IMPORTANT: Before completing this form, please read the accompanying instructions carefully. Form Approved: OMB No. 2070-0054 

EPA Form 7710-35 (01/2005)

U.S. ENVIRONMENTAL PROTECTION AGENCY 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 

CONTROL NUMBER 

MANUFACTURER’S REPORT 

PRELIMINARY ASSESSMENT INFORMATION 

PERIOD COVERED 

FROM: Mo. Yr. TO: Mo. Yr. 

Send completed form to: 

Document Control Office (7407M) 

Office of Pollution Prevention and Toxics 

U.S. EPA 

Room 6438 EPA East 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 This information is required under the authority of Section 8(a), Toxic 

Substances Control Act. 15 U.S.C. 2607. Attn: 8(a) PAIR Reporting

Section I -- CERTIFICATION 

TECHNICAL CERTIFICATION STATEMENT Signature Date 

I hereby certify that, to the best of my knowledge and belief, all information entered on this 

form is complete and accurate. I agree to permit access to, and the copying of records by, a 

duly authorized representative of the EPA Administrator, in accordance with the Toxic 

Substances Control Act, to document any information reported here. 

Name and title Please print or type

CONCERNING EPA DISCLOSURE OF INFORMATION 

Any person who submits information to EPA under the Preliminary Assessment Information Rule (40 CFR 712) should be aware of EPA regulations (40 CFR Part 2) 

which govern the disclosure of such information. Those regulations provide that any such person may, if he or she desires, assert a confidentiality claim covering part or 

all of the information submitted. Information covered by such a claim will be publicly disclosed by EPA only to the extent, and by means of the procedures, set forth in 40 

CFR Part 2. However, if no such claim accompanies the information when it is received, EPA may make that information public without notifying the submitter.

CONFIDENTIALITY STATEMENTS 

Information disclosed to EPA on this form may be claimed confidential by marking the appropriate boxes below. The person signing the Confidentiality Certification 

Statement attests to the truth of the following four statements concerning all information that is claimed confidential. Note that chemical substance identity may not be 

claimed confidential for this rule. 

1. My company has taken measures to protect the confidentiality of the information, and intends to continue to take such measures. 

2. The information is not, and has not been, reasonably obtainable without our consent by other persons (other than governmental bodies) by use of legitimate means 

(other than discovery based on a showing of special need in a judicial or quasi-judicial proceeding). 

3. The information is not publicly available elsewhere. 

4. Disclosure of the information would cause substantial harm to our competitive position. 

CONFIDENTIALITY CERTIFICATION STATEMENT Signature Date 

I hereby certify that the Confidentiality Statements on this form are true as to that 

information below for which I have asserted a confidentiality claim. 

Name and title Please print or type

Section II – CHEMICAL IDENTIFICATION 

► Part A ► Part B 

CAS No. Category name (first 15 characters) 

Chemical name (first 15 characters) Inventory Form C number 

Section III -- RESPONDENT IDENTIFICATION 

MARK THIS BOX TO CLAIM THIS SECTION CONFIDENTIAL 

► Part A --- Plant Site --- Physical location

Name 

► Part B --- Mailing Address of: 

 Corporate headquarters Plant Site 

Number and street Name 

City Number and street 

County City 

State ZIP Code State ZIP Code 

Dun and Bradstreet number Dun and Bradstreet number (for corporate headquarters only) 

--- --- --- --- 

► Part C --- Technical contact 

Name and title 

► Part D --- Acknowledgement 

 At headquarters 

Telephone (Area code/number) 

 At plant site 

 EPA will send acknowledgement to – Name and title 
Section IV – PRELIMINARY ASSESSMENT INFORMATION 

NOTE Mark the box to the left of the item to claim the answer to the item as confidential. Report all quantities in kilograms 

(1 kilogram equals 2.2 pounds). Enter N/A for any item that does not apply to you; do not leave any blanks. 

►Part A – Plant Site Activities – Information in part A must be your best estimate from readily obtainable data. 

