October 31, 2016 EPA CDR Reporting Applies to Many Manufacturers

Under EPA interpretation of the CDR regulations, manufacturers who send byproducts, such as wastewater treatment sludge, spent etchant or spent baths, for recycling may be required to report under the CDR because EPA views the byproduct stream as a new chemical because it is a feedstock to the recycling process. The applicability of the CDR reporting requirements depends on a number of factors including the amounts of specific chemicals in the byproduct.

For example, any printed circuit board manufacturer using ammonium chloride etchant in excess of approximately 784 gallons/year during 2102, 2013, 2014, or 2015 and sending the spent etchant for recycling is likely to exceed the 2,500 lb. reporting threshold for copper tetraammine chloride.

Recently, IPC achieved a long-sought goal with the inclusion of a requirement for EPA to reexamine this rule passage as part of the of The Frank R. Lautenberg Chemical Safety for the 21st Century Act amending TSCA, however this does not change the need to report this year.

For more information, please review our CDR guidance and TSCA CDR website.  You may also contact Fern Abrams, IPC director of regulatory affairs at FernAbrams@ipc.org or +1 202 661-8092.