A new EPA rule finalizes amendments to the definition of “small manufacturer” in accordance with the Toxic Substances Control Act (TSCA). Changes to the small manufacturer definition impact certain reporting and recordkeeping requirements established under TSCA. The final rule is effective 30 days after publication in the Federal Register.

The final rule, made public May 12, updates EPA’s 1984 definition of entities that must file production volume and other information under existing regulations, including the Chemical Data Reporting rule.

The update defines an entity as a “small manufacturer” if it meets either of two standards:

  • a company making or importing chemicals is “small” if its total annual sales, when combined with those of its parent company, are less than $120 million and the chemical it must report is produced or imported in a volume of 100,000 pounds or less.
    • Note that both conditions must be met. A company with annual sales below the limit that makes or imports more than 100,000 pounds annually of a chemical would have to report that chemical’s production.


  • a company making or importing chemicals is “small” if its total annual sales are less than $12 million, regardless of the volume of the chemicals it produces or imports

The new definitions of small manufacturer supplement broader changes the EPA published in April to the Chemical Data Reporting (CDR) reporting requirements, which are due between June 1 and Nov. 30. (See previous blog-post.)