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ARTICLE · 30 MARCH 2011

Changes Proposed For The 2011 Toxic Substances Control Act Inventory Update Reporting

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2011 is a reporting year pursuant to the Toxic Substance Control Act (TSCA) Inventory Update Reporting (IUR) rule.

United StatesEnvironment
Barnes & Thornburg LLP’S Environmental Law Department
Barnes & Thornburg LLP’S Environmental Law Department
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2011 is a reporting year pursuant to the Toxic Substance Control Act (TSCA) Inventory Update Reporting (IUR) rule. Pursuant to IUR, companies (other than "small" manufacturers) that manufacture (including import) chemicals for commercial purposes (including byproduct chemicals that are not disposed of as waste) must periodically report manufacturing information to the United States Environmental Protection Agency (EPA). For the 2011 reporting period, EPA is proposing many changes that may trigger additional reporting for many companies.
Last fall EPA issued a proposed rule seeking many changes to the IUR requirements, including requiring companies to identify if a chemical is being recycled. This requirement is a change from previous reporting years and affects companies that may not have previously reported chemicals that were recycled or used on-site. EPA classifies those activities as commercial purposes that require a chemical, including a byproduct, to be reported.

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