select "Add New Chemical" on the bottom right of the pop-up. You
must report PFAS identities using a chemical ID number (i.e., CASRN, TSCA Accession number, or
LVE number) if one is known to or reasonably ascertainable by you; note that CAS numbers,
Accession numbers, and LVE numbers may be assigned to chemicals with unknown or variable
composition. Additionally, if you know or can reasonably ascertain another entity who would
be able to provide the chemical identity (e.g., a co-manufacturer or a foreign supplier), you
must initiate a joint submission with that entity. See Section 4.10 for more details on joint
submissions.
For the chemical name, report the CA Index name if known to or reasonably
ascertainable by you. If the CA index name is not known to or reasonably ascertainable by you,
provide the generic chemical name or description of the PFAS instead. CA name and/or CAS
number must be used to report if known, unless the chemical is treated as confidential under
4-17
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
TSCA (i.e., on the confidential Inventory or a confidential LVE). If the PFAS is not on the public
portion of the TSCA Inventory, you may claim the name as CBI. Substantiation is required unless
the PFAS has not been introduced into commerce (TSCA section 14(c)(2)(G)).
Provide the trade name or common name as appropriate. If the PFAS does not have a
trade name or common name, report "NA." For the molecular structure, provide a correct
representative or partial chemical structure diagram, as complete as can be known, if one can
be reasonably ascertained. Further details on what to include in the structure diagram are
provided in Section 4.5.9.
There may also be situations where you are reporting a PFAS whose identity you do
know, but is not in the SRS list (e.g., if the PFAS was not previously required to be reported
under TSCA). You should follow the same steps as above, by selecting "Add New Chemical" on
the bottom right of the SRS search tool. You must enter as much identifying information as is
known to or reasonably ascertainable by you. If the PFAS does have a CAS number assigned to
it, you must provide that. If you wish to claim the manually-entered chemical name and
associated number as CBI, you must check the box in the pop-up and enter a structurally-
descriptive generic name that includes "fluor" which will be made public. You will be directed to
substantiate those claims in the CBI Substantiation portion of the form. Note that you must also
check the CBI checkbox in the application for the molecular structure, if you report that
information, to assert the molecular structure of the manually-entered chemical as confidential.
4.5.5 Chemical Substance Identifying Number
Every chemical substance reported in accordance with the section 8(a)(7) rule must be
accompanied by its correct CASRN, corresponding to the chemical substance's specific chemical
name as described in Section 4.5.6. (40 CFR 705.15(b)(l)(i)). You may enter either a CASRN or
the specific name of the chemical substance to select the appropriate CASRN/Chemical
Abstracts (CA) Index Name combination from the SRS database.
Report the correct CASRN for your chemical substance if it is listed on the non-
confidential portion of the TSCA Inventory. In the case of a chemical substance listed on the
confidential portion of the TSCA Inventory, report the TSCA Accession Number as the chemical
identifying number. Note that the SRS contains a cross-reference list that displays the Accession
Number, generic chemical name, and PMN case number (or for an initial TSCA Inventory
substance, the TSCA Inventory reporting form number) for any chemical substance listed on the
confidential portion of the TSCA Inventory.
PFAS are often confidential and therefore are usually assigned Accession numbers. You
can look up a chemical's Accession number in SRS if you have the PMN case number. You may
also submit an inventory inquiry via the CDX TSCA communications module if your rights to
access this information have been validated.
If the PFAS is not listed on the TSCA Inventory, it may have a low-volume exemption
(LVE) case number. Report the LVE case number as the chemical identification number. If you
4-18
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
also know the CASRN for the PFAS, report the CASRN instead. If none of these types of
identification numbers have been assigned to the chemical, or if you do not know enough
information about the chemical identity to determine one of those identification numbers,
report as much information regarding the chemical identity as is known to or reasonably
ascertainable by you. Select the reporting tool's "Add New Chemical" button to describe the
chemical identity to the extent known.
Additionally, the type of chemical substance identifying number you use to report will
correspond to an associated code in the database after submission. See codes in Table 4-5.
Table 4-5. ID Code for Chemical Identifying Numbers
If the Number You are Reporting is a(n)
This Code Will be Entered
TSCA Accession Number
A
CAS Registry Number
C
Low-volume exemption (LVE) Case Number
L
4.5.6 Chemical Name
Report your chemical substance using the CA Index Name currently used to list the
chemical substance on the TSCA Inventory. You can identify the CA Index name by searching
SRS using a CASRN, the specific name of the chemical substance, or related synonyms. In the
event that a synonym is used for multiple chemical substances, you should take care to select
the correct substance. In describing the chemical substance, the EPA requires Chemical
Abstracts Service (CAS) chemical nomenclature be used for identification purposes when it is
available.
In cases where a chemical substance is listed on the confidential portion of the TSCA
Inventory, the generic chemical name will automatically be incorporated into your report when
you select the Accession Number in the SRS search tool.
In order to continue to protect the confidentiality of the underlying specific chemical
identification information (i.e., the CASRN and specific chemical name as listed on the
confidential portion of the Inventory), you must claim the chemical identity as confidential and
complete the upfront substantiation. The Accession Number and generic chemical name will
remain non-confidential. Failure to identify the chemical identity as confidential waives any
confidentiality claim for the chemical identity and will likely result in the transfer of the
chemical substance from the confidential portion of the TSCA Inventory to the public portion of
the TSCA Inventory.
If any entity (other than article importers reporting using the streamlined Article Importer
form) reports a PFAS by specific chemical identity and does not claim the specific chemical
identity as CBI, EPA expects to determine that the specific chemical identity is no longer
4-19
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
entitled to confidential treatment. However, EPA would not make this determination where an
entity attests that it does not have knowledge of the specific chemical identity. Instead, an
entity that does not have knowledge of a specific chemical identity must initiate a joint
submission with its supplier or other manufacturer if that entity is known. In these cases, the
secondary submitter would be responsible for providing the specific chemical identity and for
asserting and substantiating any CBI claims concerning the specific chemical identity. See, e.g.,
40 CFR 705.15(b); 705.30(f). Importers of articles using the streamlined Article Importer form
are not required to assert or substantiate CBI claims for chemical identity. Therefore, joint
submissions are not required or enabled for article importers.
4.5.7 Trade Name or Common Name
In the Chemical Identification portion of the form, the reporter must select a response
to Am I reporting the identity of the chemical?". If the reporter selects "No" (i.e., they cannot
identify their PFAS by CA Name, CAS, TSCA generic name, Accession Number, or LVE Number),
the reporting application will prompt them to report the trade name(s) or other designation and
any other information by which the product is sold or commonly known. This includes all
reporters who must initiate a joint submission with a secondary submitter (see Section 4.5.11),
and those reporters who do not know the specific chemical identity and also cannot initiate a
joint submission.
This does not apply to reporters who are able to report the identity of the PFAS
themselves, either by selecting the PFAS in the SRS widget, or by manually adding it outside of the
SRS list (see Section 4.5.4) with at least one of the following identifiers: CA Name, CAS, TSCA
generic name, Accession Number, or LVE Number.
4.5.8 Generic Chemical Name or Description
If you do not know the specific identity of the chemical substance, provide a description
of the substance. If you claimed CBI for the chemical name, you must provide a generic
chemical name. If the chemical is on the confidential portion of the TSCA Inventory, the generic
chemical name will be pre-populated from EPA's Substance Registry Service (SRS).
Generic chemical names must be sufficiently detailed to identify the reported chemical
as a PFAS. Specifically, any generic chemical name reported for a PFAS that does not contain
"fluor" in the name would be rejected by EPA as insufficient under TSCA section 14(c)(1)(C).
Additionally, any previously existing generic chemical names from earlier TSCA section 5
submissions for PFAS without "fluor" are insufficient. Further, even if a generic chemical name
reported under the TSCA 8(a)(7) rule lacks the structural unit "fluor," the Agency will identify
the chemical substance as a PFAS.
4.5.9 Molecular Structure
Upload as an attachment a representative molecular structure to the extent it is known
to you or reasonably ascertainable. This is not required if your chemical is listed as a class I
4-20
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
substance on the TSCA Inventory. If the chemical has a single defined structure, provide a
complete, correct chemical structure diagram. The diagram should clearly indicate the identity
of the atoms and the nature of bonds joining the atoms. Any ionic charges or stereochemistry
should be shown clearly. All known stereochemical details should be provided. Carbon atoms in
ring systems and their attached hydrogen atoms need not be explicitly shown. Where
applicable, specify the proportions of isomers or tautomeric forms, degree of neutralization,
etc.
For a substance with unknown or variable composition, provide a correct representative
or partial chemical structure diagram, as complete as can be known, if one can be reasonably
ascertained. The diagram should indicate the characteristic structure or variable compositional
elements of the substance. For PFAS described as reaction products, as much specific detail as
possible should be provided.
For polymers, provide a simple, representative structural diagram that illustrates what
you know or can reasonably ascertain concerning the key structural features of the polymer
molecules. For example, you could identify the linkages formed during polymerization, the
functional groups present, the range and typical values for the number of repeating structural
units, and the relative molar ratios of the precursors. Indicate if the repeating substructures are
arranged in a nonrandom order such as in graft or block arrangements. For example:
H0-C(=0)-R-0-(C(=0)-R'-C-0-R-0)n-H
3 < n < 10, where R may be either
-CF2CF2-or -CF2CF-CF3
and R' may be either a 1,4-substituted benzene ring or -(CF2)-
If you do not know nor can reasonably ascertain the molecular structure (e.g., if you know
you have manufactured a PFAS but do not have information on its specific identity), then you do
not need to upload or otherwise submit anything in this field.
4.5.10 Additional Information on Chemical Identity
In this optional free text field, you may provide any additional information known to or
reasonably ascertainable by you regarding the identity, structure, or composition of the PFAS.
This may include, but is not limited to, additional information on the composition of a UVCB
chemical or descriptions of a polymer. Report any additional information that was known to or
reasonably ascertainable by you at the time of the substance's manufacture. If no additional
information is known to or reasonably ascertainable by you, leave this text field blank.
4.5.11 Special Provisions for Joint Submitters of Unknown Chemical Substances
You may report an alternate chemical name, and a trade name, in those instances
where your supplier will not disclose to you the specific chemical name of an imported PFAS
4-21
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
because the information is claimed confidential. In these cases, you and the supplier may
report the information required in a joint submission, which is further discussed in Section 4.10
of this chapter (this does not apply to reporters using the streamlined Article Importer form). If
you, as the importer, cannot provide the chemical name, supply a trade name or other
designation to identify the proprietary chemical substance and provide the supplier's
(secondary submitter's) company information. Complete as much of the section 8(a)(7)
reporting as is known to or reasonably ascertainable by you. In addition, you must use the
reporting tool to ask the supplier (secondary submitter) of the confidential chemical substance
to directly provide EPA with the correct chemical identity (as described in Section 4.5.2), in a
joint submission with you. Note that if you actually know or can reasonably ascertain the
specific chemical identity of the chemical, you must provide that information regardless of your
supplier's confidentiality claims, rather than using a joint submission.
Your request to the supplier must include instructions for submitting chemical identity
information electronically, using the reporting tool via CDX (see 40 CFR 705.35), and for clearly
referencing your submission. Contact information for the supplier, a trade name or other
designation for the chemical substance or mixture, and a copy of the request to the supplier
must be included with your submission for the chemical substance. If your connection to your
supplier's name and other contact information, including the trade name, is confidential, you
must indicate so by checking the CBI box. Failing to check the CBI box may result in EPA making
the information publicly available without further notice to you, the submitter.
Substantiation of this confidentiality claim is not required at the time of submission.
If the secondary submitter does not know the chemical components of a mixture
supplied to you, they may ask their supplier to complete the form as a tertiary submitter. When
the secondary (or tertiary, as appropriate) submitter responds to the primary submitter's
request, the secondary submitter would use the reporting software to identify the chemical
substance in question.
If this information is considered confidential, the secondary (or tertiary, as appropriate)
submitter must indicate so by checking the CBI box and, in the case of the chemical identity as
listed on the confidential portion of the TSCA Inventory, completing the required substantiation
questions (as listed in Section 4.11 of this document). The chemical-specific function cannot be
claimed as confidential (see Sections 4.6.4.1 and 4.6.5.1 of this document for more
information). Failing to check the CBI box may result in EPA making the information publicly
available without further notice to the submitter.
These special provisions only apply in cases where the supplier will not reveal the
pertinent chemical identity to you because it is claimed confidential. In the event that you
actually know the chemical identity of a chemical substance subject to section 8(a)(7) reporting,
you must provide that information irrespective of a supplier's confidentiality claims.
EPA will only accept joint submissions that are submitted electronically using the
reporting tool via CDX (see 40 CFR 705.35) and that clearly reference the specific section 8(a)(7)
4-22
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
submission to which they refer. See Section 4.10 in this chapter for more information on
preparing joint submissions.
Joint submissions are not required for reporters using the streamlined article importer
form. Additionally, in the event that the supplier is unknown or no longer exists (e.g., supplier
has gone out of business without any successor entity), check the button in the Chemical
Identification portion of the form that states "No - I do not know the specific chemical identity
and cannot initiate a joint submission" and provide as much identifying detail as is known to
you. In this case a joint submission will not be required.
4.6 Standard Form: Domestic Manufactured/Imported PFAS
4.6.1 Manufacturing/Importing Information
The following subsections describe the manufacturing information required to be
reported for each PFAS.
4.6.1.1 Confidentiality of Manufacturing Information
Information reported in the
manufacturing section of the section
8(a)(7) form can be claimed as
confidential. For most of the data
elements, upfront substantiation of
the claim is required. Specifically,
upfront substantiation:
• IS NOT required forthe annual
domestically manufactured
volume, imported volume.
• IS required for all other data
elements.
For all manufacturing information, if you do not check the CBI box for any information
element, then that information is not claimed as CBI and may be made public without further
notice to you. Further, if you fail to assert your CBI claims in accordance with the statute and
applicable rules, EPA may make the information available to the public without further notice
to you.
For information that does require substantiation of CBI claims, checking the CBI box
automatically triggers the substantiation questions to appear later in the CBI Substantiation
portion of the form. See Table 4-30 for substantiation questions related to these data elements.
If you do not check the CBI box for any information element, then that information is not
claimed as CBI and may be made public without further notice to you. Further, if you fail to
substantiate your CBI claims in accordance with the statute and applicable rules, EPA may make
Summary of substantiation requirements for claims
of confidentiality:
All claims of confidentiality, except for information exempt from
substantiation under TSCA section 14(c)(2) such as production
volume information (including domestic manufacture and import),
and certain information in joint submissions, must be substantiated
at the time of submission as required by TSCA section 14(c)(3).
When using the reporting tool, you will be prompted to substantiate
claims where CBI substantiations are required.
For additional information about how to answer substantiation
questions, visit www.eDa.aov/tsca-cbi on the EPA website.
For information on EPA's policy of reviewing CBI claims, visit EPA
Review and Determination of CBI Claims under TSCA on the EPA
website.
4-23
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
the information available to the public without further notice to you. For additional information
about how to answer substantiation questions, visit www.epa.gov/tsca-cbi on the EPA website.
4.6.1.2 Reporting Manufacturing Information
This section describes the manufacturing data elements that should be reported for
your PFAS for each year. If any information is not known or reasonably ascertainable by you
(including your company), enter or select "NKRA" for "not known or reasonably ascertainable"
in the box corresponding to that data element. You may also check the CBI box next to each
data element to claim data as confidential. However, keep in mind that you cannot claim an
"NKRA" designation as confidential.
4.6.1.2.1 Domestically Manufactured Production Volume
Report the volume of the chemical substance domestically manufactured at your site, in
pounds. Report the quantity to at least two significant figures; it should be accurate to the
extent known to or reasonably ascertainable by you. Production volumes should be reported in
numeric format, without commas (e.g., 6352000). See Table 4-6 for examples.
4.6.1.2.2 Imported Production Volume
Report the volume of the
chemical substance imported by
your site, in pounds. Report the
quantity to at least two significant
figures; it should be accurate to the
extent known to or reasonably
ascertainable by you. You should
use the same numeric format as
described for the domestically
manufactured production volume.
Imported and domestically
manufactured production volumes
are reported separately for each PFAS at each site.
Note that if you import various mixtures containing PFAS, you should add all import
volumes associated with each PFAS. For instance, if you import three mixtures and each
mixture contains PFAS A, then you would determine the volume of PFAS A in each mixture and
report the aggregated amount. See Table 4-6 for examples.
4.6.1.2.3 For Imported Chemical Substances, Is the Chemical Never Physically at Site?
Report whether or not your imported PFAS is physically at the reporting site. Report one
of the following choices:
~ Yes, the imported PFAS is never physically at the reporting site (e.g., if you ship
the chemical substance from a foreign country directly to another location
such as a warehouse, a processing or use site, or a customer's site).
Reporting for a chemical with multiple sources
If you import a PFAS from multiple sources, or domestically
manufacture the PFAS through multiple processes, sum those sources
together for reporting the total production volume, and consider the
total amount for all other data fields.
If you import or domestically manufacture a chemical and also have
quantities on site that were not manufactured by your site (e.g.,
purchased from a domestic source), consider only the volume
manufactured (including imported) by your site when reporting total
production volume and all other data fields. Do not report on
quantities of the PFAS that were not manufactured (including
imported) by your site.
4-24
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
~ No, the imported PFAS is physically present at the reporting site.
~ NA, not applicable because the PFAS is not imported.
~ NKRA, it is not known to or reasonably ascertainable by you whether the
imported PFAS is physically present at the reporting site.
4.6.1.2.4 Volume Directly Exported
Report the volume directly exported and not domestically processed or used, in pounds.
The volume exported should not exceed the sum of the domestically manufactured and
imported volumes minus volume used on site. Note that direct exporting includes sending a
PFAS to a distributor who then exports it without repackaging it, even if it is relabeled. Direct
exporting does not include sending a PFAS to a distributor who repackages and relabels it. The
latter case would be considered an Industrial Processing and Use activity (see Section 4.6.4).
Report the quantity to at least two significant figures; it should be accurate to the extent known
to or reasonably ascertainable by you. You should use the same numeric format as described
for domestically manufactured production volume (see Section 4.6.1.2.1). See Table 4-6 for
examples.
Table 4-6. Examples of Reporting Manufactured and Imported Volumes
Description
Reporting Requirement
Example Site S domestically
manufactures 31,415 lb of Example
PFAS S.
Example Site S should report 31415 lb as domestically
manufactured for Example PFAS S. The total production volume
(i.e., the domestically manufactured volume) should be used to
report all remaining information.
Example Site T domestically
manufactures 15,000 lb of Example PFAS
T and directly imports 15,112 lb of
Example PFAS T.
Example Site T should report 15000 lb as domestically manufactured.
Because Example Site T controls the import transaction, Example Site
T should also report 15112 lb as imported for Example PFAS T. The
total production volume (i.e., sum of the domestically manufactured
and import volumes, 30112 lb) should be used to report all remaining
information.
Example Site U domestically
manufactures 33,500 lb of Example PFAS
U. Of the 33,500 lb manufactured,
Example Site U directly exports 13,000 lb
to a foreign customer.
Example Site U should report 33500 lb as domestically manufactured
and 13000 lb as exported for Example PFAS U. The volume not
directly exported (20500 lb) should be used to report all remaining
information.
Example Company V coordinates the
import of 105,000 lb of Example PFAS V,
which is imported directly to three
different sites owned by Company V. Site
1 receives 41,000 lb and Sites 2 and 3
each receive 32,000 lb of Example
PFAS V.
Example Company V should report 105000 lb as imported for Example
PFAS V. The total production volume (i.e., the imported volume)
should be used to report all remaining information. Because the three
sites controlled by Company V did not control the import transaction,
the sites are not required to report the imported volumes.
4-25
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Description
Reporting Requirement
Example Site W domestically
manufacturers 77,000 lb, imports 22,000
lb, and exports 11,000 lb of Example PFAS
W.
Example Site W should report an amount that does not exceed 88,000
lb as volume used at site for Example PFAS W, as the volume used at
site should not be greater than the sum of the domestically
manufactured and imported volumes minus the volume exported
(77,000 lb + 22,000 lb - 11,000 lb).
Example Site X imports 20,000 lb of
Example PFAS X and purchases 30,000 lb
of Example PFAS X from a domestic
producer.
Example Site X should report 20000 lb as imported for Example PFAS
X. The total production volume is 20,000 lb; the 30,000 lb of Example
PFAS X purchased from a domestic producer is not included because
Example Site X is not the manufacturer of that quantity of PFAS X (i.e.,
Site X neither imported nor produced those 30,000 lb). Only the
20,000 lb of PFAS X imported should be considered throughout the
entire section 8(a)(7) form.
The processing or use information should be reported to the extent that it is known to
or reasonably ascertainable by you (40 CFR 705.15). See Section 4.2 for a discussion of this
reporting standard and examples of information that may or may not be known to or
reasonably ascertainable by you.
If any information is not known or reasonably ascertainable by you (including your
company), enter or select "NKRA" for "not known or reasonably ascertainable" in the box
corresponding to that data element. Keep in mind that you cannot claim an "NKRA" designation
as confidential.
4.6.1.2.5 Site-limited?
Indicate whether the PFAS was site-limited. Site-limited means a chemical substance is
manufactured and processed only within a site and is not distributed as a chemical substance or
as part of a mixture or article outside the site. Imported chemical substances are never site-
limited. Report yes if the PFAS was site-limited, no if the PFAS was not site-limited, or NKRA if
you do not know and cannot reasonably ascertain whether the PFAS was site-limited.
4.6.1.2.6 Recycled Volume
Report the volume of the manufactured PFAS, which otherwise would be disposed of as
a waste, that is being removed from the waste stream (on site) and is being used for a
commercial purpose (40 CFR 705.15(d)(7)). Report the quantity, in pounds, to at least two
significant figures; it should be accurate to the extent known to or reasonably ascertainable by
you. You should use the same numeric format as described for the domestically manufactured
production volume.
Table 4-7 provides examples of reporting recycling activities.
4-26
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Table 4-7. Examples of Reporting Recycling
Description
Reporting Requirement
Example Site EF manufactures 2,721 lb of Example PFAS
EF, none of which is recycled instead of being disposed of
as a waste.
Enter 0 or NA as no portion of the chemical is
being recycled.
Example Site GH manufactures 5,550 lb of Example PFAS
GH, 1,650 lb of which is then recycled instead of being
disposed of as a waste.
Enter 1650 lb as the volume recycled.
Example Site IJ manufactures 52,000 lb of Example PFAS IJ,
10% (1,500 lb) of which is manufactured as a byproduct.
That 1,500 lb is then directly recycled and the other
50,500 lb is sold into commerce.
Enter 1500 lb as the volume recycled.
Example Site KL manufactures a chemical substance,
WonderChem. The process to manufacture WonderChem
results in the production of a byproduct, Example PFAS KL.
Some portion of PFAS KL stays with WonderChem. The
remaining portion of PFAS KL is 58,000 lb Initially Site KL
disposed of PFAS KL as a waste, but partway through the
year discovered a use for PFAS KL and diverted the
remaining portion (29,000 lb) from the waste stream. The
full volume of WonderChem is intended for commercial
use.
Enter the portion of Example PFAS KL that is being
recycled instead of being disposed of as a waste.
Do not include any quantity of PFAS KL that stays
with and is distributed with WonderChem,
because WonderChem is produced for
commercial use and no quantity is intended to be
disposed of as a waste or recycled. In this case,
29,000 pounds were recycled.
Example Site MN manufactures 12,000 lb of Example
Chemical MN for processing by incorporation into a
mixture. Of the production volume, 92% (11,040 lb) is
processed for incorporation and 8% (960 lb) is shipped to
a waste management facility that also recycles certain
materials. The manufacturer cannot reasonably ascertain
whether this portion of Example PFAS MN is being
recycled or disposed of as a waste.
Enter NKRA as the manufacturer does not know
and cannot reasonably ascertain whether PFAS
MN is being recycled or disposed of as a waste.
Example Site OP manufactures 100% of Example PFAS OP
(15,000 lb) as a byproduct. That 15,000 lb is then sold
directly to a recycler.
Enter 15000 lb as the entire volume of Example
PFAS OP is known to be recycled rather than
disposed of as a waste.
4.6.1.3 Disposal Information
4.6.1.3.1 Confidentiality of Disposal Information
Information reported in the disposal section of the section 8(a)(7) reporting form can be
claimed as confidential if it is not already public information. For all of the data elements in this
section, upfront substantiation of the claim is required.
Check the appropriate CBI box in this block and complete the substantiation questions
to assert a confidentiality claim for the associated information being submitted. Checking the
CBI box automatically triggers the substantiation questions to appear later in the CBI
Substantiation portion of the form. See Table 4-30 for substantiation questions related to these
data elements. If you do not check the CBI box for any information element, then that
4-27
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
information is not claimed as CBI and may be made public without further notice to you.
Further, if you fail to substantiate your CBI claims in accordance with the statute and applicable
rules, EPA may make the information available to the public without further notice to you. For
additional information about how to answer substantiation questions, visit www.epa.gov/tsca-
cbi on the EPA website.
4.6.1.3.2 Manner or Method of Disposal
If the PFAS is disposed of, report the method of disposal using a code or codes from
Table 4-8. Report all disposal controlled by the site (e.g., on-site disposal, off-site disposal and
shipments of waste for disposal to third parties). You are not required to report disposal
methods by downstream users. For each year, report any disposal methods(s) used during that
year. You will be prompted to and are required to report disposal in any year from 2011 to
2022, even if you did not manufacture the PFAS in each year. For example, if you manufactured
a PFAS in 2014, 2015, and 2016, and disposed of remaining waste containing that PFAS in 2016,
you must include the disposal that occurred in 2016 even though you did not manufacture all of
the disposed PFAS in that year.
If the PFAS is not disposed of in a given year, select "N/A" for that year. If you do not
know and cannot reasonably ascertain whether the PFAS is disposed of, or if you know the PFAS
is disposed of but do not know and cannot reasonably ascertain the method of disposal, select
"NKRA."
