• In most cases, information that may be claimed as CBI includes a checkbox for designating the information as CBI adjacent to the field where the information is to be entered.
• In cases in which the electronic reporting application does not support making a CBI claim adjacent to where the information is entered, the submitter is responsible for indicating what information is being claimed as CBI.

Almost all Toxic Substances Control Act (TSCA) submissions are required by regulation to be submitted electronically. See 40 CFR 703.5(f). The Environmental Protection Agency (EPA) electronic reporting systems within the Central Data Exchange (CDX) prompt users for some required elements when confidential business information (CBI) claims are made.

TSCA electronic reporting tools are available in the Chemical Safety and Pesticide Programs (CSPP) portion of EPA’s CDX. The electronic reporting applications for many TSCA submission types are based on fillable forms where each data element is entered individually. In most cases, information that may be claimed as CBI includes a checkbox for designating the information as CBI adjacent to the field where the information is to be entered.

In cases in which the electronic reporting application does not support making a CBI claim adjacent to where the information is entered (for example, if a submission includes document attachments), the submitter is responsible for indicating what information is being claimed as CBI. For documents created outside of the CDX reporting application that include CBI claims, both the complete document (with information claimed as CBI shown) and a sanitized version (with CBI redacted or otherwise masked) generally must be attached to the submission.

For electronic submissions, the certification statement is incorporated into the reporting application. The official making the submission will be prompted to agree to the certification statement prior to being able to complete the submission.

If a specific chemical identity is claimed as CBI, a structurally descriptive generic name must also be provided. Electronic reporting applications provide a field for inputting a structurally descriptive generic name for all submission types. Substantiation questions are also incorporated into the reporting applications.