 For items 3b, 3c, and 3d, specify the accuracy of your answers. 

 1. Total quantity imported kg 2. Quantity manufactured for sale or use kg 

 3 a. Quantity lost during manufacture 

 (3b + 3c + 3d must equal 3a) kg 3 c. Quantity in wastes treated to 

 destroy the chemical kg 

 3 b. Quantity lost to the 

 environment kg± % 3 d. Quantity in wastes not treated to  destroy the chemical kg± % 

Activity 

(1) 

Process category 

(2) 

Quantity (kilograms) 

(3) 

Total worker-hours 

(4) 

Total workers 

(5) 

a. Enclosed 

b. Controlled release 

4. Manufacture of the chemical 

c. Open 

a. Enclosed 

b. Controlled release 

5. On-site use as a reactant 

 

 Total Quantity ________________ kg c. Open 

a. Enclosed 

b. Controlled release 

6. On-site nonreactant use of the 

 chemical substance 

 Total Quantity ________________ kg c. Open 

a. Enclosed 

b. Controlled release 

 7. On-site preparation of products 

 Total Quantity ________________ kg c. Open 

 8. MANUFACTURER’S PRODUCTS – Report on the quantity of the chemical substance that you prepare for each of the following 

a. Chemical or mixture kg d. Chemical or mixture kg 

b. Article with some release kg e. Article with some release kg 

INDUSTRIAL 

PRODUCTS 

(domestic)

c. Article with no release kg 

CONSUMER 

PRODUCTS 

(domestic) 

f. Article with no release kg 

g. Products for export ───────────────────────────────────────────────────► kg 

►Part B – Chemical Substance Processing by Customers – Information in part B must be accurate within ± 50%. 

 9. CUSTOMERS’ USES AND PRODUCTS – Estimate the quantity of the chemical substance that your customers use or prepare for each of the following. 

a. Chemical or mixture kg d. Chemical or mixture kg 

b. Article with some release kg e. Article with some release kg 

INDUSTRIAL 

PRODUCTS 

(domestic)

c. Article with no release kg 

CONSUMER 

PRODUCTS 

(domestic) 

f. Article with no release kg 

g. Products for export ───────────────────────────────────────────────────► kg 

h. Quantity of chemical consumed as reactant ──────────────────────────────────────► kg 

i. Unknown customer uses─────────────────────────────────────────────────► kg 

10. MARKET NAMES – If you report your customers’ uses as unknown (9i above) for more than 20% of the total quantity of the chemical substance that you 

manufacture and import (20% of items 1 and 2 above), list the market names under which you distribute the chemical (if you need more space, attach an 

additional sheet.) 

a. c. 

b. d. 

11. CUSTOMERS’ PROCESS CATEGORIES – Based on your knowledge of general industry practices, estimate the quantity of the chemical substance that you sell 

to customers as the chemical and that your customers further process in each of the following categories. 

a. Enclosed processes kg c. Open processes kg 

b. Controlled release processes kg d. Unknown kg 

EPA Form 7710-35 (01/2005) Reverse
INSTRUCTIONS FOR MANUFACTURER’S REPORT FORM 

PRELIMINARY ASSESSMENT INFORMATION

What chemicals to report – This form applies to substances that are listed in 40 CFR 712.30. 

Do not report on listed chemical substances if these are manufactured or imported incidentally as 

a byproduct, non-isolated intermediate, or impurity. 

A byproduct or co-product must be reported if it's marketed or used as a subject (listed) 

chemical. 

Do not report a listed chemical substance if it is a component of a mixture (imported or 

manufactured). Note, though, that the mixture itself may be listed as a reportable substance. 

Reporting is required, however, if the chemical is manufactured separately by a given company, 

and then blended into a mixture. In such a case, the blending step(s) would be reported as 

processing activities. Reporting is also required if the manufactured or imported chemical is (1) 

in aqueous solution; (2) in a solution containing an additive (such as a stabilizer or other 

chemical) to maintain the integrity or physical form of the substance; or (3) present in any grade 

or purity. 

