TSCA Inventory and Chemical Data Reporting Readiness
Check each site and substance against the threshold, plan the 2028 period early and keep the records behind every volume.
In Short
- Decide per site, per substance.
- Any one year can trigger it.
- Keep records 5 years.
The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
- Which rules reach your plant
- Raw material to store
- Charge, watch, adjust, release
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The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
Chemical Data Reporting (CDR) under 40 CFR Part 711 asks manufacturers and importers of chemical substances on the TSCA Inventory to report production volumes and related information, site by site, every four years. This guide covers who reports, the thresholds, timing and records. It is orientation, not legal advice. New-chemical notices are covered in our separate TSCA section 5 guide. Sources checked 4 Oct 2026.
Who must report, site by site
Section 711.8 applies to anyone who manufactured, including imported, a reportable substance for commercial purposes at or above the threshold at any single site they own or control, during any calendar year since the last principal reporting year. The determination is made per substance and per site, not per company.
More on who must report, site by site
Start with a site list and, for each, the substances made or imported, so the question is answered from records rather than estimates. Sections 711.9 and 711.10 set out additional exemptions; check them before concluding a site is out of scope.
Volume Thresholds
The general threshold in 711.8(a) and 711.15 is 25,000 lb (11,340 kg) of a substance at one site in any calendar year since the last principal reporting year. A lower 2,500 lb (1,134 kg) threshold applies to substances subject to the TSCA rules, orders or actions listed in 711.8(b).
Common gap. Volume data held only in finance systems, without the site split CDR needs.
Thresholds per site (711.8, 711.15)
| Substance | Any one calendar year |
|---|---|
| Most substances | 25,000 lb (11,340 kg) |
| Subject to actions in 711.8(b) | 2,500 lb (1,134 kg) |
- Most substances
- Any one calendar year
- 25,000 lb (11,340 kg)
- Subject to actions in 711.8(b)
- Any one calendar year
- 2,500 lb (1,134 kg)
More on volume Thresholds
Because any single year counts, the peak year matters, not the average. Section 711.6 exempts some categories fully or partly, but those exemptions fall away for substances subject to certain TSCA actions.
When to report
Section 711.20 states that the 2024 submission period ran from 1 June to 22 November 2024, and that later periods run from 1 June to 30 September at four-year intervals, beginning in 2028. Each period looks back at the calendar years since the last principal reporting year.
More on when to report
Plan the 2028 work in 2027: confirm substances, sites and annual volumes per year, decide who signs, and leave time for confidentiality decisions under 711.30, which must be asserted when information is submitted.
Records to Keep
Section 711.25 requires records that document any information reported, kept for five years beginning on the last day of the submission period; EPA encourages keeping them longer. In practice that means the production and import records behind each volume, the method used to calculate it, any exemption relied on and the signed submission.
Worked Example: Site S-02, Substance CX-77
- 2027Annual volumes pulled from batch and import recordsPlanning
- 2027Peak year 31,400 lb: above 25,000 lbRegulatory
- 1 Jun – 30 Sep 2028Report submitted and signedAuthorised official
- To 30 Sep 2033Working file retained (5 years)Regulatory
More on records to Keep
Keep the working file per site and substance so the next cycle starts from evidence, not from last cycle's numbers.
Linking CDR to Everyday Records
CDR numbers come from batch, receipt and import records. If batch quantities, substance identities and sites are recorded consistently through the year, the annual totals are a query and a review rather than a reconstruction.
More on linking CDR to Everyday Records
Assign an owner for substance identity, check that imported mixtures are broken down where the rule requires, and review totals with production before sign-off. The decision to report, and what to claim as confidential, stays with your regulatory team.
Questions
Is CDR the same as a premanufacture notice?
No. CDR is periodic reporting on substances already on the TSCA Inventory. New substances go through section 5 notices, covered in a separate guide.
What is the standard reporting threshold?
25,000 lb of a substance at one site in any calendar year since the last principal reporting year, or 2,500 lb for substances subject to the actions listed in 711.8(b).
When is the next submission period?
Section 711.20 sets recurring periods from 1 June to 30 September at four-year intervals beginning in 2028. Check EPA for any amendment before planning.
Where does V5 fit?
V5 keeps formulations, receipts, batch quantities and shipments linked by material and site, which your team can total and review. Your regulatory team decides what to report and submits it to EPA.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
Keep reading
TSCA Section 5 PMN: Who Files, the 90-Day Review and Notice of Commencement
TSCA PFAS Reporting (40 CFR 705): Scope, Articles and the 2027 Window
FTC Made in USA Labels (16 CFR 323) and Endorsement Disclosures
Chemical Traceability Software: Batch, Lot and SDS Records
ISO/IEC 17025 Chemical Testing Labs Readiness Guide
Medical Device Inventory Management: Manufacturer Controls