U.S. Environmental Protection Agency
May 2020
TSCA Chemical Data Reporting
Fact Sheet: Kraft Pulp and Paper Process
This fact sheet provides guidance on Chemical Data Reporting (CDR) rule requirements related to
Kraft pulp and paper mill chemical recovery processes. Specifically, this fact sheet seeks to provide
guidance for Kraft pulp and paper mill facilities to accurately characterize reportable chemical
streams as required under the CDR rule (40 CFR 711).
The primary goal of this document is to help the regulated community comply with the CDR rule
requirements. 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).
The CDR rule, issued under the Toxic Substances Control Act (TSCA), requires manufacturers
(including importers) to give EPA information on the chemicals they manufacture domestically or
import into the United States. EPA uses the data, which provides important screening-level
exposure related information, to help assess the potential human health and environmental effects
of these chemicals and makes the non-confidential business information it receives available to
the public.
Kraft Pulping Process under the CDR Rule
Kraft pulp and paper sites may be required to report manufactured chemical substances under
the CDR rule. Reporting under the CDR rule is based on the manufacture (including import) of
chemical substances (see 40 CFR 711.8). It is important to note as well that the act of
processing or using one chemical substance may result in the manufacture of another chemical
substance. In such cases, persons who process or use chemical substances may be subject to
reporting requirements under CDR: not with respect to the chemical substance that they
processed or used, but with respect to the chemical substance that they manufactured.
Typically, the Kraft pulping cycle manufactures chemical substances that may be considered
products, byproducts, or intermediates. This fact sheet describes the Kraft pulping process and
how to determine whether certain chemical substances are exempt from CDR reporting. In April
2020, EPA added two new byproduct exemptions to the CDR rule.1 This fact sheet includes a
discussion of those new exemptions as well as already-existing exemptions associated with
intermediates and byproducts.
1 Toxic Substances Control Act (TSCA) Chemical Data Reporting Revisions Under TSCA Section 8(a) (Docket ID
No. EPA-HQ-QPPT-2018-0321-0118).
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1. What is a product?
For the purposes of CDR, a product is considered to be a chemical substance that is intentionally
manufactured (e.g., for distribution into commerce or for the manufacturer's own use) for commercial
purposes (i.e., with the purpose of obtaining an immediate or eventual commercial advantage for the
manufacturer or importer). As a process input, a product would serve a specific commercial function.
2. What is a byproduct?
A byproduct is "a chemical substance produced without a separate commercial intent during the
manufacture, processing, use, or disposal of another chemical substance(s) or mixture(s)." See 40
CFR 704.3, referenced by 40 CFR 711.3.
A byproduct is manufactured for commercial purposes since it is part of the manufacture of a
chemical product for a commercial purpose, regardless of whether the byproduct itself has
commercial value.2
3. What is an intermediate?
An intermediate is "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." See 40 CFR
704.3, referenced by 40 CFR 711.3.
In considering whether a chemical substance is an intermediate, EPA generally thinks of an
intermediate as a kind of "building block" precursor chemical used to make what is, at least to some
degree, a structurally related product. A reaction sequence containing an intermediate could be
represented as A B C, where A is an initial feedstock that is transformed into B which is then
transformed into C, the product. The product C is built upon the chemical structure/composition of B,
which is built upon the chemical structure/composition of A. Substance B therefore can be
considered an intermediate for making C. There may be reagents or other reactants involved in
transforming A to B or B to C, but such reagents or other reactants are not typically viewed as
intermediates because they are not themselves chemically transformed into the intended chemical
products and they are not added to alter the rate of a reaction, instead they are often added to cause
a desired chemical transformation.
4. What is a non-isolated intermediate?
A non-isolated intermediate is "any intermediate that is not intentionally removed from the equipment
2 Manufacture for commercial purposes means: (1) To import, produce, or manufacture with the purpose of obtaining an
immediate or eventual commercial advantage for the manufacturer, and includes among other things, such "manufacture"
of any amount of a chemical substance or mixture:
(i) For commercial distribution, including for test marketing.
(ii) For use by the manufacturer, including use for product research and development, or as an intermediate.