Reporting Period – Enter the months and years beginning and ending the 12-month period for 

which you report (e.g., July 81 - June 82). This reporting period is listed with the chemical 

substance in 40 CFR 712.30. 

Who must report – Manufacturers and importers must report. See 40 CFR 712.25 for 

exemptions from reporting. In addition to the actual synthesis of a compound, all refining, 

extracting, and purifying activities of a listed chemical substance are considered manufacturing 

activities under Section 3(7) of TSCA (15 U.S.C. 2602(7)). Reporting is required for all 

companies involved in any of these activities. 

Repackaging is considered a processing activity and should not be reported as manufacture. A 

company that only repackages a listed chemical substance is considered only a processor. Note, 

however, that if the company imports the chemical prior to repackaging it is considered a 

manufacturer and must report. 

How many forms to complete – For each chemical, complete a separate form for each plant site 

that manufactured the chemical. 

If a site manufactured and imported the chemical, report both manufacture and import data on a 

single form. 

A company that imported the chemical, but did not process the imported quantity or manufacture 

an additional quantity, may submit a separate form for each import site or may submit a single 

form with the total data for all import sites. 

Who may submit forms – Companies may choose to complete and submit forms to EPA from 

each plant site directly, or through company headquarters. 

EPA Form 7710-35 (01/2005) Page 1 of 10 
Retention of forms – You should keep a copy of each completed form. Refer to the preprinted 

Control Number (shown in the upper right corner on the front of the form) when communicating 

with EPA. 

EPA Assistance – For further information or to obtain copies of the Manufacturer’s Report 

form, contact: 

 Environmental Assistance Division, 

 Office of Pollution Prevention and Toxics (7408), 

 Environmental Protection Agency, 

 1200 Pennsylvania Ave., NW., 

 Washington, DC 20460; 

 Telephone (TSCA Hotline): (202) 554–1404 

 E-mail: TSCA-Hotline@epa.gov.

 Internet: http://www.epa.gov/opptintr/chemtest/info.htm

Paperwork Reduction Action Notice: The public reporting and record keeping burden for this 

collection is estimated to average about 30 hours per response, including the time for reviewing 

instructions, searching existing data sources, gathering and maintaining the data needed, and 

completing and reviewing the collection of information. Send comments regarding this burden 

estimate or any other aspect of this collection of information, including suggestions for reducing 

the burden, to Director, Collection Strategies Division (Mail Code 2822T), U.S. Environmental 

Protection Agency, Washington, DC 20460. Include the OMB control number in any 

correspondence, but do not submit the form or report to this address. The actual information or 

form should be submitted in accordance with the instructions accompanying the information or 

form, specified in the corresponding regulation. 

I. CERTIFICATION

Technical certification – Certify the technical accuracy of data you report on the form by 

signing and dating the Technical Certification Statement. Print or type the name and title of the 

person who signs this statement. 

Confidentiality certification – You may claim information confidential by marking appropriate 

boxes in sections III and IV. If you claim any information confidential, you must certify that the 

Confidentiality Statements are true for all information claimed confidential on the form. Do this 

by signing and dating the Confidentiality Certification Statement. Remember: To claim 

confidentiality, both the appropriate box must be marked and the confidentiality certification 

must be signed by personnel with designated authority (e.g., general counsel or corporate office 

in charge). 

EPA Form 7710-35 (01/2005) Page 2 of 10 
II. CHEMICAL IDENTIFICATION (Complete A or B)

Item A – If you are reporting on a chemical that has its CAS Number and Chemical Name listed 

in 40 CFR 712.30, enter the CAS Number and the first fifteen (15) characters of the listed 

Chemical Name. 

Enter N/A in section II, part B, in the spaces for Category Name and Inventory Form C Number. 