Table 4-8. Disposal Process codes
Code
Description
D1
On-site land disposal: RCRA Class C landfill (hazardous)
D2
On-site land disposal: Other landfill
D3
Other on-site land disposal
D4
On-site underground injection (UIC)
D5
Off-site land disposal: RCRA Class C landfill (hazardous)
D6
Off-site land disposal: Other landfill
D7
On-site incineration
D8
Off-site incineration
D9
Publicly owned treatment works (POTW)
D10
Other off-site waste transfer
Dll
On-site release to surface water
D12
On-site release to air (stack emissions)
D13
On-site release to air (fugitive emissions)
D99
Other
4-28
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.6.1.3.3 Changes in Disposal Methods
Use the free text field to describe any changes to the disposal process or methods since
that year, if applicable. If there have been no changes to the disposal process or methods, you
may indicate "NA" or "not applicable" in the text box.
4.6.1.3.4 Release Quantity
Report the total weight of the PFAS released to each medium (i.e., air, water, or land) in
pounds. Report the quantity to at least two significant figures; it should be accurate to the
extent known to or reasonably ascertainable by you. Release volumes should be reported in
numeric format, without commas (e.g., 6352000). Report only the weight of the specific PFAS
released. Do not include the weight of any other materials (e.g., water, solvents, containers, or
other chemical substances). Consider all possible sources of releases, including treated waste
streams. For example, incineration of PFAS waste may not fully destroy the PFAS and there may
be air releases of the PFAS associated with this process.
Table 4-9. Release media for disposal codes
Code
Description
Release Medium
D1
On-site land disposal: RCRA Class C landfill (hazardous)
Land
D2
On-site land disposal: Other landfill
Land
D3
Other on-site land disposal
Land
D4
On-site underground injection (UIC)
Land
D5
Off-site land disposal: RCRA Class C landfill (hazardous)
Land
D6
Off-site land disposal: Other landfill
Land
D7
On-site incineration
If combustion is incomplete, PFAS
may remain in stack air emissions,
ash, or scrubber blowdown, filter
material, etc., and may be released
to any medium
D8
Off-site incineration
Report off-site release media to the
extent known to or reasonably
ascertainable by you.
D9
Publicly owned treatment works (POTW)
Water
D10
Other off-site waste transfer
Report off-site release media to the
extent known to or reasonably
ascertainable by you.
Dll
On-site release to surface water
Water
D12
On-site release to air (stack emissions)
Air
D13
On-site release to air (fugitive emissions)
Air
4-29
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Description
Release Medium
D99
Other
4.6.1.3.5 Incineration Quantity and Temperature
Report the total weight of the PFAS incinerated on-site each year. If on-site incineration
occurred, also report the incineration temperature (in degrees Celsius). If incineration occurred
at multiple temperatures, indicate the minimum temperature (in degrees Celsius) at which the
PFAS was incinerated. Report only the weight of PFAS destroyed by incineration. Quantities of
PFAS not destroyed (e.g., released to air or remaining in ash) should be reported as releases in
the previous section.
4.6.1.4 Physical Form
Report all physical forms of the PFAS at the time it is reacted or as it leaves your site (40
CFR 705.15(b)(2)). For each PFAS at each site, the submitter must report as many physical forms
as applicable from the following six physical forms:
• Dry powder
• Pellets or large crystals
• Water-or solvent-wet solid
• Other solid
• Gas or vapor
• Liquid
CBI claims for physical state(s) of the chemical are allowed regardless of the
confidentiality status of the chemical. Substantiation questions to be answered for physical
state CBI claims are the same questions to be answered for confidentiality of manufacturing
information listed in Table 4-30 in Section 4.11.
4.6.2 Byproduct Information
In this section, report information about all byproducts resulting from the manufacture,
processing, use, or disposal of the PFAS. Report information about all byproducts that are
chemical substances, regardless of whether the byproducts are themselves PFAS. Information in
this section is to be reported for each byproduct manufactured in each year. Report all
information known to or reasonably ascertainable by you, including byproducts produced
during processing, use, or disposal of the PFAS at sites not under your control.
Note that in the case that you manufacture a PFAS at your site as a byproduct of
another PFAS, you may also be required to report that PFAS on its own section 8(a)(7) form. For
example, if you are reporting for PFAS A, and PFAS B is produced at your site as a byproduct of
manufacturing PFAS A, you will also need to complete a section 8(a)(7) form for PFAS B. In that
case, on your reporting forms for PFAS A, you may indicate in the Byproduct Information
Duplicative Reporting
The information in this section regarding
physical form, described in Section 4.6.1.4, may
have been previously reported under CDR. See
Section 1.2 for instructions on how to inform EPA
that this information has already been reported.
4-30
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
section that certain information related to PFAS B is duplicative of other reporting (i.e., on PFAS
B's own form).
For purposes of section 8(a)(7) reporting, refer to the following definition of byproduct:
Byproduct means a chemical substance produced without separate
commercial intent during the manufacture, processing, use, or disposal of another
chemical substance(s) or mixture(s). (40 CFR 704.3)
Manufacture for commercial purposes means:
(1) To manufacture, produce, or import with the purpose of obtaining an immediate or
eventual commercial advantage, and includes, among other things, the "manufacture" of
any amount of a chemical substance or mixture
(i) for commercial distribution, including for test marketing, or
(ii)for use by the manufacturer, including use for product research and
development or as an intermediate.
(2) The term also applies to substances that are produced coincidentally during the
manufacture, processing, use, or disposal of another substance or mixture, including
byproducts that are separated from that other substance or mixture and impurities that
remain in that substance or mixture. Byproducts and impurities without separate
commercial value are nonetheless produced for the purpose of obtaining a commercial
advantage, since they are part of the manufacture of a chemical substance for
commercial purposes.
4.6.2.1 Confidentiality of Byproduct Information
Except for the identities of chemical substances on the non-confidential TSCA Inventory,
any information reported in the byproducts section of the section 8(a)(7) form can be claimed
as confidential. For all of the data elements in this section, upfront substantiation of the claim is
required.
Check the appropriate CBI box in this block and, during the CBI Substantiation portion of
the form, complete the substantiation questions to assert a confidentiality claim for the
associated information being submitted. Checking the CBI box automatically triggers the
substantiation questions to appear later in the CBI Substantiation portion of the form. See
Table 4-31 for substantiation questions related to the byproduct chemical identity and Table
4-30 for substantiation questions related to the other byproduct data elements. If you do not
check the CBI box for any information element, then that information is not claimed as CBI
and may be made public without further notice to you. Further, if you fail to substantiate your
CBI claims in accordance with the statute and applicable rules, EPA may make the information
available to the public without further notice to you. For additional information about how to
answer substantiation questions, visit www.eDa.gov/tsca-cbi on the EPA website.
4-31
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.6.2.2 Byproduct Name or Description
In the application, select "Add Byproduct" for each byproduct you must report for that
year.
Report your chemical substance using the CA Index Name currently used to list the
chemical substance on the TSCA Inventory. Using the "Search SRS" button, you can identify the
CA Index name by searching SRS using a CASRN, the specific name of the chemical substance, or
related acronyms, similar to the search widget used for reporting the PFAS identity. In the event
that an acronym is used for multiple chemical substances, you should take care to select the
correct substance. Using the search widget to select a substance will automatically populate
both the chemical name and chemical ID.
If the name of the byproduct is unknown, describe the byproduct using the "Add New
Chemical" button in the SRS byproduct widget. The description may be a descriptive name, but
you must describe the byproduct as specifically as possible. The description you provide should
accurately and precisely convey as much information about the molecular structure of the
byproduct as is known to you. In the "Add Chemical to Section 8(a)(7)" window, you may also
add additional chemical information to provide as much specificity as you know or can
reasonably ascertain regarding the identity or composition of that byproduct.
4.6.2.3 Byproduct Generic Chemical Name [if byproduct chemical name is CBI]
In cases where a chemical substance is listed on the confidential portion of the TSCA
Inventory, the generic chemical name will automatically be incorporated into your report when
you select the Accession Number from the search tool.
In cases where a chemical substance is not found on the SRS search tool but you wish to
assert and substantiate the chemical identity as CBI, you must provide a structurally-descriptive
generic name of that identity in addition to its specific one. The generic name will be made
public.
4.6.2.4 Byproduct Chemical ID
Every byproduct reported in accordance
with section 8(a)(7) requirements must be
accompanied by its correct CASRN, corresponding
to the chemical substance's specific chemical
name as described in Section 4.5.6. (40 CFR
705.15(e)(1)). You may use the search widget to
enter either a CASRN or the specific name of the
chemical substance to select the appropriate
CASRN/Chemical Abstracts (CA) Index Name
combination from the SRS database. Using the
search widget to select a substance will automatic
chemical ID.
Report the correct CASRN for your chemical
substance if it is listed on the non-confidential
portion of the TSCA Inventory. If your chemical
substance is listed on the confidential portion of the
TSCA Inventory, report the EPA-designated TSCA
Accession Number.
If your chemical substance is not on the TSCA
Inventory, report the CASRN if one has been
assigned. Do not select the CASRN button on the
search tool if no CASRN has been assigned to the
chemical substance and if the identity of the
byproduct is not known to or reasonably
ascertainable by you.
/ populate both the chemical name and
4-32
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
In the case of a chemical substance listed on the confidential portion of the TSCA
Inventory, report the TSCA Accession Number as the chemical identifying number. Similarly, if a
chemical substance has an LVE Number and a CBI claim, the reporter should report the LVE
Number as the identifying number.
If the chemical substance is not listed on the TSCA Inventory, report the CASRN if one
has been assigned to the chemical substance. You do not need to select the chemical
identifying number buttons (CASRN, PMN No., or Accession No.) if they have not been assigned
or if you do not know and cannot reasonably ascertain the identity of the byproduct. If you do
not know and cannot reasonably ascertain the identity of the byproduct, you must provide a
generic, structural description of the byproduct.
4.6.2.5 Byproduct Source
Indicate whether the byproduct was created as a result of manufacturing, processing,
use, and/or disposal. For example, a byproduct created unintentionally while manufacturing a
PFAS was created as a result of manufacturing. A byproduct created during management of the
PFAS waste, such as a combustion byproduct formed during thermal treatment, is considered
to be created as a result of disposal.
4.6.2.6 Byproduct Release
Indicate whether the byproduct was released to the environment. Select yes, no, or
NKRA. For purposes of reporting under this section, "released to the environment" includes
quantities of the chemical disposed of in contained land disposal units such as underground
injection wells and landfills as well as releases directly to air, water, and soil.
4.6.2.7 Byproduct Release Medium
If the byproduct was released to the environment, select all media to which the
byproduct was released: air, water, and/or land.
If your byproduct is also a reportable PFAS for which your site is submitting a separate
form, you have the option to indicate in this section that the environmental release information
(i.e., release medium and volume) are duplicative of other information that will be reported for
that byproduct on its own form.
4.6.2.8 Byproduct Release Volume
For each medium to which the byproduct was released, report the total volume of the
byproduct released, in pounds. Report the quantity to at least two significant figures; it should
be accurate to the extent known to or reasonably ascertainable by you. Release volumes should
be reported in numeric format, without commas (e.g., 6352000). Report only the weight of the
byproduct(s) released. Do not include the weight of other materials (e.g., water, solvents,
containers, or other chemical substances).
4-33
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
If you do not know nor can reasonably ascertain the amount of the byproduct released
to that medium, enter "NKRA".
If your byproduct is also a reportable PFAS for which your site is submitting a separate
form, you have the option to indicate in this section that the environmental release information
(i.e., release medium and volume) are duplicative of other information that will be reported for
that byproduct on its own form.
Table 4-10 provides some examples of facilities reporting byproduct information.
Table 4-10. Examples of Byproducts Reporting
Example
Reporting
Example Company QR manufactures Example PFAS QR
and is completing the section 8(a)(7) form for Example
PFAS QR. During treatment of PFAS QR-containing
waste, the site produces 5.0 pounds of hydrogen
fluoride. 80% of the hydrogen fluoride is captured by a
dry scrubber and spent scrubber medium is disposed of
on site in a landfill. The remaining 20% is directly
released to air through the site's stacks.
Example Company QR enters CAS # 7664-39-3 as a
byproduct. The section 8(a)(7) software populates the
CAS name for the chemical, hydrofluoric acid. Company
QR reports that the source of this byproduct was
disposal. The company reports that the byproduct was
released to air and land and 5.0 pounds were released.
Example Site ST manufactures Example PFAS ST and is
completing a section 8(a)(7) form for Example PFAS ST.
During manufacture of Example PFAS ST, another
chemical substance is formed that is also a PFAS,
Example PFAS UV. Most of PFAS UV remains in the
company's product, but 12 pounds of PFAS UV are
released to air on site.
Example Site ST enters the CAS number and CA name of
Example PFAS UV and reports manufacturing as its
source. Example Site ST reports that PFAS UV was a
byproduct released to air and that releases totaled 12
pounds. Example Site ST also completes a full section
8(a)(7) submission for Example PFAS UV.
Example Site WX manufactures Example PFAS WX. The
company knows that during on-site processing of
Example PFAS WX, a byproduct is formed, but the
company does not know the identity of the byproduct.
All of the byproduct produced remains in the company's
product and is distributed into commerce.
Example Site WX reviews the information they know
and can reasonably ascertain and determines that the
specific chemical identity is unknown.
Example Site WX provides a description of the
byproduct and indicates "NKRA" for the Chemical ID.
Example Site WX indicates that the byproduct was
produced during processing and that the byproduct was
not released to the environment. The site reports "N/A"
for the byproduct release medium and release volume.
Example Site YZ manufactures Example PFAS YZ. During
manufacture of Example PFAS YZ, two byproducts are
formed, Example PFAS AA and Example PFAS BB. PFAS
AA is separated from the mixture and all 150 pounds
produced are disposed of in the site's on-site landfill.
Most of PFAS BB remains in the product and is
distributed into commerce. The company knows some
amount of PFAS BB is released to air on site but cannot
determine how much.
Example Site YZ first reports the chemical name and
CAS number for PFAS AA and indicates that PFAS AA is
produced during manufacturing. Site YZ reports that
150 lb of PFAS AA are disposed of to land. Next, Site YZ
enters the name and CAS number of PFAS BB as
another byproduct. For PFAS BB, the company reports
its source as manufacturing and reports that it is
released, to air, with total release quantity NKRA.
4-34
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.6.3 Exposure Information at the Manufacturing Site
In this section, report information concerning workers' exposure to the PFAS at the
manufacturing site. Reporting in this section includes information on the activities resulting in
exposure, number of workers exposed and the maximum duration of exposure at the
manufacturing site.
4.6.3.1 Confidentiality of Worker Exposure Information
Information reported in the worker exposure section of section 8(a)(7) reporting can be
claimed as confidential. For all of the data elements in this section, upfront substantiation of the
claim is required.
Check the appropriate CBI box in this block and complete the substantiation questions
to assert a confidentiality claim for the associated information being submitted. Checking the
CBI box automatically triggers the substantiation questions to appear later in the CBI
Substantiation portion of the form. See Table 4-30 or substantiation questions related to these
data elements. If you do not check the CBI box for any information element, then that
information is not claimed as CBI and may be made public without further notice to you.
Further, if you fail to substantiate your CBI claims in accordance with the statute and applicable
rules, EPA may make the information available to the public without further notice to you. For
additional information about how to answer substantiation questions, visit www.epa.gov/tsca-
cbi on the EPA website.
4.6.3.2 Worker Category and Activity
In this section of the application, describe the worker activities at the manufacturing site
during which workers may be exposed to the PFAS. First, select the appropriate worker
category, then the appropriate worker activity. The application will show the associated worker
activity(ies) after the worker category is selected. See Table 4-11 for the list of worker
categories, and their associated worker activities. These worker categories and activities mirror
those in the TSCA Pre-Manufacturing Notice (ePMN).
Table 4-11. Codes for Worker Category and Activity Codes
Worker Category
Worker Activity
Loading onto Transport Containers/Vessels
Loading into Bottles
Loading into Small Containers
Loading into Drums
Loading into Totes
Loading into Tank Trucks
Loading into Rail Cars
4-35
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Worker Category
Worker Activity
Loading into Containers
Loading into Transport Containers
Loading into Storage/Transport Vessels (other)
Unloading from Transport Containers/Vessels
Unloading from Bottles
Unloading from Small Containers
Unloading from Drums
Unloading from Totes
Unloading from Tank Trucks
Unloading from Rail Cars
Unloading from Containers
Unloading from Transport Containers
Unloading from Storage/Transport Vessels (other)
Cleaning Residuals from Transport
Containers/Vessels
Cleaning Residuals from Bottles
Cleaning Residuals from Small Containers
Cleaning Residuals from Drums
Cleaning Residuals from Totes
Cleaning Residuals from Tank Trucks
Cleaning Residuals from Rail Cars
Cleaning Residuals from Containers
Cleaning Residuals from Transport Containers
Cleaning Residuals from Storage/Transport Vessels
(other)
Sampling
Sampling
Equipment Cleaning Losses
Equipment Cleaning Losses from a Single, Small Vessel
Equipment Cleaning Losses from a Single, Large Vessel
Equipment Cleaning Losses from Multiple Vessels
Equipment Cleaning Losses of Solids from Process Vessels
Unit Operations and Processes
Aqueous Wash of Organic Mass
Distillation Column Bottoms Disposal
Filter Media Changeout
Grinding and Sanding
Liquid/Liquid Extraction Solvent Disposal
Scrubber Releases
Miscellaneous Activities
Miscellaneous Activities Related to Liquid Processing
4-36
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Worker Category
Worker Activity
Miscellaneous Activities Related to Solid Processing
Miscellaneous Activities Releases Related to Liquid
Processing
Miscellaneous Activities Releases Related to Solid
Processing
Miscellaneous Activities (other)
Automobile Spray Coating
Automobile OEM Spray Coating Application
Automobile Refinish Spray Coating Application
Generic Coating Applications
Rail Coating
Coating Using Hand Held Spray Gun
Coating Using Hand Held Spray Can
Recirculating Water-Cooling Tower Additives
Recirculating Water-Cooling Tower Additives
4.6.3.3 Number of Workers Exposed at the Manufacturing Site
For each activity listed above, report the total number of workers reasonably likely to be
exposed to the reportable PFAS at the manufacturing site (40 CFR 705.15(g)). Select the code
corresponding to the appropriate range for the number of workers reasonably likely to be
exposed to the PFAS during manufacture. Table 4-12 lists the codes and ranges.
Table 4-12. Codes for Reporting Number of Workers Reasonably Likely to be Exposed
Code
Range of Workers Reasonably Likely to be Exposed
W1
Fewer than 10 workers
W2
At least 10 but fewer than 25 workers
W3
At least 25 but fewer than 50 workers
W4
At least 50 but fewer than 100 workers
W5
At least 100 but fewer than 500 workers
W6
At least 500 but fewer than 1,000 workers
W7
At least 1,000 but fewer than 10,000 workers
W8
At least 10,000 workers
"Reasonably likely to be exposed" means "an exposure to a chemical substance which,
under foreseeable conditions of manufacture, processing, distribution in commerce, or use of
the chemical substance, is more likely to occur than not to occur. Such exposures would
normally include, but would not be limited to, activities such as charging reactor vessels,
drumming, bulk loading, cleaning equipment, maintenance operations, materials handling and
transfers, and analytical operations. Covered exposures include exposures through any route of
4-37
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
entry (inhalation, ingestion, skin contact, absorption, etc.), but excludes accidental or
theoretical exposures" (40 CFR 711.3).
Persons reasonably likely to be exposed to a chemical substance include workers whose
employment requires them to pass through areas where chemical substances are
manufactured, processed, or used (e.g., production workers and foremen, process engineers,
and plant managers). Workers employed to drive vehicles which transport the chemical
substance should be included in the number of workers reasonably likely to be exposed to the
chemical substance if they come into contact with the chemical substance during loading or
unloading. For example, workers engaged in the connection or disengagement of hoses used to
load or unload the chemical substance should be included. However, workers involved solely
with transporting chemical substances in sealed containers that are totally enclosed with no
potential for exposure should not be included.
In addition, when a site employs temporary, seasonal, or contract workers in the
manufacture of a reportable chemical substance, these workers should be included in the
number of workers reasonably likely to be exposed to a chemical substance if they work in
areas where the chemical substance is manufactured. The term does not include those
employees whose jobs are not associated with potential exposures to a chemical substance or
mixture (e.g., administrative staff who never enter areas where the chemical substance is
manufactured) and who are unlikely to be exposed to a chemical substance for even a brief
period of time.
No allowance is made for personal protective equipment or for engineering controls
that reduce but do not preclude exposure to a chemical substance; however, if contact
between a worker and a chemical substance is highly improbable, the worker should not be
included among those persons reasonably likely to be exposed to the chemical substance.
Workers are considered to be exposed even if the chemical does not enter the body. For
instance, skin contact with a PFAS-containing article is considered an exposure if the worker
comes into contact with the PFAS, even if it is believed not to migrate from the article or is not
dermally absorbed.
There is no minimum duration or frequency of exposure for determining the number of
workers reasonably likely to be exposed to a chemical substance. If it is determined that a
worker is reasonably likely to be exposed at any time during the year for any length of time, this
worker should be included in the estimate.
There is no minimum level of exposure to a PFAS below which a worker need not be
counted among the number reasonably likely to be exposed to a chemical substance.
Therefore, if a company knows that a chemical substance manufactured at the site is present in
the air throughout the site, all workers at the site must be included in the number of workers
reasonably likely to be exposed to the chemical substance.
4-38
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
When there is no potential exposure to a chemical substance, the code W1
corresponding to fewer than 10 workers would be reported. This would be the case, for
instance, when a chemical substance is imported in sealed containers and resold without
repackaging or is shipped from a foreign source directly to a customer.
Throughout this section, for clarity, the terms "exposed" and "exposure" are used to
mean "reasonably likely to be exposed" and "reasonably likely exposure."
4.6.3.4 Maximum Duration of Exposure for Manufacturing Workers
For each activity reported, indicate the maximum duration of exposure for any worker
at the manufacturing site in hours per day and the maximum number of days per year that
workers may be exposed. If workers have different lengths of exposure (for example, due to
shift schedules or different job roles), consider two scenarios: the worker(s) who have the
longest duration of exposure on any day of the year (called maximum daily exposure), and the
worker(s) who are exposed on the highest number of days per year (called maximum annual
exposure). For each of these workers, report the maximum duration of exposure on any single
day as well as the number of days per year that the worker is reasonably likely to be exposed.
For each activity, consider the following questions:
1) What worker or group of workers is exposed for the longest amount of time on any
one day doing this activity?
a. How long is that maximum amount of time that the worker or group of
workers is exposed doing this activity?
b. On how many days per year is this worker(s) exposed to the PFAS while
doing this activity?
4) What worker or group of workers is exposed on the largest number of days each
year doing this activity?
c. How many days per year is that worker or group of workers exposed doing
this activity?
d. What is the longest amount of time that worker(s) is exposed doing this
activity on any one day?
Report maximum daily exposure to the nearest hour, except for workers exposed for
less than one hour. Report 1 hour for any worker exposed for less than one hour; do not round
to zero. If you know the duration of exposure to a greater degree of precision than the nearest
hour, report the more precise information. If work shifts at your site cross midnight, you may
consider the work shift to be one day (e.g., a worker who is exposed on one shift from 10 PM
until 6 AM the next day may be counted as one day of exposure and 8 hours of daily exposure).
Recall that in this section, you are reporting exposure by activity. If a worker at your site may be
exposed to the PFAS during multiple activities, report for each activity considering that activity
alone, and not any other activities.
4-39
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Table 4-13 shows how companies would report in various example scenarios.
Table 4-13. Example manufacturing worker exposure scenarios
Exposure Scenario
Exposure for worker(s) with
maximum daily exposure
Exposure for worker(s) with
maximum annual exposure
Example Site CC has reported reaction
vessel clean-outs as an activity with
worker exposure to Example PFAS CC.
Production line workers perform one
thorough clean out per year, which
takes 10 hours, and less-thorough
monthly clean-outs, which each take 5
hours, for a total of 12 cleanings per
year. The same workers perform all
cleanouts.
Report 10 hours as the maximum
daily exposure, because this is
the longest duration of exposure
for workers on any single day.
Report 12 days as the maximum
annual frequency, because these
workers are exposed up to 12
days per year.
In this case, this activity is only
done by one group of workers, so
the workers with the maximum
daily exposure are also the workers
with the maximum annual
exposure. Report 10 hours as the
maximum daily exposure and 12
days as the maximum annual
frequency.
At Example Site DD, workers may be
exposed to Example PFAS DD when
charging reactor vessels, a process that
usually takes one hour but sometimes
takes up to two hours. Reactor vessels
are charged every day and the site
operates 360 days per year, but no one
worker works more than 5 days per
week, or 260 days per year.
Report 2 hours as the maximum
daily exposure, because this is
the longest amount of time the
activity takes. Report 260 days
per year as the maximum annual
exposure, because any single
exposed worker may be exposed
up to 260 days per year.
In this case, this activity is only
done by one group of workers, so
the workers with the maximum
daily exposure are also the workers
with the maximum annual
exposure. Report 2 hours as the
maximum daily exposure and 260
days as the maximum annual
frequency.
Example Site EE imports Example PFAS
EE in sealed vessels, re-labels the
containers, and ships the containers
without repackaging. No workers are
expected to be exposed to PFAS EE.
Because no activities resulting in
worker exposure occurred,
report "N/A" for this section.
Because no activities resulting in
worker exposure occurred, report
"N/A" for this section.
Workers at Example Site FF are
reasonably expected to be exposed to
Example PFAS FF while charging
reactor vessels, which takes no more
than 3 hours. Reactor vessels are
charged every day. The site rotates
staff duties, so that no worker
performs reactor vessel charging more
than one day per week, or 52 times per
year.
Line supervisors may also be briefly
exposed to PFAS FF during this activity.
Supervisory duties are split equally
between two workers, so that each
performs this duty 180 days per year.
