New Chemical Reporting Obligations Are on the Horizon

摘要

Every 4 years, chemical manufacturers, including importers, must assess and discharge their CDR reporting obligations. 2016 is a reporting year, and 2015 is the principal reporting year, but all years from 2012 to 2015 are relevant for the reasons noted above. There are new reporting obligations that will take time and energy to complete in a timely fashion, and that process should be underway now. The stakes are high as CDR data are valued by the EPA, influence the EPA's priorities regarding existing chemical regulatory priorities, are relied upon by other EPA program offices for regulatory purposes, and are closely scrutinized by EPA enforcement personnel, competitors, and the public. Care should be taken in discharging this important reporting function, and it should be done so as early as possible this year.