Item B – If you are reporting a confidential chemical that is in a category listed in 40 CFR 

712.30, enter the Category Name as listed, and enter the number of the Inventory Reporting 

Form C on which you reported the chemical for the TSCA Inventory. (If the Inventory Form C 

Number is not available, contact the TSCA Hotline.) 

In section II, part A, enter N/A in the spaces for CAS Number and Chemical Name. 

III. RESPONDENT IDENTIFICATION

Confidentiality – Mark this box to claim confidential all Respondent Identification in section 

III. Note that you may not claim your identity confidential if you reported this chemical for the 

Inventory and did not claim your identity confidential at that time. 

Item A – Enter the name, physical location address, and Dun and Bradstreet number of the plant 

sure for which the data are reported. 

If your company imported but did not further process or manufacture additional chemicals, and 

you choose to submit data for all import sites on a single form, enter N/A. 

If the plant site does not have a Dun and Bradstreet number, enter N/A. 

Item B – Mark the appropriate box to show whether the plant site or corporate headquarters is 

submitting this form. Enter the corresponding name and mailing address. 

If corporate headquarters submits this form, enter its Dun and Bradstreet number, or if the the 

plant site submits this form, enter N/A in the space for the Dun and Bradstreet number. 

EPA will send all correspondence regarding the form to this address. 

Item C – Enter the name, title, and telephone number (including area code) of a person for EPA 

to contact if there are questions about the data reported on this form. 

Item D – EPA will acknowledge receipt of the form to the person named in this item. 

EPA Form 7710-35 (01/2005) Page 3 of 10 
IV. PRELIMINARY ASSESSMENT INFORMATION

TSCA Regulable Quantities – Except under items 4 and 5, do not report any quantity of 

chemical substance that is manufactured or processed solely for use as: a pesticide; tobacco or 

any tobacco product; any source material, special nuclear material, or byproduct material (as 

terms defined in the Atomic Energy Act of 1954 and regulations issued under such Act); 

firearms or ammunition; or food, food additives, drug, cosmetic, or device (as such terms are 

defined in section 201 of the Federal Food, Drug and Cosmetic Act). The above are not TSCA 

regulable. 

Some of the chemical substances are manufactured for both TSCA and non-TSCA regulable 

purposes. If a chemical from a given manufacturing stream is solely for a non-TSCA use, no 

reporting is required. However, if a company produces a chemical from the same stream that 

will be used for both TSCA and non-TSCA purposes, the total quantity must be reported under 

items 4 and 5. Note that the quantity produced for TSCA purposes only is entered under item 2. 

PART A: PLANT SITE ACTIVITIES

Accuracy – For each item, provide numbers that represent your best estimates based on readily 

obtainable data. 

Item 1 – Enter the total quantity of the chemical substance imported in bulk during the reporting 

period. For a given compound, if a company is not involved in any manufacturing activity, and 

imports a chemical at one site and processes it at another facility, answers need to be provided 

only for item 1 and items 9 through 11 (Part B). Note that the transfer of chemical to another site 

of the same company for processing is treated as if it were a customer use. 

Item 2 – Enter the total quantity of chemical domestically manufactured for TSCA use during 

the reporting period, not counting the losses reported in item 3. 

Item 3a–3d – In 3a, report the total quantity lost in manufacture of the substance during the 

reporting period. Report only routine losses. Do not report unusual spills or accidents. In 

calculating estimates for quantities not recovered you may: (1) use measured losses, if available, 

or emission factors and other calculated releases from individual sources; or (2) if these are not 

available, or only account for a portion of the total loss, you may make a simple mass balance 

estimate of the expected yield minus actual yield, where actual yield is the value reported in item 

2. This quantity in 3a should then be broken down into three categories below (i.e., 3b + 3c + 3d 

= 3a). Specify the accuracy you report for 3b, 3c, and 3d, e.g., 1000 kg ± 30%. 

3b. Quantity lost to the environment – This covers fugitive emissions to the atmosphere 

and other losses not described in 3c and 3d. 

3c. Quantity in wastes treated to destroy the chemical.