(2) Manufacture for commercial purposes also applies to substances that are produced coincidentally during the
manufacture, processing, use, or disposal of another substance or mixture, including both byproducts that are separated
from that other substance or mixture and impurities that remain in that substance or mixture. Such byproducts and
impurities may, or may not, in themselves have commercial value. They are nonetheless produced for the purpose of
obtaining a commercial advantage since they are part of the manufacture of a chemical product for a commercial purpose.
(40 CFR 704.3, referenced by 40 CFR 711.3)
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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. Mechanical or gravity transfer through a closed system is not
considered to be intentional removal, but storage or transfer to shipping containers isolates the
substance by removing it from process equipment in which it is manufactured." See 40 CFR 704.3,
referenced by 40 CFR 711.3.
Note that accumulating a chemical in any vessel, regardless of whether it is a flow-through in-line
vessel, for reasons that are not necessary to the process's technical/chemical success but rather to
keep the operation moving in the case of an unexpected interruption in the supply as a matter of
plant convenience, is considered by EPA to be storage and isolation.
Intermediates and Byproducts under the CDR Rule
Reporting under the CDR rule may also extend to chemical intermediates and byproducts that are
manufactured in the course of typical Kraft pulp and paper activities, including in relation to chemical
recovery processes inherent to the manufacturing cycle. This section discusses the reporting
requirements under the CDR rule for intermediates and byproducts generated during the Kraft
pulping cycle. This document does not cover chemicals from other processes which may be used in
paper production. Table 1 identifies representative examples of reportable and non-reportable
intermediates and byproducts from Kraft pulp and paper activities.
1. When is a byproduct reportable?
A byproduct is generally reportable when it is used for a non-exempt commercial purpose.
Even though a byproduct was manufactured for commercial purposes, it might or might not be used
for particular commercial purposes after it is manufactured. The manufacture of a byproduct is
exempt from reporting if the byproduct is not "used for commercial purposes." (40 CFR 720.30(h)(2),
referenced by § 711.10(c))3
There are other circumstances where a byproduct may be exempt:
• The manufacture of a byproduct is also exempt from reporting if its only commercial purpose is
for use by public or private organizations that:
(1) Burn it as a fuel,
(2) Dispose of it as a waste, including in a landfill or for enriching soil, or
(3) Extract component chemical substances from it for commercial purposes. (This exclusion
only applies to the byproduct; it does not apply to the component substances extracted
from the byproduct.) (40 CFR 720.30(g), referenced by § 711.10(c))
3 Note that "commercial purpose" refers to the broad definition in 40 CFR 704.3 ("the purpose of obtaining an immediate
or eventual commercial advantage"). It is not synonymous with the narrower definition of "commercial use" at 40 CFR
711.3, which is only intended for further subcategorizing reportable uses (in Part III reporting) between industrial,
commercial, and consumer settings.
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• For certain listed manufacturing processes, the listed
byproducts are exempt when recycled or otherwise
used within a site-limited, physically enclosed system
that is part of the same overall manufacturing process
from which the byproduct substance was generated,
and when the site is reporting the byproduct or a
different chemical substance that was manufactured
from the recycled byproduct or manufactured in the
same overall manufacturing process (40 CFR
711.10(d)(1)). For the Kraft pulp and paper industry,
EPA listed three of the industries byproduct streams
as potentially exempt: black liquor, black liquor
oxidized, and calcium carbonate.
• The manufacturing of byproducts may be exempt from
reporting if the byproducts are manufactured solely in certain equipment (i.e., (i) Pollution control
equipment or (ii) Boilers used to generate heat or electricity for that site) when that equipment is
not integral to the chemical manufacturing processes of the site (40 CFR 711.10(d)(2)).
2. When is an intermediate reportable?
Intermediates are reportable under the CDR rule unless the chemical substance or chemical process
stream meets the regulatory definition of a non-isolated intermediate or is otherwise exempted at 40
CFR 720.30 (h) (referenced by 40 CFR 711.10(c)). For example, in the Kraft pulp and paper industry
green liquor is not reportable when it is manufactured and used in a continuous process and in a
manner that it is non-isolated. See Table 1 for additional information.
