EPA's Mercury Inventory Report Due July 1
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EPA's Mercury Inventory Report Due July 1

If you manufacture or import mercury for commercial purposes, you are required to complete a report to EPA by July 1, 2019 and every 3 years thereafter.

by iSi Environmental

Any person, company or organization who manufactures or imports mercury or mercury-added products, or intentionally uses mercury in a manufacturing process are required to file a report to EPA by July 1, 2019.

⚡ TL;DR: EPA’s Mercury Inventory Reporting Rule requires manufacturers/importers to report all mercury production, imports, use, and sales every 3 years—no volume exemption. Next deadline: July 1, 2019; data from calendar year 2018. Report via EPA’s Central Data Exchange.

Called the “Mercury Inventory Reporting Rule,” it is a part of the Toxic Substances Control Act (TSCA). The final rule for this was published in June 2018. TSCA requires EPA to publish an inventory on mercury supply, use and trade every 3 years. EPA’s next inventory is due in 2020, so as a result, they are requiring those use and import mercury to get their data submitted by July 1, 2019.

⚠️ What’s at stake: Mercury is a neurotoxin linked to birth defects and neurological damage. Facilities failing to report face EPA penalties and may trigger additional state/local health investigations. Missed reporting deadlines can halt operations pending compliance.

Requirements

If you fall under this requirement, it doesn’t matter how much mercury you use, you still need to report to EPA. Reporting is done through EPA’s Central Data Exchange.

The data you’ll use in the report are quantities from calendar year 2018. Some of the items required to be reported include:

Not sure if you manufacture, import, or use mercury-added products? Mercury hides in unexpected places—light bulbs, batteries, instruments. Get a mercury compliance audit from iSi Environmental before July 1.

  • Amount of mercury produced, imported, stored, used, sold, or exported;
  • Types of products made;
  • Types of manufacturing processes and how mercury is used;
  • Business sectors to which mercury or mercury-added products are sold;
  • Country of origin of imported mercury or mercury-added products; and
  • Destination country for exported mercury or mercury-added products.

Once submitted, you’ll be required to submit this report again every 3 years. EPA will not publish names or identifying information once they publish the results.

Exemptions

There are a few exemptions to reporting. In the following instances you won’t need to report:

  • Your mercury activity isn’t for commercial advantage;
  • The mercury you use is only as an impurity;
  • You’re generating, handling or managing mercury-containing waste only (and not recovering it for commerce purposes)
  • The mercury is in an assembled product that contains a mercury component (EPA gives the example of a mercury light bulb for a car manufacturer); or,
  • You manufacture assembled products that contain a component that’s a mercury-added product but you didn’t manufacture or import that component.

EPA Webinar

EPA is having two webinars to explain this Mercury Inventory Reporting Rule. One is Tuesday May 21, the other is Thursday May 23. Click on those dates to go to the signup page for each.

💰 The cost of non-compliance: Missed mercury reporting can result in EPA enforcement actions, site-specific orders to remediate contamination, and substantial remediation costs if mercury has leached into soil or groundwater.

Frequently Asked Questions

Q: What is the Mercury Inventory Reporting Rule and who must comply?

The Mercury Inventory Reporting Rule is part of the Toxic Substances Control Act (TSCA) and requires any person, company, or organization that manufactures, imports, or intentionally uses mercury or mercury-added products to report to EPA every three years. Reports must be filed by July 1 to provide data for EPA’s mercury supply, use, and trade inventory published every three years.

Q: What information must be included in a mercury inventory report?

Mercury inventory reports must include amounts of mercury produced, imported, stored, used, sold, or exported; types of products made; manufacturing processes and uses; business sectors receiving mercury products; country of origin for imports; and destination countries for exports. All data must be reported through EPA’s Central Data Exchange, regardless of mercury quantity used.

Q: What exemptions apply to mercury inventory reporting requirements?

Companies are exempt from reporting if the mercury activity is not for commercial advantage, if mercury is present only as an impurity, if the company only handles mercury waste without recovery for commerce, if mercury is in an assembled product component (like a vehicle light bulb), or if the company manufactures assembled products containing a mercury-added component that it didn’t manufacture or import.

Q: Does EPA publish company names and identifying information from mercury inventory reports?

No, EPA will not publish company names or identifying information once it publishes mercury inventory results. This provides confidentiality protection for reporting organizations while allowing EPA to maintain accurate supply and use data for regulatory oversight.

Mercury reporting feels like a burden until you realize your competitors are already filing. Get ahead of the deadline and lock in your compliance posture.

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