EPA Form 7710-35 (01/2005) Page 4 of 10 
3d. Quantity in wastes not treated to destroy the chemical – This includes, for example, 

any quantity disposed of in a landfill, surface impoundment, municipal sewage, or 

storage. 

Items 4–7 – Items 4–7 in part A require you to describe the manufacturing process and your use 

of the chemical in terms of the number of workers and quantity of substance associated with 

three process categories. Three process categories are described below, followed by instructions 

for calculating quantities, worker-hours, and number of workers. Additional instructions 

concerning items 4 through 7 are also listed. 

PROCESS CATEGORIES

Enclosed Process – The process is designed and operated so that there is no intentional release 

of the chemical. In this process category, only fugitive or inadvertent releases occur and special 

measures are taken to prevent worker exposure and environmental contamination. “Special 

measures” refer to procedures and equipment that are monitored and used to prevent worker 

exposure, and scrubbers and other recovery equipment employed to prevent environmental 

release. Equipment with emergency pressure relief venting would be allowed in this category; 

routine venting would not. With regard to handling the manufactured chemical, persons who 

handle closed packages containing the material would be counted under “enclosed process.” 

Person who package or transfer the unpackaged chemical would be counted in one of the 

following categories. 

Controlled Release Process – The process is operated in a controlled manner to minimize the 

release of the chemical into the workplace. Release should generally be within prescribed limits. 

These limits may be dictated by government regulations or by company guidelines. If the 

chemical is vented outside the plant, the process is a “controlled release” process. Do not count 

general space ventilation fans. 

Open Process – The chemical is routinely in direct contact with the atmosphere (workplace or 

outside the plant) and no measures are taken to prevent release. Routine direct contact would be 

associated, for example, with reaction vessels that are open vats, the transport or storage of the 

chemical in open containers (even in an otherwise enclosed process), and the venting of a 

chemical freely into the workplace atmosphere. 

 

QUANTITIES

Process Category – Enter the greatest quantity that is processed in each process category. If 

there is more than one process stream, calculate each stream separately and then add the values 

for each process category. If a quantity of the chemical passes in a series through an enclosed 

process and then passes through an open process, the same quantity would be reported twice, 

once under each process category. (The sum of these quantities may be greater than 100% of the 

total quantity manufactured.) 

EPA Form 7710-35 (01/2005) Page 5 of 10 
Example 1 – A company manufactures technical grade chemical x in four steps. 

 350,000 kg——▸350,000 kg——▸350,000 kg——▸200,000 kg 

 Open Enclosed Open Enclosed 

The company would report: 

 Enclosed 350,000 kg 

 Controlled release 0 

 Open 350,000 kg 

Example 2 – A company produces the same chemical in a reagent and technical grade with the 

following steps. 

Technical Grade Process: 

 350,000 kg——▸350,000 kg——▸350,000 kg——▸200,000 kg 

 Open Enclosed Open Enclosed 

Reagent Grade Process: 

 650,000 kg——▸500,000 kg——▸500,000 kg——▸400,000 kg 

 Controlled Controlled Open Open 

 Release Release 

The company would report: 

 Enclosed 350,000 kg 

 Controlled release 650,000 kg 

 Open 850,000 kg 

(The open process amount is the total of the maximum quantity in the open process category 

from each grade.) 

Total Quantity – For items 5, 6, and 7, enter the total quantity processed in all process 

categories. (This total may be less than the sum of the quantities reported n the individual 

process categories.) 

WORKER-HOURS

Worker-hours may be calculated for a given process category by multiplying the average number 

of full-time employees needed for the operation by the number of hours operating annually. 

Alternatively, worker-hour information may be taken from preexisting information source such 

as resource planning or budget figures. 

