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June 11, 2012

EPA Extends CDR Deadline

Bergeson & Campbell, P.C.

On June 11, 2012, the U.S. Environmental Protection Agency (EPA) signed a Federal Register notice extending the deadline for Chemical Data Reporting (CDR) submissions from June 30, 2012, to August 13, 2012. According to the pre-publication notice, this is a “one-time extension” only. The CDR regulations require manufacturers and importers of certain chemical substances included on the Toxic Substances Control Act (TSCA) Inventory to report current data on the manufacturing, processing, and use of the chemical substances. The pre-publication notice is available online.

On May 18, 2012, the North American Metals Council (NAMC), which is managed by B&C Consortia Management, L.L.C. (BCCM), an affiliate of Bergeson & Campbell, P.C. (B&C), requested a 90-day extension of the reporting period. According to NAMC, the extension request was necessitated by unexpected problems encountered with the electronic reporting system that EPA requires CDR submitters to use and by EPA’s failure to respond in a timely manner to questions or requests for clarification. In the notice, EPA states that it is extending the deadline in response to concerns raised by the regulated community about their ability to submit the required information within the prescribed period. Concerns raised by industry include the timing of responses to inquiries about regulatory interpretations, particularly for byproduct substances, and issues associated with several aspects of electronic reporting.