The workers with the maximum
daily exposure for this activity
are the workers actually charging
reaction vessels, who may be
exposed for up to 3 hours in a
single day. Report 3 hours for the
maximum daily exposure in this
section. These workers are
exposed up to 52 days per year,
so report 52 days as the
maximum annual exposure in
this section.
The workers with the maximum
annual exposure for this activity
are the supervisors, who may each
be exposed for up to 180 days
during the year. These workers are
exposed for no more than 15
minutes on any given day. Report 1
hour (do not round exposures less
than one half-hour down to zero)
for the maximum daily exposure
and 180 days as the maximum
annual exposure in this section.
4-40
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Exposure Scenario
Exposure for worker(s) with
maximum daily exposure
Exposure for worker(s) with
maximum annual exposure
Workers at Example Site GG are
exposed to Example PFAS GG during
two activities: transferring the
chemical from totes to smaller vessels
and cleaning empty totes. Workers
transfer the chemical from totes
multiple times per day, resulting in
total daily exposure of up to one hour.
Workers perform this activity at the
site up to 208 days per year. Empty
totes are cleaned twice a year and the
process takes two hours. The same
workers do both tasks.
Transfer to smaller vessels:
Workers are exposed to PFAS GG
for a maximum of 1 hour per day
while transferring the chemical.
This exposure may happen on a
maximum of 208 days per year.
Report 1 hour per day and 208
days per year for this activity.
Tote cleaning: Workers are
exposed to PFAS GG for up to two
hours while cleaning totes, which
may occur a maximum of two
days per year. Report 2 hours and
2 days per year for this activity.
In this case, the workers with the
maximum daily exposure and
maximum annual exposure are the
same for each activity. Report 1
hour per day and 208 days per year
for chemical transfer and 2 hours
and 2 days per year for tote
cleaning.
Note that although the same
workers perform both activities,
reporting in this section is by
activity. Do not combine exposure
from multiple activities when
reporting in this section.
4.6.4 Industrial Processing and Use
For purposes of section 8(a)(7) reporting, an industrial use means use at a site at which
one or more chemical substances or mixtures are manufactured (including imported) or
processed (40 CFR 705.3).
For each PFAS manufactured (including imported), report up to ten unique
combinations of the following data elements: the Type of Process or Use Operation (TPU)
(described in Section 4.6.4.2), the Industrial Sector (IS) (described in Section 4.6.4.3), and the
Function Category (FC) (described in Section 4.6.4.4) (40 CFR 705.15(c)(4)). A combination of
these three data elements defines a potential exposure scenario for risk-screening and priority-
setting purposes. If more than ten unique combinations apply to a chemical substance, you
need only report the ten combinations for the chemical substance that cumulatively represent
the largest percentage of production volume, measured by weight. The reporting tool will allow
you to enter more than ten combinations if you choose to do so.
For each of these unique combinations, you are also required to report the percentage
of production volume in Section 4.6.4.5, and information about worker exposure in Section
4.6.4.6 and 4.6.4.7 (40 CFR 705.15(g)).
You are required to report information that is known to or reasonably ascertainable by
you concerning the industrial uses of the PFAS manufactured (including imported) at sites you
control and at sites controlled by people to whom you have either directly or indirectly
(including through a broker/distributor, from a customer, etc.) distributed the reportable
chemical substance (40 CFR 705.15(c)(1)).
4-41
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.6.4.1 Confidentiality of Processing and Use Information
Some data elements in this section may not be claimed as confidential. You may not
claim the following data elements as confidential:
• Certain industrial processing and use data elements. These data elements are a general
description of how the chemical is used or processed and cannot be claimed as
confidential:
o type of process or use
o industrial sector
o function code.
4.6.4.2 Type of Process or Use Operation
To the extent that it is known to or reasonably ascertainable by you, report the code
which corresponds to the appropriate Type of Processing or Use Operation (TPU) for the
particular combination of IS and FC codes. Table 4-14 shows the codes and TPUs. Note that if a
chemical substance is fully reacted (i.e., reporting "PC" for the processing code), then the
chemical substance is wholly consumed and further processing and use information for that
chemical substance will not exist. In such a situation, there is no further downstream processing
and use information to be reported for that particular type of processing or use operation
under 40 CFR 705.15(c)(1). A processing or use code may be reported more than once if more
than one IS and/or FC code applies to the same processing or use operation. Definitions for
each code are provided in Appendix D, which may assist you in determining which code to
report.
Table 4-14. Codes for Reporting Types of Industrial Processing or Use Operations
Designation
Operation
PC
Processing as a reactant.
PF
Processing—incorporation into formulation, mixture, or reaction product.
PA
Processing—incorporation into article.
PK
Processing—repackaging.
U
Use—non-incorporative activities.
4.6.4.3 Industrial Sectors
Report the code that corresponds to the appropriate Industrial Sector (IS) for all sites
that receive a reportable PFAS from you either directly or indirectly (including through a
broker/distributor, from a customer of yours, etc.) and that process and use the PFAS to the
extent that this information is known to or reasonably ascertainable by you (40 CFR
705.15(c)(2)). Table 4-15 shows the codes and sectors. Because an industrial sector may apply
to more than one processing and use scenario for a chemical substance, the same IS code may
4-42
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
be reported with different combinations of FC and TPU codes. A list identifying the
correspondence between NAICS codes and IS codes is provided in Appendix D (Table D-2).
When you chose the IS "Other," you also need to provide a written description of the
use of the chemical substance. The written description should be used to provide a description
at a comparable level of specificity as found with the current codes. It should not be used to
add additional, more specific detail. Your description may include the NAICS code. If you select
the IS "Other," a text box will appear for you to enter the description. Do not include CBI in this
text box.
Table 4-15. Codes for Reporting Industrial Sectors
Code
Sector description
IS1
Agriculture, forestry, fishing, and hunting.
IS2
Oil and gas drilling, extraction, and support activities.
IS3
Mining (except oil and gas) and support activities.
IS4
Utilities.
IS5
Construction.
IS6
Food, beverage, and tobacco product manufacturing.
IS7
Textiles, apparel, and leather manufacturing.
IS8
Wood product manufacturing.
IS9
Paper manufacturing.
IS 10
Printing and related support activities.
IS 11
Petroleum refineries.
IS 12
Asphalt paving, roofing, and coating materials manufacturing.
IS 13
Petroleum lubricating oil and grease manufacturing.
IS 14
All other petroleum and coal products manufacturing.
IS 15
Petrochemical manufacturing.
IS 16
Industrial gas manufacturing.
IS 17
Synthetic dye and pigment manufacturing.
IS 18
Carbon black manufacturing.
IS 19
All other basic inorganic chemical manufacturing.
IS 20
Cyclic crude and intermediate manufacturing.
IS21
All other basic organic chemical manufacturing.
IS22
Plastics material and resin manufacturing.
IS23
Synthetic rubber manufacturing.
IS 24
Organic fiber manufacturing.
IS25
Pesticide, fertilizer, and other agricultural chemical manufacturing.
IS26
Pharmaceutical and medicine manufacturing.
IS27
Paint and coating manufacturing.
IS28
Adhesive manufacturing.
IS29
Soap, cleaning compound, and toilet preparation manufacturing.
IS 30
Printing ink manufacturing.
4-43
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Sector description
IS31
Explosives manufacturing.
IS32
Custom compounding of purchased resins.
IS33
Photographic film, paper, plate, and chemical manufacturing.
IS 34
All other chemical product and preparation manufacturing.
IS35
Plastics product manufacturing.
IS36
Rubber product manufacturing.
IS37
Non-metallic mineral product manufacturing (includes cement, clay, concrete, glass, gypsum,
lime, and other non-metallic mineral product manufacturing)
IS38
Primary metal manufacturing.
IS39
Fabricated metal product manufacturing.
IS40
Machinery manufacturing.
IS41
Computer and electronic product manufacturing.
IS42
Electrical equipment, appliance, and component manufacturing.
IS43
Transportation equipment manufacturing.
IS44
Furniture and related product manufacturing.
IS45
Miscellaneous manufacturing.
IS46
Wholesale and retail trade.
IS47
Services.
IS48
Other (requires additional information).
4.6.4.4 Industrial Function Category
Report the code that corresponds to the appropriate Industrial Function Category (FC)
for each particular combination of TPU and IS that you report (40 CFR 705.15(c)(3)). You must
use the codes in Table 4-16 for reporting under this data call. These codes, based on
Organization for Economic Cooperation and Development (OECD) standards, were required for
reporting of chemical substances designated by EPA as a high priority for risk evaluation for
2020 CDR reporting and were optional for the 2020 CDR for other chemical substances, and
were required for all chemicals in 2024 CDR; if you reported to 2020 and/or 2024 CDR, you may
be familiar with these codes. If your site reported this PFAS to 2020 or earlier CDR using other
codes, you will need to determine the appropriate 2020 CDR codes and report those in this
section. Because data reported using other codes was not reported as required by the PFAS
section 8(a)(7) rule, it is not considered duplicative. Descriptions for each FC and a crosswalk
between the OECD-based 2020 CDR codes and 2016 CDR codes are provided in Appendix D
(Table D-4). This crosswalk may be helpful if you are already familiar with the 2016 CDR codes
and can help you determine the correct 2020 CDR codes to use if you have previously reported
the PFAS using 2016 CDR codes. Function Category codes to be used for section 8(a)(7)
reporting are provided in Table 4-16.
If you select F999 (Other), you must provide a description of the function of the chemical
substance. The written description should be used to provide a description at a comparable
4-44
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
level of specificity as found with the current codes. It should not be used to add additional,
more specific detail. Do not include CBI in this text box.
Function codes are based on the intended physical or chemical characteristic for when a
chemical substance or mixture is consumed as a reactant; incorporated into a formulation,
mixture, reaction product, or article; repackaged; or used (e.g., as an abrasive, a catalyst, or an
elasticizer). However, the functional use categories for consumer or commercial categories
cover the life cycle and describe the specific function that a chemical provides when used in the
formulation of a product or article, or when used within an industrial process. While the
function of a chemical may be the same across its life cycle, certain functions may only be
appropriate for consideration in an industrial setting, while others may be relevant for a
consumer or commercial setting. For more information on reporting consumer and commercial
use data, see Section 4.6.5 below.
Table 4-16. Codes for Reporting Function Categories
Code
Category
F001
Abrasives
F002
Etching agent
F003
Adhesion/cohesion promoter
F004
Binder
F005
Flux agent
F006
Sealant (barrier)
F007
Absorbent
F008
Adsorbent
F009
Dehydrating agent (desiccant)
F010
Drier
F011
Humectant
F012
Soil amendments (fertilizers)
F013
Anti-adhesive/cohesive
F014
Dusting agent
F015
Bleaching agent
F016
Brightener
F017
Anti-scaling agent
F018
Corrosion inhibitor
F019
Dye
F020
Fixing agent (mordant)
F021
Hardener
F022
Filler
F023
Anti-static agent
F024
Softener and conditioner
4-45
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
F025
Swelling agent
F026
Tanning agents not otherwise specified
F027
Waterproofing agent
F028
Wrinkle resisting agent
F029
Flame retardant
F030
Fuel agents
F031
Fuel
F032
Heat transferring agent
F033
Hydraulic fluids
F034
Insulators
F035
Refrigerants
F036
Anti-freeze agent
F037
Intermediate
F038
Monomers
F039
Ion exchange agent
F040
Anti-slip agent
F041
Lubricating agent
F042
Deodorizer
F043
Fragrance
F044
Oxidizing agent
F045
Reducing agent
F046
Photosensitive agent
F047
Photosensitizers
F048
Semiconductor and photovoltaic agent
F049
UV stabilizer
F050
Opacifer
F051
Pigment
F052
Plasticizer
F053
Plating agent
F054
Catalyst
F055
Chain transfer agent
F056
Chemical reaction regulator
F057
Crystal growth modifiers (nucleating agents)
F058
Polymerization promoter
F059
Terminator/Blocker
F060
Processing aids, specific to petroleum production
F061
Antioxidant
4-46
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
F062
Chelating agent
F063
Defoamer
F064
pH regulating agent
F065
Processing aids not otherwise specified
F066
Energy Releasers (explosives, motive propellant)
F067
Foamant
F068
Propellants, non-motive (blowing agents)
F069
Cloud-point depressant
F070
Flocculating agent
F071
Flotation agent
F072
Solids separation (precipitating) agent, not otherwise specified
F073
Cleaning agent
F074
Diluent
F075
Solvent
F076
Surfactant (surface active agent)
F077
Emulsifier
F078
Thickening agent
F079
Viscosity modifiers
F080
Laboratory chemicals
F081
Dispersing agent
F082
Freeze-thaw additive
F083
Surface modifier
F084
Wetting agent (non-aqueous)
F085
Aerating and deaerating agents
F086
Explosion inhibitor
F087
Fire extinguishing agent
F088
Flavoring and nutrient
F089
Anti-redeposition agent
F090
Anti-stain agent
F091
Anti-streaking agent
F092
Conductive agent
F093
Incandescent agent
F094
Magnetic element
F095
Anti-condensation agent
F096
Coalescing agent
F097
Film former
F098
Demulsifier
4-47
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
F099
Stabilizing agent
F100
Alloys
F101
Density modifier
F102
Elasticizer
F103
Flow promoter
F104
Sizing agent
F105
Solubility enhancer
F106
Vapor pressure modifiers
F107
Embalming agent
F108
Heat stabilizer
F109
Preservative
F110
Anti-caking agent
Fill
Deflocculant
F112
Dust suppressant
F113
Impregnation agent
F114
Leaching agent
F115
Tracer
F116
X-ray absorber
F999
Other
4.6.4.5 Industrial Processing and Use - Percentage of Production Volume
Report the estimated percentage of total production volume of the PFAS associated with
each unique combination of industrial processing or use operation, sector, and function
category (TPU, IS, and FC) (see sections 4.6.4.2, 4.6.4.3, and 4.6.4.4). The percentage should be
accurate to the extent that it is known to or reasonably ascertainable by you. Round your
estimates to the nearest 10 percent of production volume (40 CFR 705.15(d)(4)). If you would
like to provide more specific percentages, please do so. Do not round a particular combination
that accounts for less than five percent of the total production volume to zero percent. In such
cases, you must report the percentage of production volume attributable to that combination
to the nearest one percent of production volume.
4-48
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
The total percentage of
production volumes associated with
the TPU, IS, and FC combinations
may add up to more than 100
percent, given that you are reporting
on distribution of a PFAS to sites in
your control as well as downstream
sites, some of which are not
immediate purchasers from your
original manufacturing site. Thus,
you may "double count" quantities
of the PFAS as you consider its use at
due to rounding.
Additionally, the total percentage of production volume may add up to less than 100
percent if, for example:
• You do not know or cannot reasonably ascertain information about how all of your
production volume is processed or used;
• More than 10 combinations of codes are applicable to your chemical substance;
• You export a portion of the production volume;
• A portion of the production volume is used for commercial, or consumer uses rather
than industrial uses; or
• Percentages round such that they do not sum to 100% (e.g., three use combinations that
each account for one-third of total use will be reported as 30% each, totaling 90%).
Table 4-17 provides examples of reporting industrial processing and use data.
Table 4-17. Examples of Reporting Industrial Processing and Use Information
Description
Reporting Requirement
Example Site Y manufactures 12,000 lb of Example PFAS
Y for processing for incorporation into a mixture. All of
the production is for use in industrial sector IS17
(Synthetic Dye and Pigment Manufacturing). Of the
production volume, 67% (8,000 lb) is used as an anti-
stain agent and 33% (4,000 lb) is used as a viscosity
modifier.
On line 3.A.1 of the Form, enter PF for type of process
or use, IS17 for industrial sector, F090 for FC, and 70%
for production volume. On line 3.A.2 of the form,
enter PF for type of process or use, IS17 for industrial
sector, F079 for FC, and 30% for production volume.
Example Site Z manufactures 50,000 lb of Example PFAS
Z for processing for incorporation into a mixture. All of
the production is for use under
On line 3.A.1 of the form, enter PF for type of process
or use, IS17 for industrial sector, F090 for FC, and
100% for production volume. On line 3.A.2
How to determine your percent production volume:
1. Determine the production volume that is attributable to each
unique combination of TPU, IS, and FC.
2. Determine your total production volume for the year.
a. Add together the volume domestically manufactured and
the volume imported.
b. DO NOT subtract the volume used on-site or the volume
exported.
3. Divide the volume determined in step 1 by the volume
determined in step 2 and multiply by 100.
multiple sites. The sum may also add to more than 100%
4-49
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
industrial sector IS17 (Synthetic Dye and Pigment
Manufacturing). Of the production volume, 97% (48,500
lb) is used as an anti-stain agent and 3% (1,500 lb) is
used as a viscosity modifier.
of the form, enter PF for type of process or use, IS17
for industrial sector, and F079 for FC. Because less
than 10% of the production volume is used as a
viscosity modifier, enter the percentage to the nearest
one percent, i.e., 3%, for production volume.
4.6.4.6 Number of Workers Reasonably Likely to be Exposed for each Industrial Process
and Use
For each unique combination of Type of Process or Use Operation, Industrial Sector, and
Function Category, estimate the total number of workers that are reasonably likely to be
exposed to the chemical substance at sites that process or use the chemical substance (40 CFR
705.15(g)(2)). Include workers at sites that are not under your control as well as those sites you
control. For each combination of TPU, sector, and function, report the code that corresponds to
the estimated range of the number of workers reasonably likely to be exposed. Table 4-18
shows the codes and worker ranges. See Section 4.6.3.3 for a discussion of "reasonably likely to
be exposed."
4.6.4.7 Maximum Duration of Exposure for Industrial Workers
For each unique combination of Type of Process or Use Operation, Industrial Sector, and
Function Category, estimate the maximum duration of exposure for workers that are
reasonably likely to be exposed to the chemical substance at sites that process or use the
chemical substance. Include workers at sites that are not under your control as well as those
sites you control.
If workers have different lengths of exposure (for example, due to shift schedules or
different job roles), consider two scenarios: the worker(s) who have the longest duration of
exposure on any day of the year (called maximum daily exposure), and the worker(s) who are
exposed on the highest number of days per year (called maximum annual exposure). For each
of these workers, report the maximum duration of exposure on any single day as well as the
number of days per year that the worker is reasonably likely to be exposed. For each activity,
consider the following questions:
1. What worker or group of workers is exposed for the longest amount of time on
any one day forthis combination of Type of Process or Use Operation,
Industrial Sector, and Function Category?
a. How long is that maximum amount of time that the worker or group of
workers is exposed for this TPU/IS/FC combination?
b. On how many days per year is this worker(s) exposed to the PFAS for this
TPU/IS/FC combination?
2. What worker or group of workers is exposed on the largest number of days
each year doing this activity?
4-50
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
a. How many days per year is that worker or group of workers exposed for
this TPU/IS/FC combination?
b. What is the longest amount of time that worker(s) is exposed for this
TPU/IS/FC combination?
Report maximum daily exposure to the nearest hour, except for workers exposed for
less than one hour. Report one hour for any worker exposed for less than one hour; do not
round to zero. If work shifts cross midnight, you may consider the work shift to be one day (e.g.,
a worker who is exposed on one shift from 10 PM until 6 AM the next day may be counted as
one day of exposure and 8 hours of daily exposure). Recall that in this section, you are reporting
exposure by activity. If a worker at your site may be exposed to the PFAS during multiple
activities, report for each activity considering that activity alone, and not any other activities.
Table 4-18. Example industrial worker exposure scenarios
Exposure Scenario
Exposure for worker(s) with
maximum daily exposure
Exposure for worker(s) with
maximum annual exposure
Example Site HH incorporates Example
PFAS HH into a metalworking fluid. Site
HH knows that workers at its customers'
facilities may work with the
metalworking fluid for an entire shift
and are reasonably likely to be exposed
to the PFAS during this activity, which
may occur on a daily basis. Site HH also
knows its customers operate on 4x10-
hour shift schedule, and therefore
exposed workers are likely to be
exposed for up to 10 hours per day, up
to 4 days per week, or 208 days per
year.
Report 10 hours per day as the
maximum duration per day for this
this combination of Type of Process
or Use Operation, Industrial Sector,
and Function Category. Report 208
days per year as the maximum
duration per year.
In this case, this activity is only
done by one group of workers, so
the workers with the maximum
daily exposure are also the
workers with the maximum
annual exposure.
Report 10 hours as the maximum
daily exposure and 208 days as
the maximum annual frequency.
Example Site II manufactures Example
PFAS II and processes the chemical on
site. The site knows that its processing
activity is reasonably expected to expose
workers for no more than 3 hours per
day and occurs on Monday and
Thursday every week. One group of
production workers performs the
activity on Mondays and a different
group of workers performs the activity
on Thursdays. One supervisor may also
be exposed for no more than one hour
during the activity. The same supervisor
oversees the activity every time it is
performed.
The workers with the most exposure
on any given day are the production
workers, who are exposed for up to
3 hours per day. Report 3 hours per
day for the workers with the
maximum daily exposure for this
combination of TPU, IS, and FC
codes. Report 52 days as the
maximum duration per year for
workers with the maximum daily
exposure for this this combination
of TPU, IS, and FC codes, because no
single production worker is exposed
more than one day per week, or 52
days per year.
The worker with the largest
number of days of exposure is the
supervisor, who may be exposed
twice per week, or 104 days per
year. The supervisor is not
exposed for more than one hour
per day during this activity, so
report 1 hour for the maximum
daily exposure for the worker
with maximum annual exposure.
Report 104 days per year for the
maximum annual frequency of
exposure for the worker with the
maximum daily exposure.
4-51
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Exposure Scenario
Exposure for worker(s) with
maximum daily exposure
Exposure for worker(s) with
maximum annual exposure
Example Site JJ imports a PFAS chemical
in an article. The PFAS chemical is part
of a non-stick coating on the inside of
equipment and workers are not
expected to have physical contact with
the internal non- stick surface.
Report N/A for this combination of
TPU, IS, and FC codes.
Report N/A for this combination
of TPU, IS, and FC codes.
4.6.5 Consumer and Commercial Use
For purposes of section 8(a)(7) reporting, a commercial use means the use of a chemical
substance or a mixture (including as part of an article) in a commercial enterprise providing
saleable goods or a service (40 CFR 705.3). A consumer use, on the other hand, means the use
of a chemical substance or a mixture (including as part of an article) when sold to or made
available to consumers for their use (40 CFR 705.3).
For each PFAS manufactured (including imported), report up to ten unique
combinations of the following data elements: the Product Category (PC) (described in Section
4.6.5.2), the Function Category (FC) (described in Section 4.6.5.3), whether the use is consumer
and/or commercial (described in Section 4.6.5.4), and whether the use is in products intended
for use by children (described in Section 4.6.5.5) (40 CFR 705.15(c)(7)). A combination of these
four data elements defines a potential exposure scenario for risk-screening and priority-setting
purposes. If more than ten unique combinations apply to a chemical substance, you need only
report the ten combinations for the chemical substance that cumulatively represent the largest
percentage of production volume, measured by weight (40 CFR 705.15(c)(4)). The reporting
tool will allow you to enter more than ten combinations if you choose to do so.
For each of these unique combinations, you are also required to report the maximum
concentration (described in Section 4.6.5.7), the percentage of production volume (described in
Section 4.6.5.6), and, for commercial uses, information about worker exposure (described in
Sections 4.6.5.8 and 4.6.5.9) (40 CFR 705.15(c)(8)).
You are required to report information that is known to or reasonably ascertainable by
you concerning the consumer and commercial end uses of each chemical substance
manufactured (including imported) at sites you control and at sites controlled by people to
whom you have either directly or indirectly (including through a broker/distributor, from a
customer, etc.) distributed the reportable PFAS (40 CFR 705.15(c)(4)).
4.6.5.1 Confidentiality of Consumer and Commercial Use Information
Most data elements in this section may not be claimed as confidential. You may not
claim the following consumer and commercial use data elements as confidential:
4-52
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
• product category
• function of the chemical in the consumer or commercial product
• whether the chemical is used in commercial or consumer products
• whether the chemical predictably is used in children's products
In this section, you may only assert a claim of confidentiality for the maximum
concentration of the chemical in any product. Checking the CBI box associated with this data
element automatically triggers substantiation questions. If you do not check the CBI box for any
information element, then that information is not claimed as CBI and may be made public
without further notice to you. See Table 4-30 for substantiation questions to be answered
when asserting CBI claims for processing and use information.
4.6.5.2 Pro duct Category
You must designate up to ten product categories which correspond to the actual use of
the chemical substance by reporting the codes which correspond to the appropriate product
categories (40 CFR 705.15 (c)(4)). If more than ten codes apply, you need report only the ten
codes for the chemical substance that cumulatively represent the largest percentage of
production volume, measured by weight (40 CFR 705.15(c)(4)). The reporting tool will allow you
to enter more than ten categories if you choose to do so.
You must use the codes in Table 4-19 for reporting under this data call. These codes,
based on OECD standards, were required for reporting of chemical substances designated by
EPA as a high priority for risk evaluation for 2020 CDR reporting and were optional for the 2020
CDR for other chemical substances, and were required for all chemicals in 2024 CDR; if you
reported to 2020 and/or 2024 CDR, you may be familiar with these codes. If your site reported
this PFAS to 2020 or earlier CDR using other codes, you will need to determine the appropriate
2020 CDR codes and report those in this section. Because data reported using other codes was
not reported as required by the PFAS section 8(a)(7) rule, it is not considered duplicative.
Descriptions for each product category code and a crosswalk between the OECD-based 2020
CDR codes and 2016 CDR codes are provided in Appendix D (Table D-3).
Product Category codes are provided in Table 4-19.
If you select CC980 (Other), you must provide a description of the product category. The
written description should be used to provide a description at a comparable level of specificity
as found with the current codes. It should not be used to add additional, more specific detail.
Do not enter CBI in this text box.