WORKERS

Report the total number of workers for each process category. Workers are counted in a process 

category if (1) they are directly involved in manufacturing, processing, and handling the 

chemical during the reporting period or (2) they are regularly assigned maintenance or inspection 

EPA Form 7710-35 (01/2005) Page 6 of 10 
personnel who work with the process from a remote control room, and who do not regularly 

come in contact with the actual chemical stream, are not to be counted unless their exposure to 

the chemical stream is greater than or equal to that of regularly assigned inspection and 

maintenance workers. If only control room workers are associated with a process, and their 

exposure to the chemical stream is less than that of regularly assigned inspection and 

maintenance workers, the company must nevertheless report the process categories associated 

with the manufacture and on-site use of the chemical (column 3 in items 4 through 7). The 

number of workers and total worker-hours however may be listed as zero. 

Three process categories are described in the form: enclosed, controlled release, and open. A 

worker should be counted as working with only one process category. If he operates several 

process types, count him under the one with which he spends the most time. If he spends an 

equal amount of time with several, count him under the most open process. 

Example 3 – A company manufactured 1,000,000 kg of a chemical substance in 1980. It 

manufactured the chemical for all twelve months of the year and did so in an enclosed process. 

In order to run the production line, ten (10) workers were present working 40 hour weeks; thus 

over the course of the year 20,800 worker-hours were used to run the production line. 

Over the course of the year, twelve (12) different workers worked on the production of the 

chemical. 

The form would then be filled out as follows: 

Process category Quantity (kg) Worker-hours Total workers

Open 

Controlled release 

Enclosed 

0 

0 

1,000,000 kg 

0 

0 

20.800 

0 

0 

12 

Example 4 – A company manufactured 1,000,000 kg of a chemical substance in 1980. It 

manufactured the chemical for the entire year in a 24 hour/day process consisting of three steps 

in the open, controlled release, and open process categories. The production line was shut down 

for maintenance for 2 weeks of the years. The production line had three 8-hour shifts. Each shift 

in step 1 required 5 workers, while 7 and 10 workers were needed per shift in steps 2 and 3, 

respectively. The total worker-hours required for each step follows: 

Process category

(Shifts/day x hours/shift 

x workers x days/week 

 x weeks/year) Workers-hours

Open (Step 1) 

Controlled (step 2) 

Open (step 3) 

(3 x8 x 5 x7 x 50) 

(3 x8 x 7 x7 x 50) 

(3 x8 x 10 x7 x 50) 

42,000 

58,800 

84,000 

EPA Form 7710-35 (01/2005) Page 7 of 10 
Analysis of the personnel records showed that a total of 75 individuals worked on the production 

of the chemical during 1980. After examining the personnel records, the company was able to 

fill in the following table: 

Process category Total workers

Open (Step 1) 

Controlled (step 2) 

Open (step 3) 

21 

19 

35

75 

Note that some workers are not double counted or “split” even though some jobs may require 

moving from one step of the process to another step of the same process. An employee working 

on both step 1 and step 2 is counted only in step 1 if he/she spends most of his time at that step. 

After adding together steps in the same process category, the company would report as follows: 

Process category Quantity (kg) Worker-hours Total workers

Open 

Controlled release 

Enclosed 

1,000,000 kg 

1,000,000 kg 

0 

126,000 

 58,800 

 0 

56 

19 

 0 

Item 4 – This item applies to the manufacture of the chemical substance and includes all steps to 

ready the chemical for further processing or use. 

Item 5 – This item applies to the use of the chemical at your plant site as a reactant in the 

manufacture of another chemical substance, where the molecular structure of the chemical is 

altered by breaking chemical bonds or making new chemical bonds between the original 

substance and some other substance. Report on all processing up to and including the actual 

reaction step and any ancillary steps which recycle unreacted chemicals back to the reactor 

vessel. Do not report on subsequent activities in this question. 

Item 6 – Report the quantity of the chemical substance that you use on site. Examples include 

cleaning solvents, dielectric fluids, emulsifiers, and lubricants. Do not report any quantity that 

you react to make a product. 