Kraft Pulp and Paper Reporting under the CDR Rule
The Kraft pulping cycle is a chemical recovery and reuse cycle that produces several different
streams. Generally, the pulping cycle begins with the use of white liquor to break down the pulp to
release lignin, allowing the resulting cellulose fibers (now lignin-free) to be used for paper production.
This process results in the production of black liquor as a byproduct. The black liquor byproduct is
used to manufacture green liquor. Calcium oxide is used to turn the green liquor into white liquor,
resulting in the production of calcium carbonate as a byproduct. In a side process, the calcium
carbonate is recycled to produce calcium oxide. Figure 1 provides a process flow diagram of the Kraft
pulping cycle. Table 1 provides guidance on whether each stream is reportable or exempt from CDR
rule reporting obligations:
Listed Manufacturing Processes:
As of 2020, the listed manufacturing
processes and certain related
byproduct substances are:
• Portland cement manufacturing, and
• Kraft pulping process
(40 CFR 711.10(d)(1)(i)).
The public may petition for
amendments to this list of industrial
processes and associated byproducts
(40 CFR 711.10(d)(1)(H)). For more
information, see www.epa.gov/cdr.
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Kraft Chemical Recovery & Recycle
Stream 2
( '.i i iki i iiay b<*
CfAr-rulrtl
yjmc >vtttnn)
Commercial Product
Stream 6
Stream 5
Stream 1
Stream 4
Stream 3
:ort( en traced
bfack liqtwr
dry 6*> 80S
black fcquor
dry solids 1«-
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Figure 1. Kraft Pulping and Recycling Process4
While EPA describes CDR reporting requirements in this fact sheet, individual facilities must compare
their operations to this guidance to ensure that the appropriate reporting exemptions truly apply to
their specific processes.
4 American Forest & Paper Association Comment Letter (Docket ID No. EPA-HQ-OPPT-2018-0321-0109)
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Table 1: 2020 CDR Reporting Requirements for Select Examples of Kraft Pulp and Paper
Activities3
Stream
Number
Chemical
Substance
Generalized Process
Description
2020 CDR Reporting Requirement1
1
Black liquor
(CASRN
66071-92-9)
Sulfite liquors and Cooking
liquors, spent (CASRN 66071-
92-9, referred to by industry as
black liquor), is a byproduct
resulting from the pulping
process and is separated from
the commercial product (i.e.,
cellulose) via a washing
process. The resulting
byproduct is concentrated and
sent through the recovery
furnace to generate green
liquor.
Not Reportable for CDR purposes when
this byproduct is recycled or otherwise
used within a site-limited, enclosed
system.b
Reportable if this byproduct is not
recycled or used to manufacture another
chemical substance within an enclosed
system at the same site.c
2
Black liquor,
oxidized
(CASRN
68514-09-0)
Sulfite liquors and Cooking
liquors, spent (CASRN 66071-
92-9, referred to by industry
as black liquor) is oxidized at
some sites to facilitate odor
reduction during combustion
in the recovery furnace,
resulting in Sulfite liquors and
Cooking liquors, spent,
oxidized (CASRN 68514-09-0,
referred to by industry as
black liquor, oxidized). Other
than odor reduction at the
manufacturing site, the
oxidation of the byproduct
serves no commercial
purpose separate from that of
the black liquor.
Not Reportable for CDR purposes when
this byproduct is recycled or otherwise
used within a site-limited, enclosed
system.b
Reportable if this byproduct is not
recycled or used to manufacture another
chemical substance within an enclosed
system at the same site.c
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Table 1: 2020 CDR Reporting Requirements for Select Examples of Kraft Pulp and Paper
Activities3
Stream
Number
Chemical
Substance
Generalized Process
Description
2020 CDR Reporting Requirement1
3
Green liquor
(CASRN
68131-30-6)
Sulfite liquors and Cooking
liquors, green (CASRN 68131-
30-6, referred to by industry as
green liquor) is produced when
black liquor or black liquor,
oxidized is burned for energy
recovery in the Kraft cycle and
the liquefied inorganic
chemicals drained from the
bottom of the energy recovery
furnace (also known as energy
recovery furnace smelt) are
dissolved in water.