Table 4-19. Product Category Codes
Code
Category
Chemical Substances in Furnishing, Cleaning, Treatment Care Products
CC101
Construction and building materials covering large surface areas including stone, plaster, cement,
glass and ceramic articles; fabrics, textiles, and apparel
4-53
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
CC102
Furniture & furnishings including plastic articles (soft); leather articles
CC103
Furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or
rubber articles
CC104
Leather conditioner
CC105
Leather tanning, dye, finishing, impregnation and care products
CC106
Textile (fabric) dyes
CC107
Textile finishing and impregnating/surface treatment products
CC108
All-purpose foam spray cleaner
CC109
All-purpose liquid cleaner/polish
CC110
All-purpose liquid spray cleaner
CC111
All-purpose waxes and polishes
CC112
Appliance cleaners
CC113
Drain and toilet cleaners (liquid)
CC114
Powder cleaners (floors)
CC115
Powder cleaners (porcelain)
CC116
Dishwashing detergent (liquid/gel)
CC117
Dishwashing detergent (unit dose/granule)
CC118
Dishwashing detergent liquid (hand-wash)
CC119
Dry cleaning and associated products
CC120
Fabric enhancers
CC121
Laundry detergent (unit-dose/granule)
CC122
Laundry detergent (liquid)
CC123
Stain removers
CC124
Ion exchangers
CC125
Liquid water treatment products
CC126
Solid/Powder water treatment products
CC127
Liquid body soap
CC128
Liquid hand soap
CC129
Solid bar soap
CC130
Air fresheners for motor vehicles
CC131
Continuous action air fresheners
CC132
Instant action air fresheners
CC133
Anti-static spray
4-54
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
CC134
Apparel finishing, and impregnating/surface treatment products
CC135
Insect repellent treatment
CC136
Pre-market waxes, stains, and polishes applied to footwear
CC137
Post-market waxes, and polishes applied to footwear (shoe polish)
CC138
Waterproofing and water-resistant sprays
Chemical Substances in Construction, Paint, Electrical, and Metal Products
CC201
Fillers and putties
CC202
Hot-melt adhesives
CC203
One-component caulks
CC204
Solder
CC205
Single-component glues and adhesives
CC206
Two-component caulks
CC207
Two-component glues and adhesives
CC208
Adhesive/Caulk removers
CC209
Aerosol spray paints
CC210
Lacquers, stains, varnishes and floor finishes
CC211
Paint strippers/removers
CC212
Powder coatings
CC213
Radiation curable coatings
CC214
Solvent-based paint
CC215
Thinners
CC216
Water-based paint
CC217
Construction and building materials covering large surface areas, including wood articles
CC218
Construction and building materials covering large surface areas, including paper articles; metal
articles; stone, plaster, cement, glass and ceramic articles
CC219
Machinery, mechanical appliances, electrical/electronic articles
CC220
Other machinery, mechanical appliances, electronic/electronic articles
CC221
Construction and building materials covering large surface areas, including metal articles
CC222
Electrical batteries and accumulators
Chemical Substances in Packaging, Paper, Plastic, Tovs, Hobbv Products
CC990
Non-TSCA use
CC301
Packaging (excluding food packaging), including paper articles
CC302
Other articles with routine direct contact during normal use, including paper articles
4-55
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
CC303
Packaging (excluding food packaging), including rubber articles; plastic articles (hard); plastic
articles (soft)
CC304
Other articles with routine direct contact during normal use including rubber articles; plastic articles
(hard)
CC305
Toys intended for children's use (and child dedicated articles), including fabrics, textiles, and
apparel; or plastic articles (hard)
CC306
Adhesives applied at elevated temperatures
CC307
Cement/concrete
CC308
Crafting glue
CC309
Crafting paint (applied to body)
CC310
Crafting paint (applied to craft)
CC311
Fixatives and finishing spray coatings
CC312
Modelling clay
CC313
Correction fluid/tape
CC314
Inks in writing equipment (liquid)
CC315
Inks used for stamps
CC316
Toner/Printer cartridge
CC317
Liquid photographic processing solutions
Chemical Substances in Automotive, Fuel, Agriculture, Outdoor Use Products
CC401
Exterior car washes and soaps
CC402
Exterior car waxes, polishes, and coatings
CC403
Interior car care
CC404
Touch up auto paint
CC405
Degreasers
CC406
Liquid lubricants and greases
CC407
Paste lubricants and greases
CC408
Spray lubricants and greases
CC409
Anti-freeze liquids
CC410
De-icing liquids
CC411
De-icing solids
CC412
Lock de-icers/releasers
CC413
Cooking and heating fuels
CC414
Fuel additives
CC415
Vehicular or appliance fuels
4-56
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
CC416
Explosive materials
CC417
Agricultural non-pesticidal products
CC418
Lawn and garden care products
Chemical Substances in Products not Described bv Other Codes
CC980
Other (specify)
CC990
Non-TSCA use
4.6.5.3 Functional Use for Consumer and/or Commercial Products
For each consumer and/or commercial product category reported, report the code(s)
that designates the function category(ies) that best represents the specific manner in which the
chemical substance is used (40 CFR 705.15(c)(5)). You must use the codes in Table 4-16 for
reporting under this data call. These codes are the same as those used to report the
appropriate Function Category for industrial processing and use. A particular function category
may need to be reported more than once, to the extent that more than one consumer or
commercial product category applies to a given function category.
For the special situation where the PFAS has multiple functions within the same product,
you can report in one of two ways:
If one function is predominant, simply report the primary function; or
If all functions represent a substantial portion of the product, report each on a separate
line and either estimate the portions individually or bifurcate the percent Production Volume
(%PV) equally across the functions (so as not to double or triple-count the %PV for the one
product).
If none of the listed function categories accurately describes a use of a chemical
substance, the category "Other" may be used, and must include a description of the use. The
written description should be used to provide a description at a comparable level of specificity
as found with the current codes. It should not be used to add additional, more specific detail.
Do not enter CBI in this text box.
4.6.5.4 Consumer and/or Commercial Use
For each product category reported, report whether the use is a consumer use or a
commercial use (40 CFR 705.15(c)(4)). If the product has both consumer and commercial uses,
report both.
4-57
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.6.5.5 Use in Product(s) Intended for Use by Children
Within each consumer product category reported, you must determine whether any
amount of each reportable chemical substance manufactured (including imported) by you is
present in or on any consumer product(s) intended for use by children aged 14 or younger,
regardless of the concentration of the chemical substance remaining in or on the product (40
CFR 705.15(c)(7)). If you determine that your chemical substance or mixture is used in a
consumer product intended for use by children, report "Yes" in the "Used in Product(s)
Intended for Children" field. If you determine that your chemical substance or mixture is not
used in a consumer product intended for use by children, report "No."
EPA defines "intended for use by children" to mean the chemical substance or mixture is
used in or on a product that is specifically intended for use by children aged 14 or younger (40
CFR 705.3). Your chemical substance or mixture is intended for use by children if you answer
"yes" to at least one of the following questions about the product into which your chemical
substance or mixture is incorporated:
• Is the product commonly recognized (i.e., by a reasonable person) as being intended for
use by children aged 14 or younger?
• Does the manufacturer of the product state through product labeling or other written
materials that the product is intended or will be used by children aged 14 or younger?
o Is the advertising, promotion, or marketing of the product aimed at children aged 14
or younger?
Table 4-20 illustrates some (non-exhaustive) examples of "Use in Product(s) Intended for
Use by Children." For example, certain products (e.g., crayons, coloring books, diapers, and toy
cars) are typically used by children aged 14 or younger. If you determine that your chemical
substance or mixture is used in crayons, for example, you would report "Yes" for children's use
for CC305.
Certain products, such as household cleaning products, automotive supplies, and
lubricants, typically are not intended to be used by children aged 14 or younger. As such, if you
determine that your chemical substance or mixture is used in automotive care products and
lubricants, for example, you would report "no" for children's use for categories CC401 and
CC402.
Table 4-20. Examples of Products Intended for Use by Children
Code
Category
Examples
Chemical Substances in Furnishings, Cleanings, Treatment Care Products
CC102
Furniture & furnishings including Plastic articles (soft);
Leather articles
Child's car seat, children's sheets
4-58
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
Examples
CC103
Furniture & furnishings including Stone, plaster, cement,
glass and ceramic articles; Metal articles; or Rubber articles
Baby cribs, changing tables
CC106
Textile (fabric) dyes
Children's clothing
CC107
Textile finishing and impregnating/surface treatment
products
Children's clothing, children's
sheets, child's car seat
CC127
Liquid body soap
Baby shampoo, children's bubble
bath
Chemical Substances in Construction, Paint, Electrical and Metal Products
CC219
Machinery, mechanical appliances, electrical/electronic
articles
Electronic games, remote control
cars
CC222
Electrical batteries and accumulators
Batteries used in toys
Chemical Substances in Packaging, Paper, Plastic, Hobbv Products
CC302
Other articles with routine direct contact during normal use,
including paper articles
Diapers, baby wipes, coloring
books
CC305
Toys intended for children's use (and child dedicated
articles), including Fabrics, textiles, and apparel; or Plastic
articles (hard)
Pacifiers, toy trucks, dolls, toy
cars, wagons, action figures,
balls, swing sets, slides, skates,
baseball gloves, kid's rake
CC306
Adhesives applied at elevated temperatures
Craft glue for a hot glue gun
CC308
Crafting glue
Craft glue
CC309
Crafting Paint (applied to body)
Chemicals used to add color to
body paint, finger paints
4.6.5.6 Consumer and Commercial Use - Percentage of Production Volume
Report the estimated percentage of total production volume of the reportable chemical
substance associated with each consumer and commercial product category (see Section
4.6.5.2). The percentage should be accurate to the extent that it is known to or reasonably
ascertainable by you. Round your estimates to the nearest 10 percent of production volume (40
CFR 705.15(d)(5)). If you would like to provide more specific percentages, please do so. Do not
round a particular combination that accounts for less than five percent of the total production
volume to zero percent. In such cases, you must report the percentage of production volume
attributable to that combination to the nearest one percent of production volume.
4-59
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
The total percentage of production volumes associated with the product codes may add
up to more than 100 percent, given
that you are reporting on distribution
of a chemical substance to sites in
your control as well as downstream
sites, some of which are not
immediate purchasers from your
original manufacturing site. Thus, you
may "double count" quantities of the
PFAS as you consider its use at
multiple sites. The sum may also add
to more than 100% due to rounding.
Additionally, the total percentage of production volume may add up to less than 100
percent if, for example:
• You do not know or cannot reasonably ascertain information about how all of your
production volume is processed or used;
• More than 10 combinations of codes are applicable to your chemical substance;
• You export a portion of the production volume;
• A portion of the production volume is used for industrial uses rather than
commercial/consumer uses; or
• Percentages round such that they do not sum to 100% (e.g., three use combinations that
each account for one-third of total use will be reported as 30% each, totaling 90%).
Table 4-21 provides examples of reporting consumer and commercial use information.
Table 4-21. Examples of Reporting Consumer and Commercial Use Information
Description
Reporting Requirement
Example Site AB manufactures 12,000 lb of Example PFAS AB
for processing for incorporation into a mixture. All of the
production is for use in commercial products. Of the
production volume, 67% (8,000 lb) is used in waterproofing
sprays for apparel and 33% (4,000 lb) is used in paper
packaging (for non-food use).
On one line, enter CC138 for PC and 70% for
production volume. On another line, enter CC301
for PC and 30% for production volume.
Example Site CD manufactures 50,000 lb of Example PFAS CD
for processing for incorporation into a mixture. All of the
production is for use in commercial products. Of the
production volume, 97% (48,500 lb) is used in waterproofing
sprays for apparel and 3% (1,500 lb) is used in paper packaging
(for non-food use).
On one line, enter CC138 for PC and 100% for
production volume. On another line, enter CC301
for PC. Because less than 10% of the production
volume is used in paper packaging, enter the
percentage to the nearest one percent, i.e., 3%,
for production volume.
How to determine your percent production volume:
1. Determine the production volume that is attributable to each
consumer or commercial product category.
2. Determine your total production volume for the year.
a. Add together the volume domestically manufactured and
the volume imported.
b. DO NOT subtract the volume used on-site or the volume
exported.
3. Divide the volume determined in step 1 by the volume
determined in step 2 and multiply by 100.
4-60
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.6.5.7 Maximum Concentration Code
When the chemical substance you manufacture (including import) is used in commercial
or consumer products, you are required to report the estimated typical maximum
concentration (measured by weight) of each chemical substance in each commercial or
consumer product category reported (40 CFR 715.15(c)(8)). For each chemical substance used
in a reported commercial or consumer product, report the code that corresponds to the
appropriate concentration range. Table 4-22 shows the codes and concentration ranges.
Table 4-22. Codes for Reporting Maximum Concentration
Code
Concentration Range (weight percent)
Ml
Less than 1% by weight
M2
At least 1 but less than 30% by weight
M3
At least 30 but less than 60% by weight
M4
At least 60 but less than 90% by weight
M5
At least 90% by weight
4.6.5.8 Number of Workers Reasonably Ukely to be Exposed for each Commercial Use
Report the total number of commercial workers, including those at sites not under your
control that are reasonably likely to be exposed while using the reportable chemical substance,
with respect to each commercial use (40 CFR 705.15(g)(5)). For each combination of
commercial Product Category and Function Category reported (Section 4.6), report the code
which corresponds to the appropriate range of commercial workers reasonably likely to be
exposed. Table 4-12 shows the codes for numbers of workers. See Section 4.6.3.3 for a
discussion of "reasonably likely to be exposed."
4.6.5.9 Maximum Duration of Exposure for Commercial Workers
For each unique combination of Product Category and Function Category, estimate the
maximum duration of exposure for workers that are reasonably likely to be exposed to the
chemical substance at sites that process or use the chemical substance. Include workers at sites
that are not under your control as well as those sites you control.
If workers have different lengths of exposure (for example, due to shift schedules or
different job roles), consider two scenarios: the worker(s) who have the longest duration of
exposure on any day of the year (called maximum daily exposure), and the worker(s) who are
exposed on the highest number of days per year (called maximum annual exposure). For each
of these workers, report the maximum duration of exposure on any single day as well as the
number of days per year that the worker is reasonably likely to be exposed. For each activity,
consider the following questions:
4-61
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
1. What worker or group of workers is exposed for the longest amount of time on
any one day for this combination of Product Category and Function Category?
a. How long is that maximum amount of time that the worker or group of
workers is exposed for this PC/FC combination?
b. On how many days per year is this worker(s) exposed to the PFAS for this
PC/FC combination?
2. What worker or group of workers is exposed on the largest number of days
each year doing this activity?
a. How many days per year is that worker or group of workers exposed for
this PC/FC combination?
b. What is the longest amount of time that worker(s) is exposed for this PC/FC
combination?
Report maximum daily exposure to the nearest hour, except for workers exposed for
less than one hour. Report one hour for any worker exposed for less than one hour; do not
round to zero. If work shifts cross midnight, you may consider the work shift to be one day (e.g.,
a worker who is exposed on one shift from 10 PM until 6 AM the next day may be counted as
one day of exposure and 8 hours of daily exposure). Recall that in this section, you are reporting
exposure by activity. If a worker may be exposed to the PFAS during multiple activities, report
for each activity considering that activity alone, and not any other activities.
4-62
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Table 4-23. Example commercial worker exposure scenarios
Exposure Scenario
Exposure for worker(s) with
maximum daily exposure
Exposure for worker(s) with
maximum annual exposure
Example Company KK incorporates
Example PFAS KK into a lubricating
wax. Many of its customers are
sporting good rental and repair
shops, including ski shops and bike
shops. Company KK knows that
workers are likely exposed to the
PFAS when applying lubricating
waxes to equipment, an activity that
may be done intermittently
throughout a shift. Company KK
knows from discussions with its
customers that ski shops use the
wax daily during the ski season, and
that workers work up to 12 hour
shifts up to 5 days per week during
this 20-week season; the shops are
closed the rest of the year. Bike
shops using these products operate
with shifts no longer than 10 hours
long, up to 5 days per week year
round.
The ski shop workers in this scenario
have the longest maximum
exposure on any given day and
should be considered the workers
with the maximum daily exposure.
The ski shop workers work up to 12
hours at a time.
Although exposure is intermittent,
these workers may be exposed
throughout the 12 hour shift.
Company KK reports 12 hours as the
maximum daily exposure. The ski
shop workers work up to 100 days
per year, so Company KK reports
100 days per year as the maximum
annual exposure for the workers
with the maximum daily exposure.
The bike shop workers in this
scenario are exposed for the most
days per year and should be
considered the workers with the
maximum annual exposure. Bike
shop workers work up to 10 hours at
a time. Although exposure is
intermittent, these workers may be
exposed throughout the 10 hour
shift. Company KK reports 10 hours
as the maximum daily exposure for
the workers with maximum annual
exposure. The bike shop workers
work up to 260 days per year, so
Company KK reports 260 days per
year as the maximum annual
exposure.
Example Company LL uses PFAS LL
as a stain-resistant coating for
carpets sold to commercial
customers. Company LL knows from
news reports that PFAS from coated
carpets can be released into indoor
air and dust over time, resulting in
worker exposure.
Company LL assumes that its
commercial customers operate with
8 hours shifts and that workers
work five days per week, 52 weeks
per year.
Example Company LL estimates that
workers in commercial customers
using its carpets are exposed for
eight hours per day, five days per
week. Example Company LL reports
8 hours as the maximum daily
exposure and 260 days as the
maximum annual exposure for
workers with the maximum daily
exposure.
In this case, this Product
Category/Function Category for
Example PFAS LL is only done by one
group of workers, so the workers
with the maximum daily exposure
are also the workers with the
maximum annual exposure.
Company LL reports 8 hours as the
maximum daily exposure and 260
days as the maximum annual
exposure for workers with the
maximum annual exposure.
Example Site MM produces a PFAS-
coated part used in commercial
machines. The PFAS is not expected
to produce any emissions or migrate
from the coating under normal
conditions of use.
Site MM reports 0 hours per day
and 0 days per year, as workers are
not expected to be exposed for any
amount of time.
Site MM reports 0 hours per day and
0 days per year, as workers are not
expected to be exposed for any
amount of time.
4-63
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.6.6 All existing information concerning the environmental and health effects of such
substance or mixture
In this section, report all information concerning the environmental and health effects of
the substance or mixture that is known to or reasonably ascertainable by you. The scope of "all
existing information concerning environmental and health effects" is information in the
submitter's possession or control (see Appendix A-l)
You would not necessarily be searching all information in the public realm but would be
submitting information in your possession or control, or other information for which you are
responsible. This includes any data or other information in files maintained by your site's
employees, or the employees of a subsidiary or partnership which is associated with research
and development, test marketing or commercial marketing of the PFAS. You are not required to
search open scientific literature to find relevant information on a PFAS that was previously not
in your possession or control for the purpose of this rule.
This information must be submitted for each PFAS, but need not be submitted for each
year it was manufactured (i.e., the application directs submitters to provide this information
one time). This information includes but is not limited to:
• Toxicity information (e.g., in silico, in vitro, animal test results, human data); and
• Other data relevant to environmental and health effects including range-finding studies,
preliminary studies, OSHA medical screening or surveillance standards reports, adverse
effects reports.
4.6.6.1 Confidentiality of Environmental and Health Effects Information
Information reported in this section of the PFAS data reporting form can be claimed as
confidential, but reporters should note that TSCA section 14(b) places significant limitations on
confidentiality protections for information from health and safety studies. CBI claims for
environmental and health effects are only valid if they would disclose certain information
related to a company's process or operations used in the manufacturing of the chemical. For all
of the data elements in this section, upfront substantiation of the claim is required. For any
environmental or health effects information being claimed as CBI, you must also submit a
sanitized version (omitting only information that is claimed as confidential and appropriately
substantiated) of the study report or other attachment for public release.
Check the appropriate CBI box in this block and complete the substantiation questions to
assert a confidentiality claim for the associated information being submitted. Checking the CBI
box automatically triggers the substantiation questions to appear later in the CBI Substantiation
portion of the form. See Table 4-30 for general substantiation and Table 4-31 for substantiation
questions related to chemical identity (though note that chemical identity is always part of a
health and safety study). Further, if you fail to substantiate your CBI claims and to provide a
sanitized version of the report or attachment in accordance with the statute and applicable
rules, EPA may make the information available to the public without further notice to you.
4-64
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
For additional information about how to answer substantiation questions, visit
www.epa.gov/tsca-cbi on the EPA website. Redactions must be as sparing as possible. It is your
responsibility to ensure that any sanitized reports are thoroughly sanitized. EPA may publicly
release sanitized reports as provided by you. It is your responsibility to ensure you have fully
sanitized the report and that any changes or redactions cannot be reversed in the submitted
sanitized version.
4.6.6.2 OECD Harmonized Environmental and Health Effects Template (attachment)
Upload all known or reasonably ascertainable information concerning the
environmental and health effects of the substance or mixture, using OECD Harmonized
Templates (OHTs) if available for the endpoint being reported on. OHTs are available from the
OECD website: https://www.oecd.ora/ehs/templates/harmonised-templates.htm. This can be
accomplished by using the freely available IUCLID6 software (https://iuclid6.echa.europa.euA.
exporting the dossier in the OHT working context, and uploading via this rule's reporting tool.
OHTs are not required for published study reports. (89 FR 72340).
As of this writing, EPA uses IUCLID6 v6.27.2; submitters using future IUCLID6 v7 can
export their dossier via the "Export to previous major version" function described in the IUCLID
Manual
(https://iuclid6.echa.europa.eu/documents/1387205/1809908/iuclid functionalities html en.pdf
/9d01 cb53-902d-dbb6-fb00-fal41688c395?t=l667168830907). Submitters using future
versions IUCLID6 v8 and higher (such as IUCLID7) should consult with EPA before submitting
their data to confirm the current data format acceptance standards. EPA can accept any
dossiers generated using an earlier version of IUCLID6. You may already have data in this format
if the company has submitted the studies under the European Union's Registration, Evaluation,
Authorization and Restriction of Chemicals (REACH) regulation.
The reporting software will guide you through the process of uploading attachment(s).
4.6.6.3 Study Report (attachment)
Upload as attachment(s) any relevant study report(s). You are required to provide any
test data on the health and environmental effects of the PFAS in your possession or control,
and a description of any other health and environmental effects data on the substance known
to or reasonably ascertainable by you. Data in the possession or control of either a parent
company or an affiliated subsidiary located outside the U.S. are considered by the Agency to be
data that should be known to or reasonably ascertainable by a submitter.
Data must be submitted in English. Standard literature citations may be submitted for
data in the open scientific literature. Complete test data (not summaries) must be submitted if
they do not appear in the open literature. Incomplete reports (e.g., from ongoing studies) are
exempt from full reporting. However, you must describe the nature and objective of any
incomplete study, report, or test, the name and address of any laboratory developing the data;
4-65
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
progress to date; type of data collected; significant preliminary results; and an anticipated
completion date. If significant preliminary results or final results are obtained prior to the
submission deadline or any other additional information significant to the review of the notice
becomes available to you, you must submit this information. This includes reports from studies
not conducted by your company, such as studies commissioned by your company. The reporting
software will guide you through the process of uploading attachment(s). You may consider
developing and voluntarily submitting a robust study summary along with the record as EPA is
interested in the potential utility of this information to reduce the future burden of reporting,
but this may not be submitted in lieu of a full study report.
4.6.6.4 Supporting Information (attachment)
Upload as attachments any relevant supporting information. This section is intended for
you to provide any supporting information related to the study reports uploaded in the
previous section. Other data not related to the uploaded study reports will be uploaded in the
"Other Data Relevant to Environmental or Health Effects" section (i.e., section 4.9.6 below). The
reporting software will guide you through the process of uploading attachment(s).
4.6.6.5 Analytical/Test Methods
Use the text entry field to describe any and all known analytical or test methods for the
PFAS substance. If the method is an EPA method or is substantially similar to an EPA method,
you may state which EPA method is the basis of the test method used and clearly describe all
modifications. If the method is not an EPA method or substantially similar to an EPA method,
describe all steps of the method in as much detail as possible. Standard literature citations may
be submitted for test methods described in the open scientific literature. Complete method
descriptions (not summaries) must be submitted if they do not appear in the open literature.
4.6.6.6 Other Data Relevant to Environmental or Health Effects
Upload as attachments any other data relevant to environmental or health effects not
published in a study report. Such information may include, but is not limited to, material safety
data sheets (SDS), information on physical/chemical properties, preliminary studies, range-
finding studies, OSHA medical screening or surveillance standards reports, adverse effects
reports, anonymized or aggregated informal test results in workers, underlying environmental
monitoring data, blood levels, or inhalation studies.
4.7 Streamlined Form: PFAS in Imported Articles
If you have imported PFAS as part of an imported article, then you have the option to
submit information to EPA using this streamlined form (see 40 CFR 705.18). See Section 2.2.1
for discussion on determining whether you have imported a PFAS-containing article and qualify
to use the Imported Articles streamlined form.
4-66
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
This streamlined form does not require all information required for the Standard Form;
when you select "PFAS in Imported Articles" in the section 8(a)(7) reporting tool, the program
will show only fields required for this streamlined reporting. Only certain fields of the Standard
Form are required for the streamlined article importing. Further, the article import form allows
production volume to reported as the total weight or quantity of the imported articles, rather
than weight of the PFAS.
4.7.1 Import Information
4.7.1.1 Import Production Volume of Imported Articles
Report the volume of the imported articles containing PFAS imported by your site.
Report the quantity to at least two significant figures; it should be accurate to the extent known
to or reasonably ascertainable by you. Production volumes should be reported in numeric
format, without commas (e.g., 6352000). Unlike the Standard Form and R&D PFAS streamlined
form, you should report the volume of the articles imported, rather than attempting to
calculate the volume of the PFAS contained within the articles. You may choose to report the
total weight of the PFAS-containing articles (e.g., in tons or pounds) or the quantity of the
article imported (e.g., the number of vehicles).
4.7.1.2 Unit of Measurement
You must specify the unit of measurement for the reported production volume. Select
quantity of imported articles, pounds (lb), tons, or other. If you select other, enter the
description of the unit of measurement in the text box. You may select "other" if you have a
complex article (e.g., automobile) with sub-articles containing PFAS, and you wish to clarify
whether the quantity is referring to the larger article (i.e., automobile) or the smaller sub-
articles (e.g., carpets and car seats).