Item 7 – Report the quantity of the chemical substance that you process at the manufacturing site 

into products for on site use or sale. (Note that this does not include manufacture of the chemical 

substance; this is reported in item 4 above.) This items does not include the quantity of chemical 

substance that you incorporate into a mixture or article. Report the steps up to and including 

incorporation of the chemical into an article; do not include any further processing of the article. 

Item 8 – Report the quantity of the chemical substance that you prepare for commercial 

distribution in each of the product types in 8a to 8g. Do not include any quantity of chemical 

substance that your customers will further process. This will be reported in item 9. 

In items 8a to 8f, report the quantity of the chemical substance in products that are for domestic 

use. If you are uncertain about whether your products are for domestic or foreign use, report 

them as domestic. 

EPA Form 7710-35 (01/2005) Page 8 of 10 
The products are divided into industrial and consumer products. “Industrial” means the 

manufacturing and service industries covered by the North American Industry Classification 

System codes. Products meant to be used primarily by the general population are considered to 

be “consumer” products. The following definition from the Consumer Product Safety Act can be 

used as a guide (15 U.S.C. 2052(a)(1)): “The term ‘consumer product’ means any article, or 

component part thereof, produced or distributed (i) for sale to a consumer for use in or around a 

permanent or temporary household or residence, a school, in recreation, or otherwise, or (ii) for 

the personal use consumption or enjoyment of a consumer in or around a permanent or 

temporary household or residence, a school, in recreation, or otherwise.” If you are uncertain 

about whether your products are industrial or consumer, report them as consumer. 

Three types of industrial and consumer product types are described below. 

“Chemical substance or mixture” means a chemical, or mixture containing the chemical, that 

is used directly by the persons using the product, e.g., cleaners, paints, inks, deodorizers, 

solvents, etc. This includes chemicals or mixtures in containers or other articles whose purpose 

is to release the chemical (e.g., cans of spray paint, ink pens, and other applicators). 

“Articles or products with no release” are articles constructed to prevent human exposure to or 

release to the environment of the chemical substance during normal use and storage (e.g., 

chemical coatings on internal components, and chemicals inside sealed articles as in 

thermometers and batteries). 

“Articles or products with some release” are articles whose material components are made of 

chemicals which come in direct contact with persons using the article, the atmosphere, land or 

water; e.g., exposure can come from leaching evaporation, or surface contact. This includes such 

articles as plastic containers, chemically treated textiles, printed paper, coated appliances, etc. If 

the chemical itself is sold in a bottle or other container it should be reported under “Chemical 

substance or mixture,” not as an article. Only the container itself is an article for purposes of this 

form; the substance it contains is not a component of an article. 

In item 8g, report the quantity of chemical substance that you export directly either as the 

chemical or contained in mixtures or articles. 

Item 9 – Estimate the quantity of the chemical substance that your customers process for each of 

the uses listed in items 9a to 9h. (Do not include the quantity of chemical substances that your 

customers will use without further processing; that quantity should be reported in item 8a or 8d.) 

For items 9a to 9g, follow the same directions as for 8a to 8g. 

For item 9h, report the quantity of chemical substance for which your customers’ uses are 

unknown. 

Report your best estimate for items 9a to 9h within ± 50%. If you cannot estimate an item to this 

degree of accuracy, include the quantity in item 9i. You may report “unknown” if the data 

would reveal information subject to a confidentiality agreement between you and your 

customers. 

EPA Form 7710-35 (01/2005) Page 9 of 10 
Item 10 – If you report your customers’ uses as unknown (item 9i above) for more than 20% of 

the total quantity that you manufacture and import (items 1 and 2 above) list the names under 

which you distribute the chemical substance. 

This item will allow EPA, if necessary, to find out about the chemical uses you have reported as 

“unknown” by requiring processors of your products to report directly to us. 

Item 11 – This item addresses your general knowledge of the process types your customers use 

to process the chemical. Estimate the quantity of the chemical that your customers process in 

each of the three process categories. Specify “unknown” if you do not know to within ± 50%.

EPA Form 7710-35 (01/2005) Page 10 of 10