TSCA Chemical Services in the USA

Pre-Manufacture Notification (PMN)

Determination of TSCA Inventory Status
CSI can conduct a search to determine if your substance is listed on the Toxic Substances Control Act (TSCA) Inventory. This is essential to identify any new chemical substance which is not on the TSCA Inventory, or otherwise excluded from notification.

BFI Request for Chemicals Not Found on TSCA Inventory
CSI can support a “Bona Fide Intent” (BFI) search for chemical substances on the Inventory which have confidential identities by generic names. We can guide you on required information for such search.

Substances Excluded from Notification
CSI can help you determine if your substance is exempted from PMN Notification. We can advise you if the subject chemical falls in one of the following categories: statutory excluded materials, research and development (R&D) substances, test-marketing exemption (TME), low-volume exemption (LVE), polymer exemption, and/or low release and exposure (LoREX) exemption.

Preparation & Submission of PMN
CSI can complete the necessary PMN forms and appendices, including required test data and claims of confidentiality. Our service includes consultation on your behalf with the EPA prior to PMN submission and during notice review. We can also place and monitor additional testing that may be deemed necessary by EPA’s review.

Chemical Data Reporting (CDR)

[CDR: Extension of the 2020 Submission Period – The submission period for the 2020 CDR will be from September 30, 2020, to November 30, 2020.]

The purpose of Chemical Data Reporting (CDR), formerly known as Inventory Update Reporting (IUR), is to collect quality screening-level, exposure-related information on chemical substances and to make that information available for use by EPA and, to the extent possible, the public. The rule requires manufacturers and importers to provide EPA with information on the production and use of chemicals in commerce in large quantities.

Who Must Report?
Manufacturers (including importers) are required to report if they meet certain production volume thresholds, generally 25,000 lbs or more of a chemical substance at any single site.

Chemicals Exempt From Reporting
Manufacturers (including importers) may not be required to report information on certain chemicals to CDR because of the type of chemical or because of the manner of manufacture (including import) or use of the chemical.

Manufacturers Exempt From Reporting
Small manufacturers (including importers) who meet one of the following EPA published requirements are generally exempt from CDR requirements.

Submitting CDR Data
The CDR regulation requires all companies to report data electronically using e-CDRweb, the CDR web-based reporting tool, and EPA’s Central Data Exchange (CDX) system.

CSI can assist businesses who are required to comply with the CDR regulation.  CSI has a thorough understanding of the TSCA Inventory and the criteria used to determine the listing of a substance on the TSCA Inventory.