4.7.1.3 For Imported Chemical Substances, Is the Chemical Never Physically at Site?
Report whether or not your imported PFAS is physically at the reporting site. Report one
of the following choices:
~ Yes, the imported PFAS is never physically at the reporting site (e.g., if you ship
the chemical substance from a foreign country directly to another location
such as a warehouse, a processing or use site, or a customer's site).
~ No, the imported PFAS is physically present at the reporting site.
~ NKRA, it is not known to or reasonably ascertainable by you whether the
imported PFAS is physically present at the reporting site.
4-67
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
4.7.2 Industrial Processing and Use
For purposes of section 8(a)(7) reporting, an industrial use means use at a site at which
one or more chemical substances or mixtures are manufactured (including imported) or
processed (40 CFR 705.3).
For each PFAS manufactured (including imported), report up to ten unique
combinations of the following data elements: the Type of Process or Use Operation (TPU)
(described in Section 4.7.2.2), the Industrial Sector (IS) (described in Section 4.7.2.3), and the
Function Category (FC) (described in Section 4.7.2.4) (40 CFR 705.18(3)). A combination of these
three data elements defines a potential exposure scenario for risk-screening and priority-
setting purposes. If more than ten unique combinations apply to a chemical substance, you
need only report the ten combinations for the chemical substance that cumulatively represent
the largest percentage of production volume, measured by weight. The reporting tool will allow
you to enter more than ten combinations if you choose to do so.
You are required to report information that is known to or reasonably ascertainable by
you concerning the industrial uses of the PFAS manufactured (including imported) at sites you
control and at sites controlled by people to whom you have either directly or indirectly
(including through a broker/distributor, from a customer, etc.) distributed the reportable
chemical substance (40 CFR 705.15(c)(1)).
4.7.2.1 Confidentiality of Processing and Use Information
These data elements are a general description of how the chemical is used or processed
and cannot be claimed as confidential:
• type of process or use
• industrial sector
• function code.
4.7.2.2 Type of Process or Use Operation
To the extent that it is known to or reasonably ascertainable by you, report the code
which corresponds to the appropriate Type of Processing or Use Operation (TPU) for the
particular combination of IS and FC codes. Table 4-24 shows the codes and TPUs. Note that if a
chemical substance is fully reacted (i.e., reporting "PC" for the processing code), then the
chemical substance is wholly consumed and further processing and use information for that
chemical substance will not exist. In such a situation, there is no further downstream processing
and use information to be reported for that particular type of processing or use operation
under 40 CFR 705.18(a)(3)(i). A processing or use code may be reported more than once if more
than one IS and/or FC code applies to the same processing or use operation. Definitions for
each code are provided in Appendix D, which may assist you in determining which code to
report.
4-68
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Table 4-24. Codes for Reporting Types of Industrial Processing or Use Operations
Designation
Operation
PC
Processing as a reactant.
PF
Processing—incorporation into formulation, mixture, or reaction product.
PA
Processing—incorporation into article.
PK
Processing—repackaging.
U
Use—non-incorporative activities.
4.7.2.3 Industrial Sectors
Report the code that corresponds to the appropriate Industrial Sector (IS) for all sites
that receive a reportable PFAS from you either directly or indirectly (including through a
broker/distributor, from a customer of yours, etc.) and that process and use the PFAS to the
extent that this information is known to or reasonably ascertainable by you (40 CFR
705.18(a)(3)(ii)). Table 4-25 shows the codes and sectors. Because an industrial sector may
apply to more than one processing and use scenario for a chemical substance, the same IS code
may be reported with different combinations of FC and TPU codes. A list identifying the
correspondence between NAICS codes and IS codes is provided in Appendix D (Table D-2).
When you chose the IS "Other," you also need to provide a written description of the
use of the chemical substance. The written description should be used to provide a description
at a comparable level of specificity as found with the current codes. It should not be used to
add additional, more specific detail. Your description may include the NAICS code. If you select
the IS "Other," a text box will appear for you to enter the description. Do not include CBI in this
text box.
Table 4-25. Codes for Reporting Industrial Sectors
Code
Sector description
IS1
Agriculture, forestry, fishing, and hunting.
IS2
Oil and gas drilling, extraction, and support activities.
IS3
Mining (except oil and gas) and support activities.
IS4
Utilities.
IS5
Construction.
IS6
Food, beverage, and tobacco product manufacturing.
IS7
Textiles, apparel, and leather manufacturing.
IS8
Wood product manufacturing.
IS9
Paper manufacturing.
IS 10
Printing and related support activities.
IS 11
Petroleum refineries.
IS 12
Asphalt paving, roofing, and coating materials manufacturing.
IS 13
Petroleum lubricating oil and grease manufacturing.
4-69
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Sector description
IS 14
All other petroleum and coal products manufacturing.
IS 15
Petrochemical manufacturing.
IS 16
Industrial gas manufacturing.
IS 17
Synthetic dye and pigment manufacturing.
IS 18
Carbon black manufacturing.
IS 19
All other basic inorganic chemical manufacturing.
IS 20
Cyclic crude and intermediate manufacturing.
IS21
All other basic organic chemical manufacturing.
IS22
Plastics material and resin manufacturing.
IS23
Synthetic rubber manufacturing.
IS 24
Organic fiber manufacturing.
IS25
Pesticide, fertilizer, and other agricultural chemical manufacturing.
IS26
Pharmaceutical and medicine manufacturing.
IS27
Paint and coating manufacturing.
IS28
Adhesive manufacturing.
IS29
Soap, cleaning compound, and toilet preparation manufacturing.
IS 30
Printing ink manufacturing.
IS31
Explosives manufacturing.
IS32
Custom compounding of purchased resins.
IS33
Photographic film, paper, plate, and chemical manufacturing.
IS 34
All other chemical product and preparation manufacturing.
IS35
Plastics product manufacturing.
IS36
Rubber product manufacturing.
IS37
Non-metallic mineral product manufacturing (includes cement, clay, concrete, glass, gypsum,
lime, and other non-metallic mineral product manufacturing)
IS38
Primary metal manufacturing.
IS39
Fabricated metal product manufacturing.
IS40
Machinery manufacturing.
IS41
Computer and electronic product manufacturing.
IS42
Electrical equipment, appliance, and component manufacturing.
IS43
Transportation equipment manufacturing.
IS44
Furniture and related product manufacturing.
IS45
Miscellaneous manufacturing.
IS46
Wholesale and retail trade.
IS47
Services.
IS48
Other (requires additional information).
4.7.2.4 Industrial Function Category
Report the code that corresponds to the appropriate Industrial Function Category (FC)
for each particular combination of TPU and IS that you report (40 CFR 705.18(a)(3)(iii)). You
must use the codes in Table 4-26 for reporting under this data call. These codes, based on
4-70
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Organisation for Economic Cooperation and Development (OECD) standards, were required for
reporting of chemical substances designated by EPA as a high priority for risk evaluation for
2020 CDR reporting and were optional for the 2020 CDR for other chemical substances, and
were required for all chemicals in 2024 CDR; if you reported to 2020 and/or 2024 CDR, you may
be familiar with these codes. If your site reported this PFAS to 2020 or earlier CDR using other
codes, you will need to determine the appropriate 2020 CDR codes and report those in this
section. Because data reported using other codes was not reported as required by the PFAS
section 8(a)(7) rule, it is not considered duplicative. Descriptions for each FC and a crosswalk
between the OECD-based 2020 CDR codes and 2016 CDR codes are provided in Appendix D
(Table D-4Table D-4). This crosswalk may be helpful if you are already familiar with the 2016
CDR codes and can help you determine the correct 2020 CDR codes to use if you have
previously reported the PFAS using 2016 CDR codes. Function Category codes to be used for
section 8(a)(7) reporting are provided in Table 4-26.
If you select F999 (Other), you must provide a description of the function of the chemical
substance. The written description should be used to provide a description at a comparable
level of specificity as found with the current codes. It should not be used to add additional,
more specific detail. Do not include CBI in this text box.
Function codes are based on the intended physical or chemical characteristic for when a
chemical substance or mixture is consumed as a reactant; incorporated into a formulation,
mixture, reaction product, or article; repackaged; or used (e.g., as an abrasive, a catalyst, or an
elasticizer). However, the functional use categories for consumer or commercial categories
cover the life cycle and describe the specific function that a chemical provides when used in the
formulation of a product or article, or when used within an industrial process. While the
function of a chemical may be the same across its life cycle, certain functions may only be
appropriate for consideration in an industrial setting, while others may be relevant for a
consumer or commercial setting.
Table 4-26. Codes for Reporting Function Categories
Code
Category
F001
Abrasives
F002
Etching agent
F003
Adhesion/cohesion promoter
F004
Binder
F005
Flux agent
F006
Sealant (barrier)
F007
Absorbent
F008
Adsorbent
F009
Dehydrating agent (desiccant)
F010
Drier
F011
Humectant
4-71
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
F012
Soil amendments (fertilizers)
F013
Anti-adhesive/cohesive
F014
Dusting agent
F015
Bleaching agent
F016
Brightener
F017
Anti-scaling agent
F018
Corrosion inhibitor
F019
Dye
F020
Fixing agent (mordant)
F021
Hardener
F022
Filler
F023
Anti-static agent
F024
Softener and conditioner
F025
Swelling agent
F026
Tanning agents not otherwise specified
F027
Waterproofing agent
F028
Wrinkle resisting agent
F029
Flame retardant
F030
Fuel agents
F031
Fuel
F032
Heat transferring agent
F033
Hydraulic fluids
F034
Insulators
F035
Refrigerants
F036
Anti-freeze agent
F037
Intermediate
F038
Monomers
F039
Ion exchange agent
F040
Anti-slip agent
F041
Lubricating agent
F042
Deodorizer
F043
Fragrance
F044
Oxidizing agent
F045
Reducing agent
F046
Photosensitive agent
F047
Photosensitizers
F048
Semiconductor and photovoltaic agent
4-72
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
F049
UV stabilizer
F050
Opacifer
F051
Pigment
F052
Plasticizer
F053
Plating agent
F054
Catalyst
F055
Chain transfer agent
F056
Chemical reaction regulator
F057
Crystal growth modifiers (nucleating agents)
F058
Polymerization promoter
F059
Terminator/Blocker
F060
Processing aids, specific to petroleum production
F061
Antioxidant
F062
Chelating agent
F063
Defoamer
F064
pH regulating agent
F065
Processing aids not otherwise specified
F066
Energy Releasers (explosives, motive propellant)
F067
Foamant
F068
Propellants, non-motive (blowing agents)
F069
Cloud-point depressant
F070
Flocculating agent
F071
Flotation agent
F072
Solids separation (precipitating) agent, not otherwise specified
F073
Cleaning agent
F074
Diluent
F075
Solvent
F076
Surfactant (surface active agent)
F077
Emulsifier
F078
Thickening agent
F079
Viscosity modifiers
F080
Laboratory chemicals
F081
Dispersing agent
F082
Freeze-thaw additive
F083
Surface modifier
F084
Wetting agent (non-aqueous)
F085
Aerating and deaerating agents
4-73
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
F086
Explosion inhibitor
F087
Fire extinguishing agent
F088
Flavoring and nutrient
F089
Anti-redeposition agent
F090
Anti-stain agent
F091
Anti-streaking agent
F092
Conductive agent
F093
Incandescent agent
F094
Magnetic element
F095
Anti-condensation agent
F096
Coalescing agent
F097
Film former
F098
Demulsifier
F099
Stabilizing agent
F100
Alloys
F101
Density modifier
F102
Elasticizer
F103
Flow promoter
F104
Sizing agent
F105
Solubility enhancer
F106
Vapor pressure modifiers
F107
Embalming agent
F108
Heat stabilizer
F109
Preservative
F110
Anti-caking agent
Fill
Deflocculant
F112
Dust suppressant
F113
Impregnation agent
F114
Leaching agent
F115
Tracer
F116
X-ray absorber
F999
Other
4.7.3 Consumer and Commercial Use
For purposes of section 8(a)(7) reporting, a commercial use means the use of a chemical
substance or a mixture (including as part of an article) in a commercial enterprise providing
4-74
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
saleable goods or a service (40 CFR 705.3). A consumer use, on the other hand, means the use
of a chemical substance or a mixture (including as part of an article) when sold to or made
available to consumers for their use (40 CFR 705.3).
For each PFAS manufactured (including imported), report up to ten unique
combinations of the following data elements: the Product Category (PC) (described in Section
4.7.3.2), the Function Category (FC) (described in Section 4.7.3.3), whether the use is consumer
and/or commercial (described in Section 4.7.3.4), and whether the use is in products intended
for use by children (described in Section 4.7.3.5) (40 CFR 705.15(c)(7)). A combination of these
four data elements defines a potential exposure scenario for risk-screening and priority-setting
purposes. If more than ten unique combinations apply to a chemical substance, you need only
report the ten combinations for the chemical substance that cumulatively represent the largest
percentage of production volume, measured by weight (40 CFR 705.18(a)(3)(iv)). The reporting
tool will allow you to enter more than ten combinations if you choose to do so.
For each of these unique combinations, you are also required to report the maximum
concentration of PFAS in the consumer or commercial product category (described in Section
4.7.3.6) (40 CFR 705.18(a)(3)(viii)).
You are required to report information that is known to or reasonably ascertainable by
you concerning the consumer and commercial end uses of each chemical substance
manufactured (including imported) at sites you control and at sites controlled by people to
whom you have either directly or indirectly (including through a broker/distributor, from a
customer, etc.) distributed the reportable PFAS (40 CFR 705.18(a)(3)(iv)).
4.7.3.1 Confidentiality of Consumer and Commercial Use Information
Most data elements in this section may not be claimed as confidential. You may not
claim the following consumer and commercial use data elements as confidential:
• product category
• function of the chemical in the consumer or commercial product
• whether the chemical is used in commercial or consumer products
• whether the chemical predictably is used in children's products
In this section, you may only assert a claim of confidentiality for the maximum
concentration of the chemical in any product. Checking the CBI box associated with this data
element automatically triggers substantiation questions. If you do not check the CBI box for any
information element, then that information is not claimed as CBI and may be made public
without further notice to you. See Table 4-30 for substantiation questions to be answered
when asserting CBI claims for processing and use information.
4.7.3.2 Product Category
You must designate up to ten product categories which correspond to the actual use of
the chemical substance by reporting the codes which correspond to the appropriate product
4-75
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
categories (40 CFR 705.18(a)(v)). If more than ten codes apply, you need report only the ten
codes for the chemical substance that cumulatively represent the largest percentage of
production volume, measured by weight. The reporting tool will allow you to enter more than
ten categories if you choose to do so.
You must use the codes in Table 4-27 for reporting under this data call. These codes,
based on OECD standards, were required for reporting of chemical substances designated by
EPA as a high priority for risk evaluation for 2020 CDR reporting and were optional for the 2020
CDR for other chemical substances, and were required for all chemicals in 2024 CDR; if you
reported to 2020 and/or 2024 CDR, you may be familiar with these codes. If your site reported
this PFAS to 2020 or earlier CDR using other codes, you will need to determine the appropriate
2020 CDR codes and report those in this section. Because data reported using other codes was
not reported as required by the PFAS section 8(a)(7) rule, it is not considered duplicative.
Descriptions for each product category code and a crosswalk between the OECD-based 2020
CDR codes and 2016 CDR codes are provided in Appendix D (Table D-3).
Product Category codes are provided in Table 4-27.
If you select CC980 (Other), you must provide a description of the product category. The
written description should be used to provide a description at a comparable level of specificity
as found with the current codes. It should not be used to add additional, more specific detail.
Do not enter CBI in this text box.
Table 4-27. Product Category Codes
Code
Category
Chemical Substances in Furnishing, Cleaning, Treatment Care Products
CC101
Construction and building materials covering large surface areas including stone, plaster, cement,
glass and ceramic articles; fabrics, textiles, and apparel
CC102
Furniture & furnishings including plastic articles (soft); leather articles
CC103
Furniture & furnishings including stone, plaster, cement, glass and ceramic articles; metal articles; or
rubber articles
CC104
Leather conditioner
CC105
Leather tanning, dye, finishing, impregnation and care products
CC106
Textile (fabric) dyes
CC107
Textile finishing and impregnating/surface treatment products
CC108
All-purpose foam spray cleaner
CC109
All-purpose liquid cleaner/polish
CC110
All-purpose liquid spray cleaner
CC111
All-purpose waxes and polishes
CC112
Appliance cleaners
4-76
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
CC113
Drain and toilet cleaners (liquid)
CC114
Powder cleaners (floors)
CC115
Powder cleaners (porcelain)
CC116
Dishwashing detergent (liquid/gel)
CC117
Dishwashing detergent (unit dose/granule)
CC118
Dishwashing detergent liquid (hand-wash)
CC119
Dry cleaning and associated products
CC120
Fabric enhancers
CC121
Laundry detergent (unit-dose/granule)
CC122
Laundry detergent (liquid)
CC123
Stain removers
CC124
Ion exchangers
CC125
Liquid water treatment products
CC126
Solid/Powder water treatment products
CC127
Liquid body soap
CC128
Liquid hand soap
CC129
Solid bar soap
CC130
Air fresheners for motor vehicles
CC131
Continuous action air fresheners
CC132
Instant action air fresheners
CC133
Anti-static spray
CC134
Apparel finishing, and impregnating/surface treatment products
CC135
Insect repellent treatment
CC136
Pre-market waxes, stains, and polishes applied to footwear
CC137
Post-market waxes, and polishes applied to footwear (shoe polish)
CC138
Waterproofing and water-resistant sprays
Chemical Substances in Construction, Paint, Electrical, and Metal Products
CC201
Fillers and putties
CC202
Hot-melt adhesives
CC203
One-component caulks
CC204
Solder
CC205
Single-component glues and adhesives
CC206
Two-component caulks
4-77
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
CC207
Two-component glues and adhesives
CC208
Adhesive/Caulk removers
CC209
Aerosol spray paints
CC210
Lacquers, stains, varnishes and floor finishes
CC211
Paint strippers/removers
CC212
Powder coatings
CC213
Radiation curable coatings
CC214
Solvent-based paint
CC215
Thinners
CC216
Water-based paint
CC217
Construction and building materials covering large surface areas, including wood articles
CC218
Construction and building materials covering large surface areas, including paper articles; metal
articles; stone, plaster, cement, glass and ceramic articles
CC219
Machinery, mechanical appliances, electrical/electronic articles
CC220
Other machinery, mechanical appliances, electronic/electronic articles
CC221
Construction and building materials covering large surface areas, including metal articles
CC222
Electrical batteries and accumulators
Chemical Substances in Packaging, Paper, Plastic, Tovs, Hobbv Products
CC990
Non-TSCA use
CC301
Packaging (excluding food packaging), including paper articles
CC302
Other articles with routine direct contact during normal use, including paper articles
CC303
Packaging (excluding food packaging), including rubber articles; plastic articles (hard); plastic
articles (soft)
CC304
Other articles with routine direct contact during normal use including rubber articles; plastic articles
(hard)
CC305
Toys intended for children's use (and child dedicated articles), including fabrics, textiles, and
apparel; or plastic articles (hard)
CC306
Adhesives applied at elevated temperatures
CC307
Cement/concrete
CC308
Crafting glue
CC309
Crafting paint (applied to body)
CC310
Crafting paint (applied to craft)
CC311
Fixatives and finishing spray coatings
CC312
Modelling clay
4-78
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
Code
Category
CC313
Correction fluid/tape
CC314
Inks in writing equipment (liquid)
CC315
Inks used for stamps
CC316
Toner/Printer cartridge
CC317
Liquid photographic processing solutions
Chemical Substances in Automotive, Fuel, Agriculture, Outdoor Use Products
CC401
Exterior car washes and soaps
CC402
Exterior car waxes, polishes, and coatings
CC403
Interior car care
CC404
Touch up auto paint
CC405
Degreasers
CC406
Liquid lubricants and greases
CC407
Paste lubricants and greases
CC408
Spray lubricants and greases
CC409
Anti-freeze liquids
CC410
De-icing liquids
CC411
De-icing solids
CC412
Lock de-icers/releasers
CC413
Cooking and heating fuels
CC414
Fuel additives
CC415
Vehicular or appliance fuels
CC416
Explosive materials
CC417
Agricultural non-pesticidal products
CC418
Lawn and garden care products
Chemical Substances in Products not Described bv Other Codes
CC980
Other (specify)
CC990
Non-TSCA use
4.7.3.3 Functional Use for Consumer and/or Commercial Products
For each consumer and/or commercial product category reported, report the code(s)
that designates the function category(ies) that best represents the specific manner in which the
chemical substance is used (40 CFR 705.18(a)(3)(v)). You must use the codes in Table 4-16 for
reporting under this data call. These codes are the same as those used to report the
4-79
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
appropriate Function Category for industrial processing and use. A particular function category
may need to be reported more than once, to the extent that more than one consumer or
commercial product category applies to a given function category.
For the special situation where the PFAS has multiple functions within the same product,
you can report in one of two ways:
• If one function is predominant, simply report the primary function; or
• If all functions represent a substantial portion of the product, report each on a
separate line.
If none of the listed function categories accurately describes a use of a chemical
substance, the category "Other" may be used, and must include a description of the use. The
written description should be used to provide a description at a comparable level of specificity
as found with the current codes. It should not be used to add additional, more specific detail.
Do not enter CBI in this text box.
4.7.3.4 Consumer and/or Commercial Use
For each product category reported, report whether the use is a consumer use or a
commercial use (40 CFR 705.18(a)(3)(vi)). If the product has both consumer and commercial
uses, report both.
4.7.3.5 Use in Product(s) Intended for Use by Children
Within each consumer product category reported, you must determine whether any
amount of each reportable chemical substance manufactured (including imported) by you is
present in or on any consumer product(s) intended for use by children aged 14 or younger,
regardless of the concentration of the chemical substance remaining in or on the product (40
CFR 705.18(a)(3)(vii)). If you determine that your chemical substance or mixture is used in a
consumer product intended for use by children, report "Yes" in the "Used in Product(s)
Intended for Children" field. If you determine that your chemical substance or mixture is not
used in a consumer product intended for use by children, report "No."
EPA defines "intended for use by children" to mean the chemical substance or mixture is
used in or on a product that is specifically intended for use by children aged 14 or younger (40
CFR 705.3). Your chemical substance or mixture is intended for use by children if you answer
"yes" to at least one of the following questions about the product into which your chemical
substance or mixture is incorporated:
• Is the product commonly recognized (i.e., by a reasonable person) as being intended for
use by children aged 14 or younger?
• Does the manufacturer of the product state through product labeling or other written
materials that the product is intended or will be used by children aged 14 or younger?
4-80
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
o Is the advertising, promotion, or marketing of the product aimed at children aged 14
or younger?
Table 4-28 illustrates some (non-exhaustive) examples of "Use in Product(s) Intended for
Use by Children." For example, certain products (e.g., crayons, coloring books, diapers, and toy
cars) are typically used by children aged 14 or younger. If you determine that your chemical
substance or mixture is used in crayons, for example, you would report "Yes" for children's use
for CC305.
Certain products, such as household cleaning products, automotive supplies, and
lubricants, typically are not intended to be used by children aged 14 or younger. As such, if you
determine that your chemical substance or mixture is used in automotive care products and
lubricants, for example, you would report "no" for children's use for categories CC401 and
CC402.
Table 4-28. Examples of Products Intended for Use by Children
Code
Category
Examples
Chemical Substances in Furnishings, Cleanings, Treatment Care Products
CC102
Furniture & furnishings including Plastic articles (soft);
Leather articles
Child's car seat, children's sheets
CC103
Furniture & furnishings including Stone, plaster, cement,
glass and ceramic articles; Metal articles; or Rubber articles
Baby cribs, changing tables
CC106
Textile (fabric) dyes
Children's clothing
CC107
Textile finishing and impregnating/surface treatment
products
Children's clothing, children's
sheets, child's car seat
CC127
Liquid body soap
Baby shampoo, children's bubble
bath
Chemical Substances in Construction, Paint, Electrical and Metal Products
CC219
Machinery, mechanical appliances, electrical/electronic
articles
Electronic games, remote control
cars
CC222
Electrical batteries and accumulators
Batteries used in toys
Chemical Substances in Packaging, Paper, Plastic, Hobbv Products
CC302
Other articles with routine direct contact during normal use,
including paper articles
Diapers, baby wipes, coloring
books
CC305
Toys intended for children's use (and child dedicated
articles), including Fabrics, textiles, and apparel; or Plastic
articles (hard)
Pacifiers, toy trucks, dolls, toy
cars, wagons, action figures,
balls, swing sets, slides, skates,
baseball gloves, kid's rake
4-81
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
CC306
Adhesives applied at elevated temperatures
Craft glue for a hot glue gun
CC308
Crafting glue
Craft glue
CC309
Crafting Paint (applied to body)
Chemicals used to add color to
body paint, finger paints
4.7.3.6 Maximum Concentration Code
When the chemical substance you manufacture (including import) is used in commercial
or consumer products, you are required to report the estimated typical maximum
concentration (measured by weight) of each chemical substance in each commercial or
consumer product category reported (40 CFR 705.15(c)(8)). For each PFAS imported in an
article and used in a reported commercial or consumer product, report the code that
corresponds to the appropriate concentration range. Table 4-29 shows the codes and
concentration ranges.
Table 4-29. Codes for Reporting Maximum PFAS Concentration in an Imported Article
Code
Concentration Range (weight percent)
AMI
Less than 0.1% by weight
AM 2
At least 0.1% but less than 1% by weight
AM 3
At least 1% but less than 10% by weight
AM4
At least 10% but less than 30% by weight
AM 5
At least 30% by weight
4.8 Streamlined Form: Research and Development (R&D) PFAS (below 10
kg/year)
If you have manufactured (including imported) PFAS in low quantities (i.e., below 10
kilograms/PFAS/year) for the purpose of research and development (R&D), then you have the
option to submit information to EPA using this streamlined form (see 40 CFR 705.18(b)). See
Section 2.2.2 for discussion on determining whether you qualify to use the R&D PFAS
streamlined form.
