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Electronic TSCA CDX Reporting Required Beginning April 7, 2012

Date: Apr 02, 2012

Beginning April 7, 2012, the U.S. Environmental Protection Agency is requiring that all TSCA section 5 notifications be made online using the Central Data Exchange (CDX) system.

Affected TSCA section 5 notifications include common filings such as premanufacture notifications (PMNs) and Low Volume Exemption Applications (LVEAs), and biotechnology submissions such as Tier I certifications and Microbial Commercial Activity Notices (MCANs). In addition, any subsequent submissions related to these filings must be made using the CDX system. This will include amendments to these submissions as well as Notices of Commencement (NOCs) for PMNs and MCANs.

If you have not already done so, we recommend that an authorized official (the person that signs the EPA submissions) register with EPA's CDX system as soon as possible. The CDX registration may take a few weeks to complete, as it requires a signed and notarized form be sent to EPA and verification of the employment of the registrant. Below, please find a link to where the authorized official may begin the CDX registration process. Once you have arrived at the CDX homepage, please click the "Register with CDX" button.

Central Data Exchange Hompage

When registering with CDX please make sure to register for the TSCA program. CDX registration is also required to make submissions for the TSCA Chemical Data Reporting (CDR) program, for which the reporting period runs through June 30, 2012. Also note that CDX filings are being implemented for many EPA programs in addition to TSCA.

For more information about these requirements, please contact Thomas C. Berger (+1 202.434.4285, berger@khlaw.com).