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OnePoint Alert

April 9, 2020

EPA Extends Deadline For Chemical Data Reporting Filings Under Toxic Substances Control Act

By Bernard F. Hawkins, Jr.

Effective April 9, 2020, EPA is amending the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) regulations by extending the submission deadline for 2020 reports from September 30, 2020, to November 30, 2020. This is a one-time extension for the 2020 submission period only. The CDR regulations require manufacturers (including importers) of certain chemical substances included on the TSCA Chemical Substance Inventory (TSCA Inventory) to report data on the manufacturing, processing, and use of the chemical substances. This extension may potentially affect any entity that manufactures (including imports) chemical substances listed on the TSCA Inventory.

EPA does not indicate that this extension relates to the COVID-19 pandemic. Instead, EPA indicates that the one-time extension is for the purpose of allowing additional time for the regulated community to become familiar with the changes to the CDR reporting requirements as a result of the CDR Revisions Final Rule (FRL–10006–56) and to allow time for reporters to familiarize themselves with an updated public version of the reporting tool. EPA believes it is appropriate to extend the reporting period to allow the regulated community additional time to submit their reports. Although not attributed to COVID-19, this extension could nonetheless provide welcome news to companies already struggling through challenges presented by the pandemic.


For additional information on COVID-19 related issues, please visit the Nelson Mullins COVID-19 resource page.