Glossary of Terms

Processor: Anyone who processes a chemical substance or mixture. The LCSA amendments did not change the definition of a process or processor. Process still means “the preparation of a chemical substance or mixture, after its manufacture, for distribution in commerce (A) in the same form or physical state as, or in a different form or physical state from, that in which it was received by the person so preparing such substance or mixture, or (B) as part of an article containing the chemical substance or mixture.”

TSCA Inventory: A list of each chemical manufactured or processed in the U.S. EPA is required to keep this list current. The inventory was originally compiled over 40 years ago. 

Inventory “Reset”: The LCSA amendments, require EPA to “reset” the inventory to update our understanding of what chemicals are still active in commerce today, and which are inactive. 

Active Substance: An active substance is any chemical that EPA finds is currently in commerce. The agency has a number of methods of determining whether a chemical is active, including through Form A and Form B active chemical notifications, or notifications that a new chemical is entering the market (a Notice of Commencement). 

Inactive Substance: All chemicals in the TSCA inventory not otherwise notified to or recognized by EPA as active. 

Draft Inventory: The Draft inventory is EPA’s first attempt to identify all active chemicals in commerce for the first time in over 40 years. Any chemicals on this list are chemicals that, EPA tentatively considers active in commerce and on the inventory. Therefore, any chemicals on the draft inventory are not subject to any further reporting requirements under the TSCA inventory regulations. You can find the draft inventory here. 

Initial Inventory: The initial inventory will be published in late 2018, and will include any chemicals voluntarily notified as active in commerce by processors during the processor reporting period. The initial inventory will become effective in early 2019. 

Form A: The form processors use to submit active chemical notifications for chemicals in commerce between June 22, 2006 and June 22, 2016. Manufacturers and Importers have already completed their submissions. Processors are not under any obligation to file any Form A notifications, but must do so by October 5, 2018 if they wish. 

Form B: The form used to submit active chemical notifications for inactive chemicals that a manufacturer, importer, or processor wishes to bring into commerce after the Inventory become effective in early 2019. Chemicals that are not on the Draft Inventory and not notified by a processor will become effectively inactive 90 days after the initial Inventory is published in late 2018. Processors can only use Form A to make notifications now. After October 5, processors won’t be allowed to use Form A. 

Central Data Exchange (CDX): EPA’s electronic reporting site. CDX is used to facilitate reporting across numerous EPA programs, not just the inventory reset. Processors wishing to report will need to obtain a CDX login. 

CDX Receipt: When a company files either a Form A or B notification, EPA’s digital platform will automatically send an email to the submitter documenting receipt of that submission. Each email, which acts as the CDX receipt, contains a unique transaction ID, and no other substantive information. 

Transaction ID: Each CDX receipt has a unique transaction ID. Because a transaction on CDX may notify multiple chemicals, each chemical notified does not have a unique transaction ID. 

Primary Authorized Official (PAO): The PAO is responsible for submitting Form A or B notices. The PAO may be any individual within a company, as it is up to the company to designate the PAO.PAOs must be U.S. citizens, but a company may designate an authorized agent to make submissions as well. 

Joint Submission: Each Form A or B notification may be submitted by multiple parties in a joint submission. Joint submissions may be necessary where a processor does not know the chemical identity of a substance within a proprietary mixture it is processing. 

Pick List: A list of chemicals available in the CDX reporting system from which any processor may choose a chemical to report as active. This list includes all chemicals on the TSCA inventory that are not determined to be Confidential Business Information, or that were not reported during the manufacturer and importer reporting period. 

Mixture: TSCA defines “mixture” as “Any combination of two or more chemical substances if the combination does not occur in nature and is not, in whole or in part, the result of a chemical reaction; except that such term does include any combination which occurs, in whole or in part, as a result of a chemical reaction if none of the chemical substances comprising the combination is a new chemical substance and if the combination could have been manufactured for commercial purposes without a chemical reaction at the time the chemical substances comprising the combination were combined.” 15 U.S.C. § 2602(10).

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