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April 10, 2020

EPA Announces CDR 2020 Submission Period Extension

Lynn L Bergeson

By Lynn L. Bergeson and Ligia Duarte Botelho, M.A.

On April 9, 2020, EPA issued a final rule amending the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) regulations by extending the 2020 report submission deadline to November 30, 2020. The extension applies to the 2020 submission period only. As many are aware, CDR regulations require manufacturers (including importers) of certain chemical substances to report data on the manufacturing, processing, and use of the chemical substances. This final rule is effective as of April 9, 2020.

This final rule has been published alongside EPA’s CDR Revisions final rule, which includes several changes to make regulatory updates that align with new statutory requirements of TSCA, improve the data collected, and potentially reduce the burden for chemical reporters. The CDR Revisions final rule will be effective on May 11, 2020.

Given the changes to become effective, The Acta Group (Acta®) announced on April 1, 2020, the launch of CDR Cross-Check™, an ingenious yet simple tool developed and offered by Acta to assist companies in preparing for the 2020 CDR required by EPA. CDR Cross-Check utilizes the most recent CDR listing information publicly available provided by EPA (currently, 2016 lists) to identify whether all or some of a company’s inventory of chemical substances are subject to CDR under TSCA and, if so, at what reporting threshold. CDR Cross-Check will make CDR reporting easier. CDR Cross-Check will identify whether chemicals are listed on the TSCA Inventory and, if so,

  • whether they are listed as active or inactive;
  • whether they were subject to specific TSCA regulatory actions in 2016;
  • whether they are exempt; and
  • what the 2020 reporting thresholds would be based on the 2016 data.

Visit the CDR Cross-Check website,, for more information and to order a CDR Cross-Check report.

The Acta Group is a global scientific and regulatory consulting firm that assists companies with strategic commercialization planning and complex product registration and compliance matters in North America, South America, Europe, the Middle East, and Asia. Acta is the consulting affiliate of Washington, D.C., law firm Bergeson & Campbell, P.C. (B&C®).