Nation Ford Chemical Waiver Petition for 

Dioxin/Furan Test Rule Regarding Import of 

Chloranil

Economic Assessment

October 9, 2014

CONTAINS NO CBI

Economics and Policy Analysis Branch

(EPAB)

Office of Pollution Prevention and Toxics
2

Background

In March 2014, Nation Ford Chemical (NFC) submitted a request for a waiver (NFC, 2014a) to the 

Dioxin/Furan test Rule (D/F Test Rule), codified in Title 40 CFR 766, that would allow them to import 

chloranil without triggering subsequent testing obligations. The D/F Test Rule, specifically in 40 CFR 

766.32(a)(2)(ii), allows for a waiver from testing if "in the judgement of EPA, the cost of testing would 

drive the chemical substance off the market, or prevent resumption of manufacture or import of the 

chemical substance, if it is not currently manufactured, and the chemical substance will be produced so

that no unreasonable risk will occur due to its manufacture, import, processing, distribution, use, or 

disposal (in which case , the manufacturer must submit to EPA all data supporting the determination.)"

The Economics and Policy Analysis Branch (EPAB) within the Environmental Protection Agency’s (EPA)

Office of Pollution Prevention and Toxics (OPPT) was asked to consider affordability of the testing for the 

manufacturer and whether the cost of testing would drive the chemical substance off the market, or 

prevent resumption of manufacture or import of the chemical substance if it is not currently 

manufactured. The chemical in question is chloranil (CASRN 118-75-2).

Company Information

NFC is a privately owned specialty chemical producer with approximately $25 million in annual 

revenue (2010) and approximately 40 percent of manufacturing is for toll sales. The company has 85 

employees and at a single site located in South Carolina (SOCMA, 2010).

Nation Ford Chemical can be classified under NAICs 325998, All Other Miscellaneous Chemical 

Products and Preparation Manufacture (Dunn and Bradstreet, 2014). The Small Business Administration 

defines a small business in this NAICs code as one that has 500 employees or fewer (SBA, 2014). Because 

NFC has approximately 85 employees (SOCMA, 2010) it qualifies as a small business. 

Market Information

Chloranil is used as an intermediate in the manufacture of a number of products, including 

certain colorants (Robinson, 2007). Of particular interest to NFC is its use in the manufacture of 

carbazole pigment violet 23 (PV 23) (CASRN 6358-30-1).

Chloranil

There are no reports of manufacture or import of chloranil to the most recent Chemical Data 

Reporting (CDR) (EPA, 2014). [CBI]

NFC claims that Clariant Chemical Ltd. (Clariant) is the sole source of this chemical (NFC, 2014b).

NFC’s interest in importing chloranil stems from a desire to improve the production process for 

PV 23 resulting from concerns about the company’s ability to remain competitive in the market.

Currently, NFC uses dianil (CAS 380546-37-8) to produce PV 23. According to NFC, market conditions are 

such that it has been investigating alternative approaches to manufacturing PV 23 and has found that a 

process using chloranil would produce PV 23 more efficiently. Clariant is currently the only source of 

chloranil for NFC (and is a direct competitor in the final product market – see below). Therefore, NFC is 
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seeking to begin importation of chloranil from China in a manner that would allow them to remain 

competitive in the final product (PV 23) market (NFC, 2014a).

Carbazole Pigment Violet 23 (PV 23)

PV 23 is used as a colorant in inks, plastics, rubber, coatings, and fibers among other things 

(Dyestuff Intermediates, 2014). PV 23 can refer to both crude and finished product. Crude PV 23 is solely 

used to produce finished PV 23 which takes the form of presscake and dry color (USITC, 2010). Crude PV 

23 must be further processed to produce presscake and dry color which involves additional cost and 

adds value. Therefore, prices for finished product PV 23 are higher than for PV 23. There are no direct 

substitutes for PV 23 (USITC, 2010).

According to EPA’s most recent CDR information, PV 23 was produced (manufactured and/or 

imported) by six companies in 2012. The companies and their production volumes are reported in Table 

1. It is not clear if the production volumes represent crude or finished product PV 23, however, in 2010,

Table 1. Producers and Production Volumes for PV23

Company Name Manufacture or 

Import

2012 Production 

Volume (lbs.)

Previous Year’s 

Production Volume 

(lbs.)

Heucotech, Ltd. Import 126,000 75,158

Flint Group [CBI] [CBI] 105,911

DIC Americas 1[CBI] [CBI] 120,537

Shanco [CBI] [CBI] 56,966

Nation Ford Chemical Manufacture 444,910 307,460

[CBI] [CBI] [CBI] [CBI]

1

Sun Chemical is a member of the DIC Group of companies.

the U.S. International Trade Commission (USITC) found that NFC accounted for 100 percent of the U.S. 

production of PV 23 crude and that NFC’s production of PV 23 crude is exclusively produced through its 

toll agreement with Sun Chemical, Inc. (USITC, 2010). This implies that the remaining imports are of 

finished product. It is still possible that some of the imports are crude PV 23 that is subsequently 

processed into final product in the U.S. since the CASRN does not distinguish between the two forms of 

the chemical. According to the USITC, NFC has been able to provide Sun’s entire crude PV 23 needs since 

2009 (USITC, 2010), however, given that Sun has recorded some import of PV 23 (crude and/or finished 

product) it is not clear that this is happening at this time. In the past, Sun has decreased its toll 

purchases from NFC and increased imports or lowered tolling fees to NFC in order to respond to market 

forces, although Sun has testified that it does have an interest in maintaining a secure U.S. supply source 

for crude PV 23 (USITC, 2010).

