Using and Interpreting the CDR Database

It is important to understand what the CDR collection is and what it is not, how the data are collected, and how the data are made publicly available. Understanding these factors will help you use the CDR data. 

• Historical CDR data changes
• Changes in chemicals reported under CDR
• Confidential Business Information
• Reporting thresholds
• Reported production volumes
• Range reporting 

• Processing and use information

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Historical CDR Data Changes

The CDR Program has evolved as EPA has modified the CDR reporting requirements, including production volume thresholds and the types of data reported. These changes influence production, use, and exposure-related information for a given year and may impact multi-year trend analyses of CDR data.

The table summarizes changes for each submission period. You can also view a summary of CDR requirements by year for 2006 to 2020.

Changes in Chemicals Reported Under CDR

CDR reporting is based on a chemical’s status (e.g., listing on the TSCA Inventory, applicability of various exemptions) at the beginning of the submission period, generally June 1 of the submission year (e.g., for the 2024 CDR, the submission year begins June 1, 2024).

The TSCA Chemical Substance Inventory provides a listing of chemical substances to be reported under CDR. Chemicals not claimed as confidential are listed by CAS registry number and a specific chemical name. Chemicals whose identity is protected by a CBI claim are listed using an EPA-assigned accession number and a generic name. Should this protection be lifted (due to a company giving up its claim or EPA denying the claim), the Inventory will list the CAS registry number and specific name of the chemical rather than its accession number and generic name. Such a change in how the chemical is identified may impact the ability to identify trends for those chemicals.

Whether CDR reporting occurs and what gets reported depends on regulatory factors such as: 

• the reporting threshold for the chemical (either 25,000 or 2,500 pounds),
• whether the manufacturer is defined as a small entity by the applicable regulations, and 
• exemptions to reporting (e.g., full exemptions for a byproduct chemical substance based on its use, polymers, and other exemptions).

Changes to reporting requirements may also affect the chemicals reported under CDR. For example, as part of the 2003 Inventory Update Rule Amendments, EPA removed the exemption for inorganic chemicals, leading to the first reporting on inorganic chemicals during the 2006 IUR.

Confidential Business Information (CBI)

What is CBI?

Confidential Business Information (CBI) is broadly described as proprietary information, considered confidential to the submitter, the release of which would cause substantial competitive harm to the owner. Companies generally claim information as CBI when they believe the information gives other companies an advantage in the marketplace. Learn more about CBI claims and reviews under TSCA.

CBI and the Public CDR Database

CDR data users should understand what data submitters are allowed to claim as CBI. In general, submitters can claim individual CDR data elements as CBI if they believe that publication would reveal trade secrets or confidential commercial or financial information. The 2020 CDR Revisions Rule changed which data elements could be claimed as CBI and the process for substantiating such claims, aligning with 2016 changes to TSCA.

In preparing the CDR public database, EPA may aggregate and mask data to avoid releasing CBI while publishing as much information as possible. Individual records may include CBI-protected entries in some data fields.  

Important Highlights About CBI Claims

• The identity of a chemical can be claimed confidential only if it is listed on the confidential portion of the TSCA Inventory. Following the 2020 submission period, EPA moved many chemicals from the confidential portion of the Inventory to the non-confidential portion. EPA included as many chemicals as possible in the published 2020 data. However, ongoing CBI reviews prevented the inclusion of all chemicals. See also the previous discussion under the topic “Changes in Chemicals Reported Under CDR."
• For a particular chemical, a submitter can claim their company and/or site information as CBI.  This means they can request that the association between the company/site and the chemical being reported be kept confidential and the company will not be listed as a manufacturer of that chemical. Note that this and most other CBI claims do require sufficient substantiation to be maintained and masked in the public data.
• Production volume can be claimed as CBI and does not require a substantiation at the time the data are submitted. 
• Other manufacturing-related information, such as the volume of the chemical directly exported or its physical form, can be claimed as CBI.
• Some processing and use data elements such as the type of processing or use, the industry sector, the product code, or the function of the chemical cannot be claimed as CBI. 
• Other processing and use data elements such as the number of industrial or commercial workers or the percent production volume can be claimed as CBI.

If no production volumes for a chemical are claimed as CBI, the public CDR database will include specific values for individual and aggregated production volumes. If some or all reported production volumes for a chemical are claimed as CBI, EPA will not publish the individual CBI production volumes, and aggregated production volumes will be published as a range.

