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September 13, 2024

EPA Reports Issues with Submitting CBI in CDX for CDR Reporting

Lynn L. Bergeson Carla N. Hutton

The Chemical Data Reporting (CDR) rule requires manufacturers (including importers) to report data to the U.S. Environmental Protection Agency (EPA) every four years. The 2024 submission period began June 1, 2024, and will end September 30, 2024. The CDR rule requires all companies to report data electronically using e-CDRweb through EPA’s Central Data Exchange (CDX) system. CDR reporting in CDX is currently malfunctioning, however. EPA has issued two alerts:

  • If a reporter is claiming more than one chemical as confidential business information (CBI) and is using the reporting tool’s copy functionality to substantiate multiple chemicals, “chemical specific substantiation questions/response may disappear from the application and PDF.” EPA asks reporters to “delay using the substantiation copy functionality for chemicals being claimed as CBI until after an update is deployed, expected on 9/20.”
  • If a reporter claimed a secondary submitter as confidential, the generated PDF is not accurately displaying that claim. EPA asks reporters to delay submitting the form “until after an update is deployed, expected on 9/20.”