This streamlined form does not require all information required for the Standard Form;
when you select "Research & Development PFAS (<10 kg/year)" in the section 8(a)(7) reporting
4-82
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
tool, the program will show only fields required for this streamlined reporting form. Only
certain fields of the Standard Form are required for the streamlined R&D PFAS.
4.8.1 Reporting Manufacturing Information
This section describes the manufacturing data elements that should be reported for
your PFAS for each year. If any information is not known or reasonably ascertainable by you
(including your company), enter or select "NKRA" for "not known or reasonably ascertainable"
in the box corresponding to that data element. You may also check the CBI box next to each
data element to claim data as confidential. However, keep in mind that you cannot claim an
"NKRA" designation as confidential.
4.8.1.1 Domestically Manufactured Production Volume
Report the volume of the chemical substance domestically manufactured at your site, in
pounds. Report the quantity to at least two significant figures; it should be accurate to the
extent known to or reasonably ascertainable by you. Production volumes should be reported in
numeric format, without commas, but decimals may be used if known or reasonably
ascertainable (e.g., 6.85).
4.8.1.2 Imported Production Volume
Report the volume of the
chemical substance imported by
your site, in pounds. Report the
quantity to at least two significant
figures; it should be accurate to the
extent known to or reasonably
ascertainable by you. You should
use the same numeric format as
described for the domestically
manufactured production volume.
Imported and domestically
manufactured production volumes
are reported separately for each PFAS at each site.
Note that if you import various mixtures containing PFAS, you should add all import
volumes associated with each PFAS. For instance, if you import three mixtures and each
mixture contains PFAS A, then you would determine the volume of PFAS A in each mixture and
report the aggregated amount.
4.8.1.3 For Imported Chemical Substances, Is the Chemical Never Physically at Site?
Report whether or not your imported PFAS is physically at the reporting site. Report one
of the following choices:
Reporting for a chemical with multiple sources
If you import a PFAS from multiple sources, or domestically
manufacture the PFAS through multiple processes, sum those sources
together for reporting the total production volume, and consider the
total amount for all other data fields.
If you import or domestically manufacture a chemical and also have
quantities on site that were not manufactured by your site (e.g.,
purchased from a domestic source), consider only the volume
manufactured (including imported) by your site when reporting total
production volume and all other data fields. Do not report on
quantities of the PFAS that were not manufactured (including
imported) by your site.
4-83
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
~ Yes, the imported PFAS is never physically at the reporting site (e.g., if you ship
the chemical substance from a foreign country directly to another location
such as a warehouse, a processing or use site, or a customer's site).
~ No, the imported PFAS is physically present at the reporting site.
~ NA, not applicable because the PFAS is not imported.
~ NKRA, it is not known to or reasonably ascertainable by you whether the
imported PFAS is physically present at the reporting site.
4.9 Optional Information
This section consists of a text field for submitting additional information and
attachments to upload. Use this section to provide any additional information about your
submission that may be relevant. Do not include CBI in this optional field, including any
attachments.
4.10 Joint Submissions (Standard Form and R&D Substance Form)
4.10.1 Determining the Need for a Joint Submission
For PFAS manufacturers submitting either the standard form or the R&D substance
streamlined form, joint submissions are required in those instances where a company (e.g.,
foreign supplier, contracting company) will not disclose to the manufacturer (including
importer) certain chemical substance identifiers (i.e., CASRN, Accession number, or LVE
number), due to confidentiality concerns.
This may happen, for instance, when a company is importing a mixture under a trade
name, and the foreign manufacturer refuses to reveal the chemical identity of a confidential
component of the mixture. In this case, the importer and the supplier can each separately
report their portion of the required information, resulting in a joint submission. The importer
must ask the supplier of the confidential chemical substance to directly provide EPA with the
correct chemical identity (see 40 CFR 705.15(b)(iii)).
A manufacturer (including importer) can identify, on a chemical-by-chemical basis, the
supplier for a chemical substance. The reporting tool will generate a unique ID number for each
chemical substance (identified by a trade name). Therefore, a supplier may receive multiple ID
numbers from a manufacturer (including importer). A supplier may also report multiple
chemical substances under one ID number in the case that the ID number refers to a mixture. In
that situation, the supplier will be identifying the PFAS that comprise the mixture.
It is the responsibility of the primary submitter to ask its supplier, or secondary
submitter, to send the information to EPA by the end of the submission period. The reporting
tool leads the primary submitter through this notification process.
4-84
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
If the secondary submitter decides to provide the required trade name product
information directly to you, you should change your submission type and submit a single
submission.
Note that not all submitters are required to initiate joint submissions. Article importers
using the article importer reporting form will not be required or have the option to initiate joint
submissions. Additionally, if a secondary submitter is not known or reasonably ascertainable to
the PFAS manufacturer (e.g., if a foreign supplier is no longer in business and has no successor
entity), then the manufacturer would indicate within the Chemical Identification section of the
form that there is no secondary submitter who can provide chemical identity information and
need not initiate a joint submission.
4.10.2 The Primary Submission is Completed by the PFAS Manufacturer
The primary submitter for a joint submission is either an importer or a manufacturer of
a PFAS of unknown chemical identity (i.e., CASRN, TSCA Accession number, or LVE number are
all unknown). For ease of presentation, both types of primary submitters will be referred to as
"importer." The importer, as the primary submitter, is responsible for initiating the joint
submission. The importer uses the reporting tool to notify the secondary submitter (e.g., its
supplier or contract manufacturer) of the need to complete the secondary portion of the joint
submission, and completes the sections related to manufacturing (Section 4.6.1), industrial and
consumer/commercial processing and use (Sections 4.6.4 and 4.6.5), byproducts (Section 4.6.2),
and environmental and health effects (Section 4.6.6)forthe imported substance (40 CFR
705.30(g)).
Identifying the chemical identity of the unknown chemical substance and its secondary
submitter
In its portion of the joint submission, the primary submitter identifies the proprietary
substance or mixture using the trade name or another name or description, additional
information as needed to help the secondary submitter correctly identify the substance, and
the identity and contact information for the secondary submitter. See Sections 4.4.2 and 4.5.11
for additional information.
Notifying the secondary submitter about the joint submission
Using the reporting tool, the importer enters the email address of the secondary
submitter, and any necessary instruction for the secondary submitter to complete its part of
the joint submission, into a system generated email. Also contained within the email is the
unique identifier. The importer will need to click the link to send this information from CDX to
the Secondary Authorized Official. Additional recipients may be added by the importer. The
primary submitter may send the email before it has completed its part of the joint submission.
Completing the primary portion of the joint submission
4-85
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
The importer is responsible for completing the rest of the form as it relates to the
proprietary substance or mixture.
4.10.3 The Secondary Submission is Completed
The secondary submitter is responsible for identifying that it is providing information for
the joint submission using the information (e.g., identification number) provided by the primary
submitter and completing the Secondary Form.
4.10.3.1 Receiving notification from the primary submitter about the joint submission
The secondary submitter receives an email from the primary submitter identifying that a
joint submission has been initiated and providing the unique identification number needed for
the secondary submitter to complete its part of the joint submission.
4.10.3.2 Completing the Secondary Form, the secondary portion of the joint submission
The secondary submitter is responsible for completing the Secondary Form of the joint
submission, which includes its company identity, a technical contact, identification of its
customer (i.e., the primary submitter), the product trade name, and the unique identifier
supplied by the primary submitter. The secondary submitter then provides the chemical
identity and percentage of formulation of each PFAS in the product. See Section 4.5 for
information about chemical identity.
4.10.3.3 When the Supplier Doesn't Know the Chemical Identity
There may be instances where a foreign supplier (i.e., secondary submitter) purchases a
mixture, under a trade name, from another company (tertiary company) and does not know the
chemical components of the mixture. The secondary submitter can ask the company
manufacturing the trade secret mixture or chemical substance to directly provide EPA with the
correct chemical identity. In this case, the tertiary company would register with CDX and use
the Unique Identifier for Joint Submissions, sent to them by the manufacturer (including
importer), to complete the form.
Under this scenario, the secondary submitter does not have access to any of the
information submitted to EPA by the tertiary company. Likewise, the tertiary company cannot
see the information the foreign supplier reports to EPA. This way, the confidentiality of
information for both the secondary and tertiary company is protected.
4.10.4 Confidentiality of Information Jointly Submitted
All of the confidentiality requirements discussed earlier in these Instructions apply to
information submitted jointly. However, joint submissions include information required to
connect the two reports and their related data. For example, a joint submission requires that
the primary submitter provide a generic chemical name or trade name and secondary
submitter's identity. A secondary submitter would provide the composition of its product.
4-86
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
These data elements specific to joint submissions require that any claims of
confidentiality be asserted at the time of submission, but do not require upfront substantiation
(pursuant to TSCA section 14(c)(2)):
• Joint submission information from the primary submitter consisting of trade name and
supplier identification required pursuant to § 705.15(b)(l)(i) and § 705.18(b)(2)(i).
• Joint submission information from the secondary submitter consisting of the percentage
of formulation required pursuant to § 705.15(b)(l)(i) and (ii).
Because signatures are required by each party of a joint submission, each party must
register with CDX and complete their own sections of the same report. The reporting tool will
match both submissions based upon the unique ID number sent by the manufacturer (including
importer) to notify the secondary submitter of the partial section 8(a)(7) submission. Suppliers
do not have access to any of the information submitted to EPA by the manufacturer (except the
manufacturer's identity and contact information and the submitted trade name or chemical
identifier). Likewise, manufacturers cannot see the information that the supplier reports to
EPA.
This way, the confidentiality of information for all submitters is protected. The
information provided by both submitters will be combined and processed as one joint
submission once they are received by EPA.
NOTE: In the event that a manufacturer (including importer) actually knows or can
reasonably ascertain the chemical identity (e.g., the CASRN or Accession Number) of a
chemical substance subject to section 8(a)(7) reporting, the manufacturer (including
importer) must provide that information irrespective of a supplier's confidentiality claims. If
such a primary submitter wishes to claim the chemical identity as confidential, to do so they
must check the CBI box and provide upfront substantiation as described in 4.5 of this chapter.
4.11 CBI Substantiation
If you have asserted any CBI claims for which substantiation is required, you will be
required to respond to each claim in the CBI Substantiation portion of the application. For all
non-exempt claims, you must substantiate them at the time of form submission and they must
be signed and dated by an authorized official. An authorized official representing a person
asserting a claim of confidentiality must certify that the submission complies with the
requirements of this rule by signing and dating the following certification statement:
"I certify that all claims for confidentiality asserted with this submission are true and
correct, and all information submitted herein to substantiate such claims is true and
correct. Any knowing and willful misrepresentation is subject to criminal penalty
pursuant to 18 U.S.C. 1001. I further certify that: (1) I have taken reasonable measures
to protect the confidentiality of the information; (2) I have determined that the
information is not required to be disclosed or otherwise made available to the public
4-87
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
under any other Federal law; (3) I have a reasonable basis to conclude that disclosure of
the information is likely to cause substantial harm to the competitive position of my
company; and (4) I have a reasonable basis to believe that the information is not readily
discoverable through reverse engineering."
For each data element claimed as CBI and is not specifically exempt from substantiation
(other than claims related to chemical identity), you must provide detailed written answers to
the questions listed in Table 4-30.
Table 4-30. Substantiation Questions to be Answered for All Types of Confidentiality Claims
Confidentiality Claims (40 CFR 705.30(e))
No.
Question
1
Substantial harm due to release. Please specifically explain what harm to the competitive position
of your business would be likely to result from the release of the information claimed as
confidential business information. How would that harm be substantial? Why is the substantial
harm to your competitive position likely (i.e., probable) to be caused by release of the information
rather than just possible? If you claimed multiple types of information to be confidential (e.g., site
information, exposure information, environmental release information, etc.), explain how
disclosure of each type of information would be likely to cause substantial harm to the competitive
position of your business.
2
Precautions to protect confidentiality. Has your business taken precautions to protect the
confidentiality of the disclosed information? If yes, please explain and identify the specific
measures, including but not limited to internal controls, that your business has taken to protect
the information claimed as confidential business information. If the same or similar information
was previously reported to EPA as non-confidential (such as in an earlier version of this
submission), please explain the circumstances of that prior submission and reasons for believing
the information is nonetheless still confidential.
3
Disclosure under Federal law or publicly available information.
(i) Is any of the information claimed as confidential business information required to be
publicly disclosed under any other Federal law? If yes, please explain.
(ii) Does any of the information claimed as confidential business information otherwise appear
in any public documents, including (but not limited to) safety data sheets; advertising or
promotional material; professional or trade publications; state, local, or Federal agency files;
or any other media or publications available to the general public? If yes, please explain why
the information should be treated as confidential. If this chemical is patented and the patent
reveals the information you are claiming to be confidential business information, please
explain your reasons for believing the information is nonetheless still confidential.
4
Duration of claims. Is the claim of confidentiality intended to last less than 10 years (see TSCA
section 14(e)(1)(B))? If yes, please indicate the number of years (between 1-10 years) or the
specific date after which the claim is withdrawn.
5
Previously disclosed information. Has EPA, another Federal agency, or court made any
confidentiality determination regarding information associated with this chemical substance? If
yes, please provide the circumstances associated with the prior determination, whether the
information was found to be entitled to confidential treatment, the entity that made the decision,
and the date of the determination.
4-88
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
If you assert any specific chemical identity as CBI, including byproduct chemical
substance identity, you must answer additional questions related to these claims. Table 4-31
lists all substantiation questions that must be answered in detail in the reporting application for
claims of confidentiality related to specific chemical identity.
Table 4-31. Substantiation Questions to be Answered when Asserting Chemical Identity CBI
Claims (40 CFR 705.30(e) and (f))
No.
Question
Substantiation Requirements for All Types of Confidentiality Claims (40 CFR 705.3(e))
1.
Substantial harm due to release. Please specifically explain what harm to the competitive position of
your business would be likely to result from the release of the information claimed as confidential
business information. How would that harm be substantial? Why is the substantial harm to your
competitive position likely (i.e., probable) to be caused by release of the information rather than just
possible? If you claimed multiple types of information to be confidential (e.g., site information,
exposure information, environmental release information, etc.), explain how disclosure of each type
of information would be likely to cause substantial harm to the competitive position of your business.
2.
Precautions to protect confidentiality. Has your business taken precautions to protect the
confidentiality of the disclosed information? If yes, please explain and identify the specific measures,
including but not limited to internal controls, that your business has taken to protect the information
claimed as confidential business information. If the same or similar information was previously
reported to EPA as non-confidential (such as in an earlier version of this submission), please explain
the circumstances of that prior submission and reasons for believing the information is nonetheless
still confidential.
3.
Disclosure under Federal law or publicly available information.
(i) Is any of the information claimed as confidential business information required to be publicly
disclosed under any other Federal law? If yes, please explain.
(ii) Does any of the information claimed as confidential business information otherwise appear in
any public documents, including (but not limited to) safety data sheets; advertising or promotional
material; professional or trade publications; state, local, or Federal agency files; or any other media
or publications available to the general public? If yes, please explain why the information should be
treated as confidential. If this chemical is patented and the patent reveals the information you are
claiming to be confidential business information, please explain your reasons for believing the
information is nonetheless still confidential.
4.
Duration of claims. Is the claim of confidentiality intended to last less than 10 years (see TSCA
section 14(e)(1)(B))? If yes, please indicate the number of years (between 1-10 years) or the specific
date after which the claim is withdrawn.
5.
Previously disclosed information. Has EPA, another Federal agency, or court made any
confidentiality determination regarding information associated with this chemical substance? If yes,
please provide the circumstances associated with the prior determination, whether the information
was found to be entitled to confidential treatment, the entity that made the decision, and the date
of the determination.
4-89
-------
Chapter 4
Instructions for Completing Section 8(a)(7) Reporting
No.
Question
Additional Requirements for Specific Chemical Identity" (40 CFR 705.30(f))
6.
Chemical substance in U.S. commerce. Is this chemical substance publicly known (including by your
competitors) to be in U.S. commerce? If yes, please explain why the specific chemical identity should
still be afforded confidential status (e.g., the chemical substance is publicly known only as being
distributed in commerce for research and development purposes, but no other information about
the current commercial distribution of the chemical substance in the United States is publicly
available). If no, please complete the certification statement:
"1 certify that on the date referenced, 1 searched the internet for the chemical substance identity
(i.e., by both chemical substance name and CASRN). 1 did not find a reference to this chemical
substance that would indicate that the chemical is being manufactured or imported by anyone
for a commercial purpose in the United States, [provide date]."
7.
Leave manufacturing site. Does this particular chemical substance leave the site of manufacture
(including import) in any form, e.g., as a product, effluent, emission? If yes, please explain what
measures have been taken to guard against the discovery of its identity.
8.
Chemical identity. If the chemical substance leaves the site in a form that is available to the public or
your competitors, can the chemical identity be readily discovered by analysis of the substance (e.g.,
product, effluent, emission), in light of existing technologies and any costs, difficulties, or limitations
associated with such technologies? Please explain why or why not.
9.
Chemical name. Would disclosure of the specific chemical name release confidential process
information? If yes, please explain.
4-90
-------
Chapter 5
How to Obtain Copies of Documents Cited in This Instructions Document
5. How to Obtain Copies of Documents Cited in This
Instructions Document
5.1 Obtaining Copies of the TSCA Rules
The section 8(a)(7) rule, 40 CFR 705, is available on the U.S. Government Publishing
Office website, www.ecfr.gov.
You may also contact the TSCA Hotline by telephone at (202) 554-1404 or by email tsca-
hotline@epa.gov for assistance.
5.2 Obtaining Copies of Other Information Materials
EPA has developed documents to provide additional information on submitting
information for this data call. Except where otherwise noted, materials are available on the
section 8(a)(7) website at:https://tscaquideme.epa.qov/ords/tsca-qme/r/tsca/pfas-8a7/home
In addition to materials developed specifically for section 8(a)(7) reporting, some
materials developed for TSCA more broadly or for CDR reporting are also applicable to
reporting under this data call.
Reporting Electronically:
• Instructions on CDX registration: CDX Online Registration User Guide
• Some fact sheets Fact Sheets for CDR are relevant to section 8(a)(7) reporting. These fact
sheets are available at Guidance Documents on the CDR GuideME. CDR fact sheets
relevant to reporting under this data call include:
o Reporting After Changes to Company Ownership or Legal Identity
o Imported Articles (use this fact sheet as guidance in determining if your chemical
substance is contained in an article; other items discussed in this fact sheet, such as
references to reporting thresholds and polymer exemption, do not apply to this data
call)
5-1
-------
Appendix A
Glossary of Terms
Appendix A. Glossary of Terms
The definitions and descriptions of terms used in section 8(a)(7) reporting provided
below are taken from 40 CFR 705.3 unless otherwise noted.
Act means the Toxic Substances Control Act, as amended, 15 U.S.C. 2601 etseq.
Administrator means the Administrator of the Environmental Protection Agency. (See
TSCA 3(1))
Article means a manufactured item (1) which is formed to a specific shape or design
during manufacture, (2) which has end-use function(s) dependent in whole or in part upon its
shape or design during end use, and (3) which has either no change of chemical composition
during its end use or only those changes of composition which have no commercial purpose
separate from that of the article, and that result from a chemical reaction that occurs upon end
use of other chemical substances, mixtures, or articles; except that fluids and particles are not
considered articles regardless of shape or design.
Byproduct means a chemical substance produced without separate commercial intent
during the manufacture, processing, use, or disposal of another chemical substance(s) or
mixture(s). (40 CFR 704.3)
Central Data Exchange (CDX) means EPA's centralized electronic document receiving
system.
Chemical Information Submission System (CISS) means EPA's electronic, web-based
reporting tool for the completion and submission of data, reports, and other information, or its
successors.
Chemical substance means any organic or inorganic substance of a particular molecular
identity, including any combination of such substances occurring in whole or in part as a result
of a chemical reaction or occurring in nature, and any element or uncombined radical.
"Chemical substance" does not include:
(1) Any mixture;
(2) Any pesticide (as defined in the Federal Insecticide, Fungicide, and Rodenticide Act [7
U.S.C. 136 et seq.]) when manufactured, processed, or distributed in commerce for
use as a pesticide;
(3) Tobacco or any tobacco product;
(4) Any source material, special nuclear material, or byproduct material (as such terms
are defined in the Atomic Energy Act of 1954 [42 U.S.C. 2011 et seq.] and the
regulations issued under such Act);
(5) Any article the sale of which is the subject to the tax imposed by section 4181 of the
Internal Revenue Code of 1986 [26 U.S.C. 4181] (determined without regard to any
A-l
-------
Appendix A
Glossary of Terms
exemptions from such tax provided by section 4182 or 4221 or any other provision
of such Code) and any component of such an article (limited to shot shells,
cartridges, and components of shot shells and cartridges); and
(6) Any food, food additive, drug, cosmetic, or device (as such terms are defined in
section 201 of the Federal Food, Drug, and Cosmetic Act [21 U.S.C. 321]) when
manufactured, processed, or distributed in commerce for use as a food, food
additive, drug, cosmetic, or device. (TSCA 3(2))
Commerce means trade, traffic, transportation, or other commerce: (A) between a place
in a State and any place outside of such State, or (B) which affects trade, traffic, transportation,
or commerce described in clause (A). (TSCA 3(3))
Commercial use means the use of a chemical substance or a mixture containing a
chemical substance (including as part of an article) in a commercial enterprise providing
saleable goods or services.
Consumer use means the use of a chemical substance or a mixture containing a chemical
substance (including as part of an article) when sold to or made available to consumers for their
use.
Customs territory of the United States, as referenced in TSCA section 3(9) and defined in
general note 2 of the Harmonized Tariff Schedule of the United States, includes only the States,
the District of Columbia, and Puerto Rico.
Distribute in commerce and distribution in commerce, when used to describe an action
taken with respect to a chemical substance or mixture or article containing a substance or
mixture mean to sell, or the sale of, the substance, mixture, or article in commerce; to
introduce or deliver for introduction into commerce, or the introduction or delivery for
introduction into commerce of, the substance, mixture, or article; or to hold, or the holding of,
the substance, mixture, or article after its introduction into commerce. (TSCA 3(5))
Environmental or health effects information means any information of any effect of a
chemical substance or mixture containing a chemical substance on health or the environment
or on both. This includes all health and safety studies.
(1) Not only is information that arises as a result of a formal, disciplined study included,
but other information relating to the effects of a chemical substance or mixture
containing a chemical substance on health or the environment is also included. Any
information that bears on the effects of a chemical substance on health or the
environment would be included.
(2) Examples are:
(i) Long- and short-term tests of mutagenicity, carcinogenicity, or teratogenicity;
data on behavioral disorders; dermatoxicity; pharmacological effects;
A-2
-------
Appendix A
Glossary of Terms
mammalian absorption, distribution, metabolism, and excretion; cumulative,
additive, and synergistic effects; and acute, subchronic, and chronic effects.
(ii) Tests for ecological or other environmental effects on invertebrates, fish, or
other animals, and plants, including: Acute toxicity tests, chronic toxicity tests,
critical life-stage tests, behavioral tests, algal growth tests, seed germination
tests, plant growth or damage tests, microbial function tests, bioconcentration
or bioaccumulation tests, and model ecosystem (microcosm) studies.
(iii) Assessments of human and environmental exposure, including workplace
exposure, and impacts of a particular chemical substance or mixture containing a
chemical substance on the environment, including surveys, tests, and studies of:
Biological, photochemical, and chemical degradation; structure/activity
relationships; air, water, and soil transport; biomagnification and
bioconcentration; and chemical and physical properties, e.g., boiling point, vapor
pressure, evaporation rates from soil and water, octanol/water partition
coefficient, and water solubility.
(iv) Monitoring data, including but not limited to when they have been aggregated
and analyzed to measure the exposure of humans or the environment to a
chemical substance or mixture containing a chemical substance.
EPA means the United States Environmental Protection Agency. (40 CFR 704.3)
Health and safety studies means any study of any effect of a chemical substance or
mixture on health or the environment or on both, including underlying information and
epidemiological studies, studies of occupational exposure to a chemical substance or mixture,
toxicological, clinical, and ecological studies of a chemical substance or mixture containing a
chemical substance, and any test performed under TSCA. The following information is not part
of a health and safety study:
(1) The name, address, or other identifying information for the submitting company,
including identification of the laboratory that conducted the study in cases where the
laboratory is part of or closely affiliated with the submitting company;
(2) Internal product codes (i.e., code names for the test substance used internally by the
submitting company or to identify the test substance to the test laboratory);
(3) Names and contact details for testing laboratory personnel and names and other
private information for health and safety study participants or persons involved in chemical
incidents such as would typically be withheld under 5 U.S.C. 552(b)(6) or under other privacy
laws; and
(4) Information pertaining to test substance product development, advertising, or
marketing plans, or to cost and other financial data.
[see also TSCA 3(8)]
A-3
-------
Appendix A
Glossary of Terms
Highest-level Parent Company means the highest-level company of the site's ownership
hierarchy as of the start of the submission period during which data are being reported
according to the following instructions. The highest-level U.S. parent company is located within
the United States while the highest-level foreign parent company is located outside the United
States. The following rules govern how to identify the highest-level U.S. parent company and
highest-level foreign parent company (if applicable):
(1) If the site is entirely owned by a single U.S. company that is not owned by another
company, that single company is the U.S. parent company.
(2) If the site is entirely owned by a single U.S. company that is, itself, owned by another
U.S.-based company (e.g., it is a division or subsidiary of a higher-level company), the
highest- level domestic company in the ownership hierarchy isthe United States
parent company. If there is a higher-level parent company that is outside of the
United States, the highest-level foreign company in the ownership hierarchy is the
foreign parent company.
(3) If the site is owned by more than one company (e.g., company A owns 40 percent,
company B owns 35 percent, and company C owns 25 percent), the company with
the largest ownership interest in the site isthe parent company. If a higher-level
company in the ownership hierarchy owns more than one ownership company, then
determine the entity with the largest ownership by considering the lower-level
ownerships in combination (e.g., corporation Xowns companies B and C, for a total
ownership of 60 percent for the site).
