What is the tonnage threshold for TSCA on diammonium phosphate?

CDR (Chemical Data Reporting) threshold: 25,000 lb (11,340 kg) manufactured or imported per site per year triggers reporting in the next CDR cycle

CAS 7783-28-0 · TSCA · United States of America

Diammonium phosphate under TSCA

(NH4)2HPO4 · 磷酸二铵

Status: Listed. Diammonium phosphate is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active. No PMN is required. DAP is regulated by USDA at the state level for fertiliser registration (state-by-state Fertilizer Inspection Programs). No DEA scheduling, no EPA RMP threshold listing. Section 301 List 3 25% additional duty applies to Chinese-origin DAP (HS 310530). NO active US AD/CVD case on Chinese-origin DAP; the active US AD case (initiated 2020) covers Russian and Moroccan DAP / MAP, not Chinese.

The US DAP lane is regulatorily moderate: TSCA-listed, no DEA scheduling, no RMP threshold listing, no Prop 65 listing for DAP itself, no current AD/CVD on Chinese-origin DAP. The dominant practitioner-facing compliance work is USDA state-level fertiliser registration (state-by-state, AAPFCO standards) and Section 301 List 3 25% additional duty pricing. The 2020-2021 US AD/CVD case on Russian and Moroccan DAP / MAP (definitive orders since 2021) shifts US import volume toward Chinese supply, but the Section 301 List 3 25% additional duty caps Chinese competitiveness vs Mosaic and Nutrien domestic supply. Watershed-specific EPA Clean Water Act regulations (Chesapeake Bay, Mississippi River Delta) restrict DAP application in vulnerable agricultural zones. Coal-fed Chinese ammonia upstream raises Scope 3 carbon concern for some US agricultural buyers with sustainability commitments.

Listing and threshold

Substance	Diammonium phosphate (CAS 7783-28-0), (NH4)2HPO4
Regime	US Toxic Substances Control Act (TSCA), administered by EPA
Jurisdiction	United States of America
Status	Listed
Tonnage threshold	CDR (Chemical Data Reporting) threshold: 25,000 lb (11,340 kg) manufactured or imported per site per year triggers reporting in the next CDR cycle

Classifications under this regime

NOT subject to TSCA Section 4 test rule
NOT currently subject to TSCA Section 6 unreasonable-risk evaluation
NOT on the TSCA Section 5(a)(2) Significant New Use Rule list
OSHA Hazard Communication Standard (HCS): typically NOT classified as hazardous (dust nuisance only)
No substance-specific OSHA PEL; dust falls under the PNOR / nuisance-dust category at 29 CFR 1910.1000 Table Z-1 (PEL 15 mg/m³ total dust, 5 mg/m³ respirable; verify against https://www.osha.gov/annotated-pels/table-z-1)
NOT on EPA RMP threshold list
NOT on DEA List I or List II
NOT on California Proposition 65 list (verify against OEHHA https://oehha.ca.gov/proposition-65/proposition-65-list before relying on negative listing)
USDA AAPFCO (Association of American Plant Food Control Officials) state-level fertiliser registration required
EPA Risk Management Plan (RMP) does not apply to DAP itself (anhydrous ammonia at 10,000 lb threshold IS on RMP list, but DAP product is not)

Restrictions and conditions of use

No TSCA-specific use restrictions for DAP
OSHA-compliant SDS and workplace HazCom training required
Section 301 List 3 25% additional duty applies to Chinese-origin DAP (HS 310530)
**Active US AD/CVD case on phosphate fertilisers from Russia and Morocco** initiated 2020 with definitive AD orders since 2021 (verify case numbers and current status against https://access.trade.gov/ before invoicing; prior dataset cited A-821-832 / C-821-833 for Russia and A-714-001 / C-714-002 for Morocco). Chinese DAP is NOT subject to this AD case (verify Chinese-origin scope against https://access.trade.gov/)
USDA state-level fertiliser registration required (varies by state: California Department of Food and Agriculture, Florida Department of Agriculture and Consumer Services, Iowa State Fertilizer Section, etc.)
EPA Clean Water Act and state-level Nutrient Trading regulations restrict DAP runoff and waterbody discharge in agricultural watersheds
No specific federal cadmium content limit on DAP (state-level limits exist in California Prop 65 jurisdiction context)

Importer obligations

TSCA is a self-certification regime: importers attest at customs entry that the substance is on the TSCA Inventory. The TSCA Section 13 Import Certification statement is filed via the customs broker on the entry summary (CBP Form 7501). For DAP specifically, the practitioner-facing layer is USDA state-level fertiliser registration (state-by-state, AAPFCO standards), Section 301 List 3 25% additional duty pricing, and regional cadmium content scrutiny. The active US AD/CVD case on Russian and Moroccan phosphate fertilisers (in place since 2021) is shifting US import volume toward Chinese DAP, but the Section 301 List 3 25% additional duty is a structural cost layer that limits competitiveness.

Required documents

TSCA Section 13 Import Certification statement on customs entry
OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format
CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)
USDA state-level fertiliser registration (state-by-state varies)
AAPFCO label compliance: P2O5 minimum 46%, N minimum 18%
Cadmium content certification (where state-level limits apply, e.g. California)

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

Section 301 List 3 25% additional duty applies to Chinese-origin DAP (HS 310530); structural cost layer
USDA state-level fertiliser registration is patchwork; California, Florida, Iowa, and Texas have the largest agricultural-input markets and each has separate registration. AAPFCO Uniform State Fertilizer Bill is a model framework but states implement variations
No active US AD/CVD on Chinese-origin DAP currently. The 2020-2021 AD/CVD case on Russian and Moroccan DAP / MAP shifts US import volume toward Chinese supply, but Section 301 List 3 25% additional duty limits Chinese competitiveness
Mosaic and Nutrien dominate US domestic DAP / MAP production (Mosaic Florida, Nutrien Saskatchewan and Louisiana); US is structurally net-exporter of phosphate fertilisers (despite Russia / Morocco AD case shifting some volume back to imports)
California Proposition 65 listing: DAP is NOT on Prop 65 list, but cadmium AS A METAL is Prop 65 listed and Cd content of DAP can trigger derivative concerns for California-distributed product
Coal-fed Chinese ammonia (input to DAP) raises Scope 3 carbon concern for some US agricultural buyers with sustainability commitments; gas-fed alternatives (Mosaic, Nutrien, OCP Morocco) preferred where available
EPA Clean Water Act watershed-specific DAP runoff regulations (Chesapeake Bay, Florida Everglades, Mississippi River Delta) restrict application in vulnerable zones

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for diammonium phosphate, see the CAS 7783-28-0 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the diammonium phosphate cornerstone hub covers the full sourcing chain.

For the structure and history of TSCA, see the TSCA glossary entry.

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

Cross-jurisdiction profile and sourcing references

Referenced in

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