By Jeryl L. Olson

On December 4, 2013, the U.S. Environmental Protection Agency published a final rule, effective March 4, 2014, mandating that most information required to be reported to the Agency under the Toxic Substances Control Act (TSCA) be made electronically, rather than by paper-based filings. 78 Fed. Reg. 72818.

The reporting requirements under TSCA Section 4 (Toxic Substance Monitoring Studies), TSCA Section 5 (Manufacturing of New Chemical), TSCA Section 8(a) (Production Volume Information), and TSCA Section 8(d) (Health and Safety Studies) are all required to be submitted electronically.  Reporting is to be performed using EPA’s Central Data Exchange (CDX) portal.  Once registered in CDX, users will select the Chemical Safety and Pesticide Programs (CSPP) portion of the site and will access the web-based TSCA reporting tool, called the Chemical Information Submission System (CISS) tool. Premanufacture Notice (PMN) reporting under TSCA Section 5 will continue to be done using e-PMN software.  Users already using e-PMN for TSCA Section 5, or TRI-ME for Section 313 reporting can add CSPP to their CDX registration. 

There is a cost associated with the electronic submittals: EPA is requiring a one-time fee to register with the very first TSCA submission, although, of course, EPA is justifying the fee by indicating that the electronic reporting will save companies money in the long run because of perceived efficiencies in electronic, versus paper, reporting. 

To assist companies in implementation of the electronic reporting rule, EPA has prepared system user guides.  Furthermore, EPA is going to hold webinars on December 10 and December 12, 2013. The webinar training session on December 10 from 1:00 to 4:00 p.m. EST will discuss TSCA Section 4 – Test Rule Data Submissions, and the webinar training session on December 12 from 1:00 to 4:00 p.m. EST will discuss reporting under Sections 8(a), 8(d), and 8(e). 

Information on the final rule, the webinars, “how to” guides, and other resources are available on EPA’s website at