(4) If the site is owned by a 50:50 joint venture or a cooperative, the joint venture or
cooperative is its own parent company. If the site is owned by a U.S. joint venture or
cooperative, the highest level of the joint venture or cooperative is the U.S. parent
company. If the site is owned by a joint venture or cooperative outside the United
States, the highest level of the joint venture or cooperative outside the United States
is the foreign parent company.
(5) If the site is federally owned, the highest-level federal agency or department isthe U.S.
parent company.
(6) If the site is owned by a non-federal public entity, that entity (such as a municipality,
State, or tribe) is the U.S. parent company.
Importer means
(1) any person who imports any chemical substance or any chemical substance as part
of a mixture or article into the customs territory of the United States, and includes:
(i) the person primarily liable for the payment of any duties on the merchandise,
or
(ii) an authorized agent acting on his/her behalf.
(2) Importer also includes, as appropriate:
A-4
-------
Appendix A
Glossary of Terms
(i) The consignee.
(ii) The importer of record.
(iii) The actual owner if an actual owner's declaration and superseding bond have
been filed in accordance with 19 CFR 141.20.
(iv) The transferee, if the right to draw merchandise in a bonded warehouse has
been transferred in accordance with subpart C of 19 CFR part 144.
(3) For the purposes of this definition, the customs territory of the United States
consists of the 50 States, Puerto Rico, and the District of Columbia. (40 CFR 704.3)
Impurity means a chemical substance which is unintentionally present with another
chemical substance. (40 CFR 704.3)
Industrial function means the intended physical or chemical characteristic for which a
chemical substance or mixture is consumed as a reactant; incorporated into a formulation,
mixture, reaction product, or article; repackaged; or used.
Industrial use means use at a site at which one or more chemical substances or mixtures
are manufactured (including imported) or processed.
Intended for use by children means the chemical substance or mixture is used in a
product that is specifically intended for use by children age 14 or younger. A chemical
substance or mixture is intended for use by children when the submitter answers "yes" to at
least one of the following questions for the product into which the submitter's chemical
substance or mixture is incorporated:
(1) Is the product commonly recognized (i.e., by a reasonable person) as being intended
for children aged 14 or younger?
(2) Does the manufacturer of the product state through product labeling or other
written materials that the product is intended or will be used by children age 14 or
younger?
(3) Is the advertising, promotion, or marketing of the product aimed at children age 14
or younger?
Intermediate means any chemical substance that is consumed, in whole or in part, in
chemical reactions used for the intentional manufacture of other chemical substances or
mixtures, or that is intentionally present for the purpose of altering the rates of such chemical
reactions. (40 CFR 704.3)
Known to or reasonably ascertainable by means all information in a person's
possession or control, plus all information that a reasonable person similarly situated might be
expected to possess, control, or know.
A-5
-------
Appendix A
Glossary of Terms
Manufacture means to import into the customs territory of the United States (as
defined in general note 2 of the Harmonized Tariff Schedule of the United States (19 U.S.C.
1202)). produce, or manufacture for commercial purposes, [see also TSCA 3(9)] Manufacturer
means a person who imports, produces, or manufactures a chemical substance. A person who
extracts a component chemical substance from a previously existing chemical substance or a
complex combination of substances is a manufacturer of that component chemical substance.
(40 CFR 704.3)
Manufacture for commercial purposes means: (1) to import, produce, or manufacture
with the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer, and includes among other things, such "manufacture" of any amount of a
chemical substance or mixture:
(i) For commercial distribution, including for test marketing.
(ii) For use by the manufacturer, including use for product research and
development, or as an intermediate.
(2) Manufacture for commercial purposes also applies to substances that are produced
coincidentally during the manufacture, processing, use, or disposal of another substance or
mixture, including both byproducts that are separated from that other substance or mixture
and impurities that remain in that substance or mixture. Such byproducts and impurities may,
or may not, in themselves have commercial value. They are nonetheless produced for the
purpose of obtaining a commercial advantage since they are part of the manufacture of a
chemical product for a commercial purpose.
Master Inventory File means EPA's comprehensive list of chemical substances which
constitute the Chemical Substances Inventory compiled under section 8(b) of the Act. It
includes substances reported under 40 CFR Part 710 and substances reported under Part 720
for which a Notice of Commencement of Manufacture or Import has been received under §
720.120.
Mixture means any combination of two or more chemical substances if the combination
does not occur in nature and is not, in whole or in part, the result of a chemical reaction; except
that such term does include any combination which occurs, in whole or in part, as a result of a
chemical reaction if none of the chemical substances comprising the combination is a new
chemical substance and if the combination could have been manufactured for commercial
purposes without a chemical reaction at the time the chemical substances comprising the
combination were combined. (TSCA 3(10))
Non-isolated intermediate means any intermediate that is not intentionally removed
from the equipment in which it is manufactured, including the reaction vessel in which it is
manufactured, equipment which is ancillary to the reaction vessel, and any equipment through
which the substance passes during a continuous flow process, but not including tanks or other
vessels in which the substance is stored after its manufacture. (40 CFR 704.3)
A-6
-------
Appendix A
Glossary of Terms
Parent Company is a company that owns or controls another company. (40 CFR 704.3)
Per- and polyfluoroalkyl substances or PFAS, means any chemical substance or mixture
containing a chemical substance that structurally contains at least one of the following three
sub-structures:
1. R-(CF2)-CF(R')R", where both the CF2 and CF moieties are saturated carbons
2. R-CF2OCF2-R', where R and R' can either be F, 0, or saturated carbons
3. CF3C(CF3)R'R", where R' and R"" can either be F or saturated carbons.
Person means any individual, firm, company, corporation, joint venture, partnership,
sole proprietorship, association, or any other business entity; any State or political subdivision
thereof, or any municipality; any interstate body; and any department, agency, or
instrumentality of the Federal government. (40 CFR 704.3)
Possession or control means in possession or control of the submitter, or of any
subsidiary, partnership in which the submitter is a general partner, parent company, or any
company or partnership which the parent company owns or controls, if the subsidiary, parent
company, or other company or partnership is associated with the submitter in the research,
development, test marketing, or commercial marketing of the chemical substance in question.
(A parent company owns or controls another company if the parent owns or controls 50 percent
or more of the other company's voting stock. A parent company owns or controls any
partnership in which it is a general partner). Information is included within this definition if it is:
(1) In files maintained by submitter's employees who are:
(i) Associated with research, development, test marketing, or commercial marketing
of the chemical substance in question.
(ii) Reasonably likely to have such data.
(2) Maintained in the files of other agents of the submitter who are associated with
research, development, test marketing, or commercial marketing of the chemical
substance in question in the course of their employment as such agents.
Process means to process for commercial purposes. (40 CFR 704.3)
Process for commercial purposes means the preparation of a chemical substance or
mixture after its manufacture for distribution in commerce with the purpose of obtaining an
immediate or eventual commercial advantage for the processor. Processing of any amount of a
chemical substance or mixture is included in this definition. If a chemical substance or mixture
containing impurities is processed for commercial purposes, then the impurities also are
processed for commercial purposes. (40 CFR 704.3)
Processor means any person who processes a chemical substance or mixture. (40 CFR
704.3)
A-7
-------
Appendix A
Glossary of Terms
Reasonably likely to be exposed means an exposure to a chemical substance which,
under foreseeable conditions of manufacture (including import), processing, distribution in
commerce, or use of the chemical substance, is more likely to occur than not to occur. Such
exposures would normally include, but would not be limited to, activities such as charging
reactor vessels, drumming, bulk loading, cleaning equipment, maintenance operations,
materials handling and transfers, and analytical operations. Covered exposures include
exposures through any route of entry (inhalation, ingestion, skin contact, absorption, etc.), but
excludes accidental or theoretical exposures. (40 CFR 711.3)
Research and development (R&D) means activities intended solely as scientific
experimentation, research, or analysis. R&D focuses on the analysis of the chemical or physical
characteristics, the performance, or the production characteristics of a chemical substance, a
mixture containing the substance, or an article. R&D encompasses a wide range of activities
which may occur in a laboratory, pilot plant, commercial plant outside the research facility, or at
other sites appropriate for R&D. General distribution of chemical substances to consumers does
not constitute R&D.
Site means a contiguous property unit. Property divided only by a public right-of-way
shall be considered one site. More than one plant may be located on a single site.
(a) For chemical substances manufactured under contract, i.e., by a co-manufacturer,
the site is the location where the chemical substance is physically manufactured.
(b) The site for an importer who imports a chemical substance described in § 711.5 is
the U.S. site of the operating unit within the person's organization that is directly
responsible for importing the substance. The import site, in some instances, may be
the organization's headquarters in the United States. If there is no such operating
unit or headquarters in the United States, the site address for the importer is the
United States address of an agent acting on behalf of the importer who is authorized
to accept service of process for the importer.
(c) For portable manufacturing units sent out to different locations from a single
distribution center, the distribution center shall be considered the site. (40 CFR
704.3)
Site-limited means a chemical substance is manufactured and processed only within a
site and is not distributed for commercial purposes as a substance or as part of a mixture or
article outside the site. Imported substances are never site-limited. Although a site-limited
chemical substance is not distributed for commercial purposes outside the site at which it is
manufactured and processed, the substance is considered to have been manufactured and
processed for commercial purposes.
Small manufacturer means a manufacturer (including importer) that meets either of the
following standards:
A-8
-------
Appendix A
Glossary of Terms
(1) First standard. A manufacturer (including importer) of a substance is small if its total
annual sales, when combined with those of its parent company (if any), are less than
$120 million. However, if the annual production or importation volume of a
particular substance at any individual site owned or controlled by the manufacturer
or importer is greater than 45,400 kilograms (100,000 lb), the manufacturer
(including importer) will not qualify as small for purposes of reporting on the
production or importation of that substance at that site, unless the manufacturer
(including importer) qualifies as small under standard (2) of this definition.
(2) Second standard. A manufacturer (including importer) of a substance is small if its
total annual sales, when combined with those of its parent company (if any), are less
than $12 million, regardless of the quantity of substances produced or imported by
that manufacturer (including importer). (40 CFR 704.3)
State means any State of the United States, the District of Columbia, the
Commonwealth of Puerto Rico, the Virgin Islands, Guam, the Canal Zone, American Samoa, the
Northern Mariana Islands, or any other territory or possession of the United States. (TSCA 3(16))
United States, when used in the geographic sense, means all of the States. (TSCA3(17))
Worker means someone at a site of manufacture, import, or processing who performs
work activities near sources of a chemical substance or mixture or directly handles the chemical
substance or mixture during the performance of work activities.
A-9
-------
Appendix B.
Key Comparisons between Section 8(a)(7) Data Call and CDR
Appendix B. Key Comparisons between Section 8(a)(7) Data
Call and CDR
This PFAS data call is promulgated under TSCA section 8(a)(7) and has many similarities
to Chemical Data Reporting (CDR) required under TSCA section 8(a)(1). You or someone else at
your site or company may have previously reported to CDR. However, it is important to note
that there are certain differences between section 8(a)(7) reporting and reporting under CDR.
You should review the final rule in 40 CFR 705 as well as this document to ensure you are
reporting correctly. To assist you, this section outlines key differences between section 8(a)(7)
reporting and reporting under CDR. Important differences to consider include:
• Absence of certain reporting exemptions and reporting thresholds that exist under CDR
• Differences in what data elements are to be reported
• Timeframe (years covered by the rule)
• Considerations for claiming information as confidential business information (CBI)
• Availability of streamlined reporting options in certain manufacturing scenarios
Reporting Exemptions
PFAS section 8(a)(7) reporting does not provide any exemptions. Do not assume you
qualify for a section 8(a)(7) exemption because you qualify for a CDR exemption. Review
Section 2 of this document for additional guidance on determining if you are required to report.
For example, CDR reporters are not required to report for small manufacture/import quantities,
chemicals imported as part of an article, or chemicals manufactured as byproducts that meet
exemption requirements under 711.10(c), 711.10(d)(1), or 711.10(d)(2). No such exemptions
apply to section 8(a)(7) reporting - you may be required to submit a section 8(a)(7) report
even if one of these, or any other, CDR exemption applies to your chemical substance.
CDR exemptions that do not apply to PFAS Section 8(a)(7) reporting include, but are not
limited to, exemptions for: articles containing PFAS (including imported articles containing PFAS
such as articles containing PFAS as part of surface coatings), byproducts, impurities, polymers,
and non-isolated intermediates.
Reported Data Elements
Data to be reported under section 8(a)(7) include some fields comparable to data
reporting under CDR and some additional data. For fields comparable to CDR reporting, note
that there may be differences between requirements for how to report to this data call
compared to CDR reporting. In particular, lists of codes (such as codes for reporting industrial
uses) may differ from the codes your site has used to report to CDR in the past. Additional data
to be reported includes information on byproducts, environmental and health effects, worker
exposure during industrial and commercial use, and disposal.
B-l
-------
Appendix B.
Key Comparisons between Section 8(a)(7) Data Call and CDR
Covered Timeframe
This data call covers activities occurring from January 1, 2011, through December 31,
2022 (i.e., the end of the last calendar year prior to the effective date of this rule), a period of 12
years. Unlike CDR reporting, all years are treated equally for purposes of this data call; there is
no "principal reporting year," and the same data elements must be reported for each year. The
reporting software allows you to select a subset of years to report on if you did not manufacture
the PFAS every year.
Considerations for CBI claims
Although the process of asserting CBI claims is similar to the process used for CDR
reporting, there are some important differences. Review the section 8(a)(7) rule and this
guidance when asserting CBI claims. It is your responsibility to ensure you are claiming and
substantiating CBI claims as required by the section 8(a)(7) rule. If you fail to substantiate your
CBI claims in accordance with the statute and applicable rules, EPA may make the information
available to the public without further notice to you. However, EPA intends to publish a list of
Accession numbers for which either no chemical identity CBI claim was asserted or the claim
was denied as candidates for moving to the public Inventory and provide opportunity for other
claimants of the chemical identity to appeal. Instructions for claiming and substantiating CBI
claims are included in the instructions for each section. For additional information about how to
answer substantiation questions, visit www.epa.gov/tsca-cbi on the EPA website.
B-2
-------
Appendix C
Examples of PFAS covered by this rule
Appendix C. Examples of PFAS covered by this rule
The requirements of this part apply to all chemical substances and mixtures that are
PFAS, consistent with the definition of PFAS at § 705.3. A non-exhaustive list of PFAS is provided
in EPA's CompTox Dashboard. The CompTox list includes all chemicals with known structures
that meet the definition of PFAS for section 8(a)(7) reporting. The CompTox list includes all
known chemicals, regardless of their TSCA Inventory status, and is updated as new chemicals
are added to the database. The CompTox list does not include all polymers or chemicals with
undefined (unknown or variable) structures, which may be covered by this rule. This list is also
available via EPA's Substance Registry Service. An Excel® file of chemicals on the TSCA Inventory
that meet the definition of PFAS is provided in the Additional Resources section of the PFAS
8(a)(7) TSCA website and on the TSCA 8(a)(7) GuideME resources:
https://tscaguideme.epa.gov/ords/tsca-gme/r/tsca/pfas-8a7/gd?gd=pfas-public-list. The Excel®
file includes both chemicals with known structures as well as polymers and other chemicals
with unknown orvariable composition.
Note that this rule defines PFAS using a structural definition. While EPA is providing
these lists to assist potentially affected entities with identifying reportable PFAS, manufacturers
are advised that a chemical substance's omission from these lists does not necessarily mean it
is not reportable under this rule. EPA notes that some possible reasons that a TSCA chemical
substance that meets this rule's PFAS definition include: (1) being exempt from other TSCA
reporting or notification requirements (e.g., certain byproducts, impurities, R&D substances);
(2) a substance whose identity (even a generic identity) EPA cannot currently reveal due to
confidential business information (CBI) protections.
c-i
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Appendix D. Descriptions of Codes for Reporting Processing
or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial
Product Categories
The following descriptions were developed by EPA to assist persons submitting
information in response to 40 CFR 705.15(c) and reported in Industrial Processing and Use
section (Section 4.6.4 or Section 4.7.2) and Consumer and Commercial Use section (Section
4.6.5 or Section 4.7.3) of the section 8(a)(7) reporting. Table D-3, Table D-4, Table D-5 and Table
D-6 include crosswalks between OECD standardized codes to be used for section 8(a)(7)
reporting and codes used for reporting to CDR.
For more information, see the Technical Support Document: "Harmonizing CDR
Functional and Product codes with OECD Functional, Product, and Article Codes," located in the
rulemaking record (EPA-HQ-OPPT-2018-0321).
Table D-l provides the type of processing or use operation (TPU) codes with descriptions of the
types of operations (see Section 4.6.4.2).
Table D-l. Type of Processing or Use Operation and Descriptions
Code
Type of Operation
Description
PC
Processing as a reactant
Chemical substance is used in chemical reactions for the
manufacturing of another chemical substance or product.
PF
Processing—incorporation into
formulation, mixture, or reaction
product
Chemical substance is added to a product (or product mixture)
prior to further distribution of the product.
PA
Processing—incorporation into
article
Chemical substance becomes an integral component of an article
distributed for industrial, trade, or consumer use.
PK
Processing—repackaging
Preparation of a chemical substance for distribution in commerce
in a different form, state, or quantity. This includes transferring
the chemical substance from a bulk container into smaller
containers. This definition does not apply to sites that only relabel
or redistribute the reportable chemical substance without
removing the chemical substance from the container
in which it is received or purchased.
U
Use—non-incorporative
activities
Chemical substance is otherwise used (e.g., as a chemical
processing or manufacturing aid).
D-l
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Table D-2 provides a crosswalk between Industrial Sector (IS) codes (see Section 4.6.4.3)
with North American Industry Classification System (NAICS) codes commonly used to classify
businesses.
Table D-2. Industrial Sector (IS) Code Descriptions with NAICS Crosswalk
NAICS
IS Code
IS Title
11
IS1
Agriculture, Forestry, Fishing and Hunting
211
IS2
Oil and Gas Drilling, Extraction, and Support Activities
213
212
IS3
Mining (except Oil and Gas) and Support Activities
22
IS4
Utilities
23
IS5
Construction
311
IS6
Food, beverage, and tobacco product manufacturing
312
313
IS7
Textiles, apparel, and leather manufacturing
314
315
316
321
IS8
Wood Product Manufacturing
322
IS9
Paper Manufacturing
323
IS10
Printing and Related Support Activities
32411
IS11
Petroleum Refineries
32412
IS12
Asphalt Paving, Roofing, and Coating Materials Manufacturing
324191
IS13
Petroleum Lubricating Oil and Grease Manufacturing
324199
ISM
All Other Petroleum and Coal Products Manufacturing
32511
IS15
Petrochemical Manufacturing
32512
IS16
Industrial Gas Manufacturing
32513
IS17
Synthetic Dye and Pigment Manufacturing
325182
IS18
Carbon Black Manufacturing
32518
IS19
All Other Basic Inorganic Chemical Manufacturing
325192
IS20
Cyclic Crude and Intermediate Manufacturing
32519
IS21
All Other Basic Organic Chemical Manufacturing
325211
IS22
Plastic Material and Resin Manufacturing
D-2
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
NAICS
IS Code
IS Title
325212
IS23
Synthetic Rubber Manufacturing
32522
IS24
Organic Fiber Manufacturing
3253
IS25
Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing
3254
IS26
Pharmaceutical and Medicine Manufacturing
32551
IS27
Paint and Coating Manufacturing
32552
IS28
Adhesive Manufacturing
3256
IS29
Soap, Cleaning Compound, and Toilet Preparation Manufacturing
32591
IS 30
Printing Ink Manufacturing
32592
IS31
Explosives Manufacturing
325991
IS32
Custom Compounding of Purchased Resin
325992
IS33
Photographic Film Paper, Plate, and Chemical Manufacturing
325998
IS34
All Other Chemical Product and Preparation Manufacturing
3261
IS35
Plastics Product Manufacturing
3262
IS36
Rubber Product Manufacturing
327
IS37
Nonmetallic Mineral Product Manufacturing (includes clay, glass, cement,
concrete, lime, gypsum, and other nonmetallic mineral product manufacturing)
331
IS38
Primary Metal Manufacturing
332
IS39
Fabricated Metal Product Manufacturing
333
IS40
Machinery Manufacturing
334
IS41
Computer and Electronic Product Manufacturing
335
IS42
Electrical Equipment, Appliance, and Component Manufacturing
336
IS43
Transportation Equipment Manufacturing
337
IS44
Furniture and Related Product Manufacturing
339
IS45
Miscellaneous Manufacturing
42
IS46
Wholesale and Retail Trade
44
45
48
49
51
IS47
Services
52
53
54
55
D-3
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
NAICS
IS Code
IS Title
56
61
62
71
72
81
92
IS48
Other (requires additional information)
D-4
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Table D-3 provides the 2020 CDR Product Category codes (based on OECD harmonized
codes) to be used for section 8(a)(7) reporting, with corresponding product category codes
from 2016 CDR reporting. The 2016 CDR codes are provided only as a reference to assist you if
your company has used these codes in past reporting. Do not use 2016 CDR codes for section
8(a)(7) reporting.
Table D-3. Product Category Codes
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Category
Code
Category
Chemical Substances in Furnishing, Cleaning, Treatment Care Products
CC101
Construction and building materials covering large
surface areas including stone, plaster, cement, glass and
ceramic articles; fabrics, textiles, and apparel
C101
Floor coverings
CC102
Furniture & furnishings including plastic articles (soft);
leather articles
C102
Foam seating and bedding
products
CC103
Furniture & furnishings including stone, plaster,
cement,glass and ceramic articles; metal articles; or
rubber articles
C103
Furniture and furnishings not
covered elsewhere
CC104
Leather conditioner
C104
Fabric, textile, and leather
products not covered
elsewhere
CC105
Leather tanning, dye, finishing, impregnation and care
products
CC106
Textile (fabric) dyes
CC107
Textile finishing and impregnating/surface treatment
products
CC108
All-purpose foam spray cleaner
C105
Cleaning and furnishing care
products
CC109
All-purpose liquid cleaner/polish
CC110
All-purpose liquid spray cleaner
CC111
All-purpose waxes and polishes
CC112
Appliance cleaners
CC113
Drain and toilet cleaners (liquid)
CC114
Powder cleaners (floors)
CC115
Powder cleaners (porcelain)
CC116
Dishwashing detergent (liquid/gel)
C106
Laundry and dishwashing
products
CC117
Dishwashing detergent (unit dose/granule)
CC118
Dishwashing detergent liquid (hand-wash)
CC119
Dry cleaning and associated products
D-5
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Category
Code
Category
CC120
Fabric enhancers
CC121
Laundry detergent (unit-dose/granule)
CC122
Laundry detergent (liquid)
CC123
Stain removers
CC124
Ion exchangers
C107
Water treatment products
CC125
Liquid water treatment products
CC126
Solid/Powder water treatment products
CC127
Liquid body soap
C108
Personal care products
CC128
Liquid hand soap
CC129
Solid bar soap
CC130
Air fresheners for motor vehicles
C109
Air care products
CC131
Continuous action air fresheners
CC132
Instant action air fresheners
CC133
Anti-static spray
C110
Apparel and footwear care
products
CC134
Apparel finishing, and impregnating/surface treatment
products
CC135
Insect repellent treatment
CC136
Pre-market waxes, stains, and polishes applied to
footwear
CC137
Post-market waxes, and polishes applied to footwear
(shoe polish)
CC138
Waterproofing and water-resistant sprays
Chemical Substances in Construction, Paint, Electrical, and Metal Products
CC201
Fillers and putties
C201
Adhesives and sealants
CC202
Hot-melt adhesives
CC203
One-component caulks
CC204
Solder
CC205
Single-component glues and adhesives
CC206
Two-component caulks
CC207
Two-component glues and adhesives
CC208
Adhesive/Caulk removers
C202
Paints and coatings
D-6
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Category
Code
Category
CC209
Aerosol spray paints
CC210
Lacquers, stains, varnishes and floor finishes
CC211
Paint strippers/removers
CC212
Powder coatings
CC213
Radiation curable coatings
CC214
Solvent-based paint
CC215
Thinners
CC216
Water-based paint
CC217
Construction and building materials covering large
surface areas, including wood articles
C203
Building/ construction
materials - wood and
engineered wood products
CC218
Construction and building materials covering large
surface areas, including paper articles; metal articles;
stone, plaster, cement, glass and ceramic articles
C204
Building/ construction
materials not covered
elsewhere
CC219
Machinery, mechanical appliances, electrical/electronic
articles
C205
Electrical and electronic
products
CC220
Other machinery, mechanical appliances,
electronic/electronic articles
CC221
Construction and building materials covering large
surface areas, including metal articles
C206
Metal products not covered
elsewhere
CC222
Electrical batteries and accumulators
C207
Batteries
Chemical Substances in Packaging, Paper, Plastic, Tovs, Hobbv Products
CC990
Non-TSCA use
C301
Food packaging
CC301
Packaging (excluding food packaging), including paper
articles
C302
Paper products
CC302
Other articles with routine direct contact during normal
use, including paper articles
CC303
Packaging (excluding food packaging), including rubber
articles; plastic articles (hard); plastic articles (soft)
C303
Plastic and rubber products
not covered elsewhere
CC304
Other articles with routine direct contact during normal
use including rubber articles; plastic articles (hard)
CC305
Toys intended for children's use (and child dedicated
articles), including fabrics, textiles, and apparel; or
plastic articles (hard)
C304
Toys, playground, and
sporting equipment
CC306
Adhesives applied at elevated temperatures
C305
D-7
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Category
Code
Category
CC307
Cement/concrete
Arts, crafts, and hobby
materials
CC308
Crafting glue
CC309
Crafting paint (applied to body)
CC310
Crafting paint (applied to craft)
CC311
Fixatives and finishing spray coatings
CC312
Modelling clay
CC313
Correction fluid/tape
C306
Ink, toner, and colorant
products
CC314
Inks in writing equipment (liquid)
CC315
Inks used for stamps
CC316
Toner/Printer cartridge
CC317
Liquid photographic processing solutions
C307
Photographic supplies, film,
and photochemicals
Chemical Substances in Automotive, Fuel, Agriculture, Outdoor Use Products
CC401
Exterior car washes and soaps
C401
Automotive care products
CC402
Exterior car waxes, polishes, and coatings
CC403
Interior car care
CC404
Touch up auto paint
CC405
Degreasers
C402
Lubricants and greases
CC406
Liquid lubricants and greases
CC407
Paste lubricants and greases
CC408
Spray lubricants and greases
CC409
Anti-freeze liquids
C403
Anti-freeze and de-icing
products
CC410
De-icing liquids
CC411
De-icing solids
CC412
Lock de-icers/releasers
CC413
Cooking and heating fuels
C404
Fuels and related products
CC414
Fuel additives
CC415
Vehicular or appliance fuels
CC416
Explosive materials
C405
Explosive materials
CC417
Agricultural non-pesticidal products
C406
Agricultural products (non-
pesticidal)
D-8
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Category
Code
Category
CC418
Lawn and garden care products
C407
Lawn and garden care
products
Chemical Substances in Products not Described bv Other Codes
CC980
Other (specify)
C909
Other (specify)
CC990
Non-TSCA use
C980
Non-TSCA use
D-9
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Table D-4 provides the Function Category codes based on OECD harmonized codes to be
used for section 8(a)(7) reporting, with corresponding Function Category codes from 2016 CDR
reporting. The CDR codes are provided only as a reference to assist you if your company has
used these codes in past reporting. Do not use CDR codes for section 8(a)(7) reporting.