Green liquor subsequently
undergoes reaction with
calcium oxide to form white
liquor. Green liquor is
transformed in whole or in part
to intentionally manufacture
another chemical substance.
As used in the pulping cycle,
this substance is an
intermediate.
Not Reportable for CDR purposes when
this intermediate is manufactured and
used in a continuous process and in a
manner that it is non-isolated.
Reportable if it is not a non-isolated
intermediate.
NOTE: Isolation can occur when green
liquor is diverted into flow-through storage
tanks (e.g., to allow settling of solids) and
held or stored for a period of time in
excess of the time technically needed to
successfully produce the green liquor. For
example, holding or storing the green
liquor for delayed or future use in the
production of white liquor would be
considered isolation.
4
Lime or
Calcium oxide
(CASRN
1305-78-8)
Calcium oxide (CASRN 1305-
78-8 referred to by industry as
lime) is produced when the
calcium carbonate byproduct is
heated in the lime kiln to drive
off carbon dioxide (CO2).
Calcium oxide is then used as
a reagent in a reaction with
green liquor to form white
liquor Calcium oxide is
transformed in whole or in part
to intentionally manufacture
another chemical substance.
As used in the pulping cycle,
this substance that is itself
produced in the same overall
Kraft process manufacturing
equipment can be considered
an intermediate for CDR
purposes.
Not Reportable for CDR purposes if it is
an intermediate and consumed in reaction
with green liquor in a continuous process
and in a manner that is not isolated.
Reportable if it is not a non-isolated
intermediate.
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Table 1: 2020 CDR Reporting Requirements for Select Examples of Kraft Pulp and Paper
Activities3
Stream
Number
Chemical
Substance
Generalized Process
Description
2020 CDR Reporting Requirement1
5
Calcium
carbonate
(CASRN 471-
34-1)
Calcium carbonate, a
byproduct of using lime to turn
green liquor into white liquor
using a causticizing reaction,
is washed and sent to a lime
kiln to regenerate calcium
oxide for use in the
causticizing reaction.
Not Reportable for CDR purposes when
this byproduct is recycled or otherwise
used within a site-limited, enclosed
system.b
Reportable if this byproduct is not
recycled or used to manufacture another
chemical substance within an enclosed
system at the same site.c
6
White liquor
(CASRN
68131-33-9)
White liquor is reacted with
wood chips, through
application of high temperature
and pressure, to break down
the pulp and release lignin
(CASRN 9005-53-2), allowing
the resulting cellulose fibers
(now lignin-free) to be used for
paper production. Black liquor
is a byproduct of this reaction.
Reportable. White liquor is the product of
a series of reactions, starting with black
liquor and ending with white liquor.
a Note that the guidance is generally applicable to most Kraft pulp and paper mills; however, each site will have to evaluate
their process to ensure their process stream meets the CDR reporting and exemption requirements.
b Byproduct substances listed in 40 CFR 711.10(d)(l)(i) are not subject to reporting under CDR when recycled or otherwise
used within a site-limited, physically enclosed system that is part of the same overall manufacturing process from which
the byproduct substance was generated, and when the site is reporting the byproduct or a different chemical substance
that was manufactured from the recycled byproduct or manufactured in the same overall manufacturing process. (40 CFR
711.10(d)(1))
cYour chemical production can be bifurcated between reportable and not reportable amounts. Report only the volume
that meets the reportable requirements.
For further information:
To access copies of additional fact sheets and other CDR information, visit www.epa.gov/cdr. These
documents might be of particular interest:
• For additional information about byproducts, see Chemical Data Reporting Byproduct and
Recycling Scenarios.
• For additional information about non-isolated intermediates, see TSCA Chemical Data
Reporting Fact Sheet: Non-Isolated Intermediates.
If you have questions about CDR, you can contact the TSCA Hotline by phone at 202-554-1404 or
e-mail your question to eCDRweb@epa.gov.
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