Reporting Thresholds

CDR reporting is triggered by the amount of a chemical manufactured (including imported), rather than the hazard or potential exposures associated with a chemical. Understanding CDR reporting thresholds is important when using and interpreting the CDR data.

• 25,000 pounds threshold: Reporting for 2016 and future is required if a site’s production volume was 25,000 pounds or more during any calendar year since the last principal reporting year. The principal reporting year is the most recent year in a reporting period. For example, for the 2024 CDR cycle, the last principal reporting year was 2019, so submitters considered annual production from 2020 to 2023. For the 2024 CDR cycle, 2023 was the principal reporting year.
• 2,500 pounds threshold: For chemicals under specific TSCA actions, the reporting threshold is reduced to 2,500 pounds. Find out how to identify if a chemical substance is one of those affected.

• Manufacturers (including importers) must report manufacturing data for the principal reporting year and production volumes only for each year since the previous principal reporting year.

  CDR Cycle	Principal Reporting Year	Past Years (Report Production Volume Only)
  2016	2015	2012-2014
  2020	2019	2016-2018
  2024	2023	2020-2022

The reporting threshold has also changed over time. Read a summary of changes to the reporting threshold from 2006 to 2020. 

Reported Production Volumes

Several factors impact reported production volumes.

Reporting Thresholds

Due to reporting thresholds, total CDR production volumes reported may underestimate the actual amount of chemicals manufactured and imported in the United States, particularly if a substantial number of sites manufacture (including import) the chemical in quantities less than 25,000 pounds per year or are otherwise exempted from reporting (such as small manufacturers). When comparing production changes, the impacts of reporting thresholds should be considered.

TSCA Definition of Chemical Substances

The production volume reported for a chemical is limited to chemical substances as defined by TSCA. If a chemical has both a TSCA use and a use covered by another law (e.g., the Federal Food, Drug, and Cosmetic Act), only the volumes associated with the TSCA use are reported under CDR. As a result, the CDR volume may undercount the national production volume for a particular substance.   

Reporting Triggers

Reported production volumes are also impacted by what years are considered when assessing the reporting requirements. Beginning with the 2016 CDR, companies had to consider whether they exceeded the threshold for any year since the last principal reporting year. For example, for the 2016 CDR, companies considered the production volumes for 2012 to 2015 and reported for all the years if they met the threshold requirements for any year. Prior to 2016, submitters considered only the year they were reporting for (e.g., for 2012 reporting they only considered the production for 2011). This change helped to eliminate variability due to production impacts from any single year.

CBI Claims

The production volume in the publicly available data is affected by CBI claims. The CBI section of this page has additional details.

Range Reporting

While most information is reported as discrete values, manufacturers report some data elements as ranges. Depending on the intended use of the data, it may be appropriate to use a mean or median value or the high end or low end of the range. The data elements reported as ranges are:

• Manufacturing Information:
  • Number of workers reasonably likely to be exposed to the chemical
  • Maximum concentration of the chemical
• Processing and Use Information:
  • Percent production volume for each product category
  • Number of sites for each product category
  • Number of workers for each product category
  • Maximum concentration for consumer and commercial use

Publicly available data may include production volumes in ranges. Although reported as discrete values, ranges are used to protect information claimed as CBI. The CBI section of this page has details.

Processing and Use Information

Notable Limitations

Manufacturers (including importers) often do not control how chemicals are processed and used, so they may not possess complete information about these activities. Manufacturers (including importers) are required to report processing and use information they know or can reasonably ascertain. They are not required to collect information from their customers regarding end uses. In addition, they are not required to report processing and use information for quantities of a chemical that are manufactured solely for export. 

The processing and use information reported in the CDR public database presents a partial view of chemical processing and use in the United States.

Identifying Trends

When analyzing CDR processing and use information to identify trends, users should be aware that:

• Function category and product code lists changed.  The new lists were voluntary for most chemicals for the 2020 submissions and were required for the 2024 and future submissions.  
• Sector codes replaced NAICS codes beginning with the 2012 submissions.
• Information on processing and use is not required for partially exempted chemicals.
• Processing and use information are only reported for the principal reporting year (e.g., for 2020, the principal reporting year is 2019).
• Processing and use information reporting was first required in 2006 for chemicals with production volumes of at least 300,000 pounds. This threshold was reduced to 100,000 pounds for the 2012 collection, after which the separate threshold was eliminated.