Table D-4. Function Category Descriptions and Crosswalk: Section 8(a)(7) reporting
and 2016-2020 CDR
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Description
Code
Description
F001
Abrasives
U001
Abrasives
F002
Etching agent
F003
Adhesion/cohesion promoter
U002
Adhesives and Sealant Chemicals
F004
Binder
F005
Flux agent
F006
Sealant (barrier)
F007
Absorbent
U003
Adsorbents and Absorbents
F008
Adsorbent
F009
Dehydrating agent (desiccant)
F010
Drier
F011
Humectant
F012
Soil amendments (fertilizers)
U004
Agricultural Chemicals (non-pesticidal)
F013
Anti-adhesive/cohesive
U005
Anti-Adhesive Agents
F014
Dusting agent
F015
Bleaching agent
U006
Bleaching Agents
F016
Brightener
F017
Anti-scaling agent
U007
Corrosion inhibitors and antiscaling agents
F018
Corrosion inhibitor
F019
Dye
U008
Dyes
F020
Fixing agent (mordant)
F021
Hardener
U009
Fillers
F022
Filler
F023
Anti-static agent
U010
Finishing agents
F024
Softener and conditioner
F025
Swelling agent
D-10
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Description
Code
Description
F026
Tanning agents not otherwise specified
F027
Waterproofing agent
F028
Wrinkle resisting agent
F029
Flame retardant
U011
Flame retardants
F030
Fuel agents
U012
Fuels and fuel additives
F031
Fuel
F032
Heat transferring agent
U013
Functional fluids (closed systems)
F033
Hydraulic fluids
F034
Insulators
F035
Refrigerants
F036
Anti-freeze agent
U014
Functional fluids (open systems)
F037
Intermediate
U015
Intermediates
F038
Monomers
F039
Ion exchange agent
U016
Ion exchange agents
F040
Anti-slip agent
U017
Lubricants and lubricant additives
F041
Lubricating agent
F042
Deodorizer
U018
Odor agents
F043
Fragrance
F044
Oxidizing agent
U019
Oxidizing/reducing agents
F045
Reducing agent
F046
Photosensitive agent
U020
Photosensitive chemicals
F047
Photosensitizers
F048
Semiconductor and photovoltaic agent
F049
UV stabilizer
F050
Opacifer
U021
Pigments
F051
Pigment
F052
Plasticizer
U022
Plasticizers
F053
Plating agent
U023
Plating agents and surface treating agents
F054
Catalyst
U024
Process regulators
F055
Chain transfer agent
D-ll
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Description
Code
Description
F056
Chemical reaction regulator
F057
Crystal growth modifiers (nucleating agents)
F058
Polymerization promoter
F059
Terminator/Blocker
F060
Processing aids, specific to petroleum
production
U025
Processing aids, specific to petroleum production
F061
Antioxidant
U026
Processing aids, not otherwise listed
F062
Chelating agent
F063
Defoamer
F064
pH regulating agent
F065
Processing aids not otherwise specified
F066
Energy Releasers (explosives,
motivepropellant)
U027
Propellants and blowing agents
F067
Foamant
F068
Propellants, non-motive (blowing agents)
F069
Cloud-point depressant
U028
Solids separation agents
F070
Flocculating agent
F071
Flotation agent
F072
Solids separation (precipitating) agent, not
otherwise specified
F073
Cleaning agent
U029
Solvents (for cleaning or degreasing)
F074
Diluent
U030
Solvents (which become part of product
formulation or mixture)
F075
Solvent
F076
Surfactant (surface active agent)
U031
Surface active agents
F077
Emulsifier
F078
Thickening agent
U032
Viscosity adjustors
F079
Viscosity modifiers
F080
Laboratory chemicals
U033
Laboratory chemicals
F081
Dispersing agent
U034
Paint additives and coating additives not
described by other codes
F082
Freeze-thaw additive
F083
Surface modifier
F084
Wetting agent (non-aqueous)
F085
Aerating and deaerating agents
D-12
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Description
Code
Description
F086
Explosion inhibitor
U999
Other (specify)
F087
Fire extinguishing agent
F088
Flavoring and nutrient
F089
Anti-redeposition agent
F090
Anti-stain agent
F091
Anti-streaking agent
F092
Conductive agent
F093
Incandescent agent
F094
Magnetic element
F095
Anti-condensation agent
F096
Coalescing agent
F097
Film former
F098
Demulsifier
F099
Stabilizing agent
F100
Alloys
F101
Density modifier
F102
Elasticizer
F103
Flow promoter
F104
Sizing agent
F105
Solubility enhancer
F106
Vapor pressure modifiers
F107
Embalming agent
F108
Heat stabilizer
F109
Preservative
F110
Anti-caking agent
Fill
Deflocculant
F112
Dust suppressant
F113
Impregnation agent
F114
Leaching agent
F115
Tracer
F116
X-ray absorber
D-13
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR
reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Description
Code
Description
F999
Other (specify)
NOTE: For codes F085 - F116, no comparable crosswalk code existed in 2016 CDR
D-14
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Table D-5Table D-5 provides the Consumer and Commercial Product Category codes
based on OECD harmonized codes to be used for section 8(a)(7) reporting, with corresponding
consumer and commercial product category codes from 2016 CDR reporting. The CDR codes are
provided only as a reference to assist you if your company has used these codes in past
reporting. Do not use CDR codes for section 8(a)(7) reporting.
Table D-5. Consumer and Commercial Product Category Descriptions and Crosswalk
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
Chemical Substances in Furnishing, Cleaning, Treatment Care Products
CC101
Construction and building
materials covering large
surface areas including
stone, plaster, cement,
glass and ceramicarticles;
fabrics, textiles, and apparel
Cement flooring, stone tile,
mirrors, flooring or wall
materials, carpets, rugs,
tapestries
C101
Floor coverings
CC102
Furniture & furnishings
includingplastic articles (soft);
leather articles
Foam armchair, couch/sofa,
mattress(adult), mattress (infant),
mattress (child), sleeping bag,
beanbag chair
C102
Foam seating and
bedding products
CC103
Furniture & furnishings
including stone, plaster,
cement, glass and ceramic
articles; metal articles; or
rubber articles
Tables, chairs, benches, outdoor
furniture, or furniture feet
C103
Furniture and
furnishings not
covered elsewhere
CC104
Leather conditioner
Products applied to leather
surfaces to preserve and/or
restore strength, appearance,
and flexibility.
C104
Fabric, textile, and
leather products not
covered elsewhere
CC105
Leather tanning, dye, finishing,
impregnation and care
products
Products applied to the
surfaces of leather articles to
impart desirable properties.
CC106
Textile (fabric) dyes
Products applied to impart color(s)
to textiles.
CC107
Textile finishing and
impregnating/surface
treatment products
Products applied to the surfaces
of textiles to impart water or stain
resistances, flame resistance, but
not dyes.
D-15
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC108
All-purpose foam spray cleaner
Foams that are spray applied to
surfaces such as countertops,
tables, windows, and surfaces of
appliances.
CC109
All-purpose liquid
cleaner/polish
Liquids that are not spray
applied and are applied to
surfaces of furniture,
silverware, sinks, tubs,
carpeted floors, and hard-
surface floors. Note:
distinguish between "neat" and
"dilute" products.
CC110
All-purpose liquid spray cleaner
Liquids that are spray applied to
surfaces such as countertops,
tables, windows, and surfaces of
appliances.
CC111
All-purpose waxes and polishes
Waxes and other semi-solids
that are not spray applied and
are applied to the surfaces of
furniture (generally wooden
furniture) to improve shine
and/or impart stain resistance.
C105
Cleaning and
furnishing care
products
CC112
Appliance cleaners
Cleaners that are applied to
the interior of appliances such
as dishwashers, washing
machines, electronic
appliances, disposals, and
ovens).
CC113
Drain and toilet cleaners
(liquid)
Liquids applied to toilets
and/or drains that may remain
in the sewer line for a time but
ultimately go down the drain.
CC114
Powder cleaners (floors)
Powders that are applied to
carpets and rugs to clean or
deodorize.
CC115
Powder cleaners (porcelain)
Powders applied to sinks,
showers, and tubs to remove
dirt, soap scum, and mold.
D-16
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC116
Dishwashing detergent
(liquid/gel)
Liquid cleaners added to
dishwashing machines to
remove food residue from
dishes.
CC117
Dishwashing detergent (unit
dose/granule)
Powder or powder/liquid tablet
cleaners added to washing
machines to remove dirt from
clothing and
other textiles.
CC118
Dishwashing detergent
liquid (hand-wash)
Liquid cleaners added to sinks and
combined with water to remove
food residue from dishes.
CC119
Dry cleaning and associated
products
Products used to remove dirt
from clothing and other
textiles in non- aqueous
cleaning processes.
Laundry and
dishwashing
products
CC120
Fabric enhancers
Products which enhance fabrics.
Examples include liquid
products added to washing
machines or sheetsadded to
driers, bleach, film, lime and
rust removers.
C106
CC121
Laundry detergent (unit-
dose/granule)
Powder or powder/liquid tablet
cleaners added to washing
machinesto remove dirt from
clothing and other textiles.
C122
Laundry detergent (liquid)
Liquid cleaners added to
washing machines to remove
dirt from clothing and other
textiles.
CC123
Stain removers
Applied to clothing before
addition to laundry machine to
remove stains (can be gels,
liquids, or spray applications).
D-17
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC124
Ion exchangers
Point of use filters which may
be used by consumers in
homes (e.g., refrigerator filters
or pitcher filters) or in
commercial and industrial
settings to treat water for use
in these processes.
C107
Water
treatment
products
CC125
Liquid water treatment
products
Water treatment drops
CC126
Solid/powder water treatment
products
pH adjusters, filter media, water
treatment tablets
CC127
Liquid body soap
Liquid soap used for washing
entire body.
CC128
Liquid hand soap
Liquid soap used for washing
hands.
C108
Personal care products
CC129
Solid bar soap
Solid soap used for washing
hands and body.
CC130
Air fresheners for motor
vehicles
Aerosol spray and continuous
action air products used to
odorize or deodorize motor
vehicles.
CC131
Continuous action air
fresheners
Liquid, solid, gel diffuser, solid
incense products and scented
candle products that odorize
or deodorize air in indoor
environments.
C109
Air care products
CC132
Instant action air fresheners
Aerosol spray and incense
products that odorize or
deodorize air in indoor
environments.
CC133
Anti-static spray
Spray applied to eliminate or
reduce static electricity on
apparel.
Apparel and
CC134
Apparel finishing, and
impregnating/surface
treatment products
Products applied to the surfaces
of apparel to impart water or
stain resistances, flame resistance,
but not dyes.
C110
footwear care
products
D-18
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC135
Insect repellent treatment
Product applied to clothing to
repel insects.
CC136
Pre-market waxes, stains, and
polishes applied to footwear
Waxes, stains, and polishes
applied to footwear to impart
water resistance, improve
appearance and impart other
desirable properties.
CC137
Post-market waxes, and
polishes applied to footwear
(shoe polish)
Waxes and polishes applied to
footwear.
CC138
Waterproofing and water-
resistant sprays
Spray applied to impart water
resistance to apparel or
footwear.
Chemical Substances in Construction, Paint, Electrical, and Metal Products
CC201
Fillers and putties
Highly malleable materials used to
repair, smooth over, or fill minor
cracks and holes in building
surfaces.
CC202
Hot-melt adhesives
Adhesives (supplied in solid
cylindrical sticks and intended
for small applications)
designed to be melted and
dispensed through an electric
hot glue gun.
CC203
One-component caulks
Caulks (sealants) which are
premixed with their final
product formulation. Examples
include acrylic solvent-based,
butyl solvent- based, latex
water-based, silicone and
polyurethane.
C201
Adhesives and sealants
CC204
Solder
Metal alloys melted down to
permanently bond metal parts
together. Commonly used in
electronics, plumbing and
sheet metal work.
D-19
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC205
Single-component glues and
adhesives
Adhesives (packaged less than 8
ounces per bottle and intended
for small amount per use
applications such as
bookbinding) which are
premixed with their final
product formulation. Product
use and exposure to light,
humidity, or temperature
initiates chemical reaction and
cure. Examples include
anaerobic, cyanoacrylates, heat-
cure, moisture-cure, radiation-
cure, and silicones.
CC206
Two-component caulks
Caulks (sealants) which are
stored in two separate parts,
generally a base and an
activator. The activator is added
to the base and mixed before
application. Examples include
epoxy-solvent based silicone
and polyurethane.
CC207
Two-component glues and
adhesives
Adhesives (packaged in
containers smaller than 8
ounces per container and
intended for small applications)
which are stored in two
separate containers, generally a
resin and a hardener which are
then mixed
together to initiate chemical
reaction and cure. Examples
include epoxies,
methyl methacrylates, silicon
adhesives, and polyurethanes.
CC208
Adhesive/caulk removers
Products applied to surfaces to
unbind substances or remove
sealants and to clean the
underlying surface by
softening adhesives, caulks and
other glues so they can be
removed.
C202
Paints and coatings
D-20
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC209
Aerosol spray paints
Pressurized one-component paint
released with a propellant and
spray applied as a fine mist.
CC210
Lacquers, stains, varnishes
and floor finishes
Liquids applied to surfaces such as
floors, countertops, appliances,
furnishings, decking, and patios to
impart coloring or resistance to
fade, scuffing, marking, or wear.
CC211
Paint strippers/removers
Liquid product applied to
surfaces to remove paint,
coatings and other finishes and
also to clean the underlying
surface.
CC212
Powder coatings
Dry powder coating that does not
contain solvents and is cured
under heat to create a coating
film.
CC213
Radiation curable coatings
Coatings designed to cure onto
surface when exposed to
radiation such as ultraviolet or
electron beam radiation.
CC214
Solvent-based paint
Paints that have been
formulated to have a solvent
as the vehicle.
CC215
Thinners
Liquids to dilute paints and
coatings to obtain suitable
viscosity for paint application.
CC216
Water-based paint
Paints that have been
formulated to have water as
the main vehicle.
CC217
Construction and building
materials covering large
surface areas, including
wood articles
Floor decking, claddings, toys
outdoor equipment, walls,
flooring
C203
Building/
construction
materials - wood
and engineered
wood products
D-21
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC218
Construction and building
materials covering large
surface areas, including paper
articles; metal articles; stone,
plaster, cement, glass and
ceramic articles
Construction and building
materials; e.g. insulation panels,
wall papers, roof sheets, drinking
water pipes, sewer pipes, cement
flooring, mirrors
C204
Building/
construction
materials not
covered elsewhere
CC219
Machinery, mechanical
appliances,
electrical/electronic
articles
Refrigerators, washing machines,
vacuum cleaners, computers,
telephones, drills, saws, smoke
detectors, thermostats, radiators
C205
Electrical and
electronic products
CC220
Other machinery,
mechanical appliances,
electronic/electronic
articles
Large-scale stationary
industrial tools
CC221
Construction and building
materials covering large
surface areas, including
metal articles
Roof sheets, drinking water
pipes, sewer pipes
C206
Metal products not
covered elsewhere
CC222
Electrical batteries and
accumulators
Batteries
C207
Batteries
Chemical Substances in Packaging, Paper, Plastic, Tovs, Hobbv Products
CC990
Non-TSCA use
Items included under non-TSCA
use include food contact
articles, such as plastic wrap,
plastic dinner ware, food
storage, packaging containers.
C301
Food packaging
CC301
Packaging (excluding food
packaging), including paper
articles
Paper packaging
C302
Paper products
CC302
Other articles with routine
direct contact during normal
use, including paper articles
Nappies, feminine hygiene
products, adult incontinence
products, tissues, towels, toilet
paper, newspapers, books,
magazines, photographic paper
and negatives
D-22
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC303
Packaging (excluding food
packaging), including
rubber articles; plastic
articles (hard); plastic
articles (soft)
Phone covers, personal tablet
covers, styrofoam packaging,
bubble wrap
C303
Plastic and rubber
products not covered
CC304
Other articles with routine
direct contact during normal
use including rubber articles;
plastic articles (hard)
Gloves, boots, clothing, rubber
handles, gear lever, steering
wheels, handles, pencils,
handheld device casing
elsewhere
CC305
Toys intended for children's
use (and child dedicated
articles), including fabrics,
textiles, and apparel; or
plastic articles (hard)
Stuffed toys, blankets, comfort
objects, dolls, car, animals,
teething rings
C304
Toys, playground, and
sporting equipment
CC306
Adhesives applied at elevated
temperatures
Used at elevated temperatures
to melt and apply adhesive
which when cooled, hardens
and adheres the two substances
to one another. Examples
include solder and hot-melt
adhesive, see adhesive
definitions.
CC307
Cement/concrete
Used to create and support
structures and pathways.
CC308
Crafting glue
Used to adhere two
substances to one another,
see adhesives definitions.
C305
Arts, crafts, and
hobby materials
CC309
Crafting paint (applied to body)
Used to add color to fingers,
faces, or other body parts.
CC310
Crafting paint (applied to craft)
Used to add color to crafting
substances, see paints definitions.
CC311
Fixatives and finishing spray
coatings
Fixatives, shellacs, or other
spray applied coatings intended
to cover or hold other arts and
crafts materials to a surface.
CC312
Modelling clay
Used to mold or sculpt.
D-23
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC313
Correction fluid/tape
Fluids used to cover up
permanent ink so that
corrections can be made.
C306
Ink, toner, and
colorant products
CC314
Inks in writing equipment
(liquid)
Liquids used in pens, markers,
or other writing instruments.
CC315
Inks used for stamps
Inks incorporated into stamp
or ink pads used to apply ink
to paper and other substrates.
CC316
Toner/printer cartridge
Pigmented liquids, toners or
powders contained in
cartridges, bottles, or other
dispensers used in printers and
copy machines. This category
includes printing inks for
commercial applications.
CC317
Liquid photographic processing
solutions
Chemicals used in the stop
bath, fixing bath, hardener, or
stabilizer to develop
photographs.
C307
Photographic
supplies, film, and
photochemicals
Chemical Substances in Automotive, Fuel, Agriculture, Outdoor Use Products
CC401
Exterior car washes and soaps
Cleaning agents used to
remove dirt and grime.
C401
Automotive
care
products
CC402
Exterior car waxes, polishes,
and coatings
Used to increase the shine, add
UV protection and scratch
resistance to automotive paints,
or provide waterproofing/resistant
properties to windshields and
automotive window glass.
CC403
Interior car care
Cleaning agents used to
remove stains from interior
carpets and textiles, rubber,
vinyl, or plastic.
CC404
Touch up auto paint
Used to paint over scratches or
cover up dent marks on
automotive paints.
CC405
Degreasers
Product that remove greases or
oils from hard surfaces,
machinery, or tools.
C402
Lubricants and greases
D-24
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
CC406
Liquid lubricants and greases
Liquids that reduce friction, heat
generation and wear between
surfaces.
CC407
Paste lubricants and greases
Pastes that reduce friction,
heat generation and wear
between surfaces.
CC408
Spray lubricants and greases
Sprays that reduce friction, heat
generation and wear between
surfaces.
CC409
Anti-freeze liquids
Reduce the freezing point of
surfaces.
CC410
De-icing liquids
Reduce the freezing point of
surfaces in order to remove ice.
C403
Anti-freeze and de-
CC411
De-icing solids
Ice melting crystals, rock salts
icing products
CC412
Lock de-icers/releasers
Applied within locks to remove
ice so that doors can be
opened.
CC413
Cooking and heating fuels
Pressurized liquid fuels
generally contained within
metal containers and
released directly into an
appliance in a controlled way
to prevent direct release.
C404
Fuels and related
products
CC414
Fuel additives
Added to fuels to improve
properties such as stability,
corrosion, oxygenation, and
octane rating.
CC415
Vehicular or appliance fuels
Liquid fuels stored in containers
and refilled into vehicles or
appliances as needed.
CC416
Explosive materials
Chemical substances capable of
producing a sudden expansion
usually accompanied by the
production of heat and large
changes in pressure upon
initiation, that are intended for
consumer or commercial use.
Examples include pyrotechnics,
C405
Explosive materials
D-25
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
high explosives and
propellants, igniter, primer,
initiatory, illuminants, smoke
and decoy flares, and
incendiaries.
CC417
Agricultural non-
pesticidal products
Products used to increase the
productivity of crops, or aid in
the harvesting of crops.
Examples include fertilizers,
colorants, and application aids,
and soil amendments (e.g.
products added to soil to adjust
pH, retain water or alter other
properties).
C406
Agricultural
products (non-
pesticidal)
CC418
Lawn and garden care products
Chemical substances contained
in lawn, garden, outdoor or
potted plant, and tree care
products that are intended for
consumer or commercial use
should be reported under this
code. Examples of lawn and
garden care products include
fertilizers and nutrient
mixtures, soil amendments,
mulches, pH adjustors, water
retention beads, vermiculite,
and perlite. Excludes any
substance that is
manufactured, processed, or
distributed in commerce for
use as a pesticide as defined in
the Federal Insecticide,
Fungicide, and Rodenticide Act.
C407
Lawn and garden care
products
Chemical Substances in Products not Described bv Other Codes
CC980
Other (specify)
Provide description of use.
C909
Other (specify)
CC990
Non-TSCA use
Chemical substances contained
in products intended for
consumer or commercial use
that are not regulated by TSCA
should be reported under this
code. Examples of products
with non-TSCA uses include
C980
Non-TSCA use
D-26
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: Section 8(a)(7) codes
Column B: 2016 CDR codes
Code
Name
Description
Code
Name
pesticide, insecticide,
rodenticide and fungicide
formulations; food or drink for
humans or animals; articles
intended for use in the
diagnosis, cure, mitigation,
treatment, or prevention of
disease in humans or animals;
substances intended to be
applied to the human body
other than soap; any radioactive
source material, special nuclear
material, or byproduct material;
pistols, revolvers, fire arms,
or ammunition; and tobacco or
tobacco products.
D-27
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Table D-6 provides examples of products intended for use by children, including 2020
CDR (OECD-based) codes to be used for section 8(a)(7) reporting as well as 2016 CDR codes.
This table is meant to help you identify products intended for use by children and may not
include all products intended for use by children. The 2016 CDR codes in this table are provided
only as a reference to assist you if your company has used these codes in past reporting. Do not
use 2016 CDR codes for section 8(a)(7) reporting.
Table D-6. Examples of Products Intended for Use by Children
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: section 8(a)(7) codes
Column B: 2016 CDR
codes
Examples
Codes
Category
Code
Category
Chemical Substances in Furnishings, Cleanings, Treatment Care Products
CC102
Furniture & furnishings including Plastic
articles (soft); Leather articles
C102
Foam seating and
bedding products
Child's car seat, children's
sheets
CC103
Furniture & furnishings including Stone,
plaster, cement, glass and ceramic articles;
Metal articles; or Rubber articles
C103
Furniture and
furnishings not
covered
elsewhere
Baby cribs, changing tables
CC106
Textile (fabric) dyes
C104
Fabric, textile,
and leather
products not
covered
elsewhere
Children's clothing
CC107
Textile finishing and impregnating/surface
treatment products
Children's clothing,
children's sheets, child's
car seat
CC127
Liquid body soap
C108
Personal
care
products
Baby shampoo, children's
bubble bath
Chemical Substances in Construction, Paint, Electrical and Metal Products
CC219
Machinery, mechanical appliances,
electrical/electronic articles
C205
Electrical
and
electronic
products
Electronicgames, remote
control cars
CC222
Electrical batteries and accumulators
C207
Batteries
Batteries used in toys
Chemical Substances in Packaging, Paper, Plastic, Hobbv Products
CC302
Other articles with routine direct contact
during normal use, including paper
articles
C302
Paper products
Diapers, baby wipes,
coloring books
D-28
-------
Appendix D. Descriptions of Codes for Reporting Processing or Use Operations, Industrial Sectors, Function
Categories, and Consumer and Commercial Product Categories
Use column A for all reporting. Column B shows 2016 CDR codes, which may have been used for CDR reporting.
Column A: section 8(a)(7) codes
Column B: 2016 CDR
codes
Examples
Codes
Category
Code
Category
CC305
Toys intended for children's use (and
child dedicated articles), including
Fabrics, textiles, and apparel; or Plastic
articles (hard)
C304
Toys, playground,
and sporting
equipment
Pacifiers, toy trucks, dolls,
toy cars, wagons, action
figures, balls, swing sets,
slides, skates, baseball
gloves, kid's rake
CC306
Adhesives applied at elevated
temperatures
C305
Arts, crafts, and
hobby materials
Craft glue for a hot glue
gun
CC308
Crafting glue
Craft glue
CC309
Crafting Paint (applied to body)
Chemicals used to add
color to body paint,
finger paints
D-29
------- |