Chemical Data Reporting (CDR) is the four-year volume reporting cycle required under TSCA Section 8(a). US manufacturers and importers of chemicals on the TSCA Inventory must report annual production or import volumes during a specified reporting window. The data feeds the EPA’s risk-prioritisation work and the public-facing TSCA Inventory volume bands.
Who must report
Any US manufacturer or importer of a TSCA-Inventory-listed chemical at or above the reporting threshold during any of the four reporting years in the cycle. The default threshold is 25,000 pounds (11,340 kg) per site per year of production or import. For chemicals on the EPA’s Active List (currently undergoing risk evaluation) the threshold drops to 2,500 pounds (1,134 kg) per site per year.
If your annual import of a chemical at a single port-of-entry / warehouse site is at or above the threshold for any reporting year, you have a CDR filing obligation for that chemical.
What must be reported
The 2024 CDR covering reporting years 2020-2023 required filing of:
- Chemical identity (CAS number, name)
- Annual volume produced or imported (pounds) for each of the four years
- Site information (manufacturing or import site location)
- Industrial processing and use information
- Commercial and consumer use information
- Worker exposure data (number of workers, average hours per shift)
- Production volume for the most recent year detailed; prior years can be summarised
The filing is online via EPA’s Central Data Exchange (CDX). The data fields are extensive, a complete CDR submission for a single chemical typically takes 4 to 8 hours of preparation time, more if the importer’s own records are not well-kept.
The next cycle
CDR cycles run on a four-year cadence. The next CDR submission window is in 2028, covering reporting years 2024-2027. Importers should be capturing volume data now in a way that allows easy CDR extraction in 2028. Reconstructing four years of import volumes from old customs entries under deadline pressure is the most common late-filing failure mode.
Penalties for late or missing filings
CDR is a Section 8(a) requirement and non-compliance is a TSCA violation. Civil penalties for CDR failures can reach USD 47,000 per day per violation under the EPA’s current penalty schedule. The EPA has been more active on CDR enforcement in recent years, particularly for importers of chemicals on the Active List undergoing risk evaluation.
Practical sourcing notes
For US importers we work with on chemicals that may approach the CDR threshold, we provide annual import-volume summaries by CAS number and site at year-end. The summary covers each batch shipped, the receiving port and warehouse site, the kilogram volume, and the reporting-year total. The importer can pull straight from those summaries when CDR season opens.
For chemicals on the EPA’s Active List with the 2,500-pound threshold, we flag the cargo at booking. A small order, one or two IBCs, can put a buyer over the threshold quickly. Knowing this in advance lets the buyer either keep volumes below threshold (split orders across sites or quarters) or accept the CDR obligation deliberately.
What CDR captures and what it does not
The CDR rule captures domestic manufacturer and importer-of-record data on production and import volumes, plus information on processing and downstream-use patterns where known. The rule does not capture full supply-chain confidentiality data; the EPA permits filers to claim Confidential Business Information (CBI) status on specific data fields. CBI claims must be substantiated and re-substantiated at each reporting cycle.
For an importer of Chinese chemicals, the CDR filing requires data the Chinese factory does not have visibility into: the US-side downstream processors, the end-product applications, the US sites where the chemical is processed or used. The importer must collect this information from US customers and downstream processors. For multi-tier supply chains where the importer is several layers removed from the actual end use, gathering accurate downstream-use data is one of the harder operational aspects of CDR compliance.
CDR enforcement and penalty exposure
CDR violations carry administrative penalties under TSCA Section 16 of up to USD 47,357 per violation per day at 2026 rates. Late filing, incomplete filing, and CBI substantiation failures all attract penalty exposure. EPA enforcement of CDR has tightened since 2020 with several seven-figure settlements published. For an importer running multi-substance procurement, the cost of getting CDR wrong can substantially exceed the cost of running the compliance programme correctly. Treating CDR as a routine annual exercise rather than an afterthought is the right operational stance.
Related terms
TSCA is the parent statute. Section 5 PMN is the pre-introduction filing for new chemicals; CDR is the post-introduction volume report. MSDS Section 1 should reflect the importer of record, who is the entity with the CDR obligation.