Regardless of whether imports of PV 23 are in crude or finished form, it appears that NFC 

controls a large portion of the domestic market. However, because PV 23 is used for a variety of end 

products, it is expected that the market and price for PV 23 is driven by the markets and prices for the 

final end products (e.g., printer inks). The demand for PV 23 has remained relatively stable (USITC, 2010) 

which suggests that strong growth in the overall market is not expected, however, CDR data indicate an 

increase in total volume (adding all forms, crude and finished product together) of almost 24 percent

from 2010 to 2012 (EPA, 2014).
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In 2004, the USITC investigated a petition from NFC and Sun Chemical alleging that imports of 

PV 23 from India were being subsidized and that imports of PV 23 from India and China were being sold 

at less than fair market value in the U.S. The USITC prepared a report concluding that under the U.S. 

Tariff Act of 1930, the U.S. market was materially injured by these imports and an antidumping duty 

order was imposed. In 2010, USITC revisited the situation and came to the determination that 

revocation of the antidumping duty orders would still materially injure the U.S. “within a reasonably 

foreseeable time” (USITC, 2010). During its investigations, the USITC conducted extensive reviews of the 

market for PV 23.

The USITC studies point to a market that is particularly sensitive to price changes. There is 

moderate to high substitutability between imported and domestic product. While quality of product is a 

consideration (top ranked) in choosing a PV 23 supplier, price (second ranked) was also an important 

consideration (USITC, 2010). The investigation also showed that both China and India have capacity to 

produce large volumes of PV 23 and that these countries have incentive to increase their exports to the 

U.S. (USITC, 2010). When the USITC imposed anti-dumping orders , producers exporting to the U.S. were 

found to shift their exports to downstream products (such as inks) the contain PV 23 but are not subject 

to the orders further demonstrating a desire to supply the U.S. market (USITC, 2010). In the past, the 

domestic industry’s financial performance has been found to suffer due to decreasing prices resulting 

from imports from China and India (USITC, 2010).

According to NFC, their current selling price for PV 23 is $[CBI]/lb. This price is slightly higher 

than the price that is available on the market at $[CBI]/lb. (NFC, 2014b). NFC has stated that they have 

been able to hold market share because of the quality and consistency of their product, however that 

share is beginning to diminish (NFC, 2014c). While the production volume increases from 2010 to 2012 

do not support this argument, it is plausible given the price sensitivity of the product. Additionally, the 

USITC indicated that, as a result of installation of new production process equipment, NFC had 

significantly reduced production capacity from 2006 to 2008. During this time, Sun sourced crude PV 23

from China and India. NFC reported that it was able to return to producing Sun’s PV 23 requirement in 

mid-2009 (USITC, 2010). It is possible that the growth in production by NFC from 2010 to 2012 was 

partially from regaining previously held market share rather than an expansion of the market.

Cost of Testing

The Economic Analysis of Final Section 4 Testing Rule for Chemicals Potentially Contaminated 

with Polyhalogenated Dibenzo-p-dioxins and Polyhalogenated Dibenzofurans (D/F Test Rule) developed 

estimates of costs associated with testing required by the test rule (EPA, 1987). Because the rule was 

finalized over 17 years ago, it is reasonable to expect that the estimated costs have changed 

significantly. Factors that would contribute to changes include increases due to rising costs (e.g., labor, 

materials) over time and decreasing costs due to things such technological advances in testing 

approaches and methodology developments, etc. However, it is reasonable to expect that some of the 

activities outlined in the economic analysis for the rule would still occur. The economic analysis of the 

rule identifies methodology development, synthesis of analytic standards, and sample analysis. In 

addition, NFC would need to develop and submit a study plan for review by the EPA.

Since the test rule became effective, a number of companies have submitted data to the Agency 

to comply with the rule. It is expected that contract research organizations (CROs) that are expected to 

do the testing, likely have experience with this type of testing such that costs for methodology 

development and synthesis of analytic standards are minimal. Remaining costs would be most likely to 
5

include costs for analytical testing, testing oversight, and test plan development and negotiation (if 

necessary) with EPA.

NFC developed an overall testing cost estimate of $200,000. EPA contacted NFC and received 

further explanation on the basis for the estimated cost (NFC, 2014b, c, 2014). The estimate included 

[CBI]. According to NFC, the estimate was based on [CBI]. EPA finds this estimate to be reasonable and 

uses it in the analysis below.

In its waiver request, NFC offered an alternative testing strategy to the requirements of the D/F 

test rule. Under their proposed approach, NFC would have a composite sample drawn [CBI] and have it 

tested using method [CBI]. NFC estimates the cost of this testing to be approximately $[CBI]/sample 

(NFC, 2014c). EPA, through its contractor, informally contacted SGS Environmental Services, Inc. in 

Wilmington, North Carolina, to inquire about the cost to run this test method and were told that this 

method provides a sampling protocol but that the cost to analyze the sample could be approximately 

$[CBI] per sample (Wilson, 2014). It is not clear how many samples would need to be drawn or if a 

composite sample would be sufficient, however, the analytical costs estimated by NFC seem reasonable. 

NFC has also indicted that the cost of testing [CBI]. EPA used this price to back calculate the 

potential annual cost of testing using method [CBI].

Because the potential imported volume of chloranil is not known and was not provided to EPA, 

EPA assumed that NFC will import the volume of chloranil necessary to manufacture the volume of 

crude PV 23 that is currently produced in the U.S. which is estimated to be 444,910 lbs. (based on the 

most recent CDR data provided by NFC). Using the relationship of the molecular weight (MW) of 

chloranil (246 g/mol) to the MW of PV 23 (589 g/mol), we find that:

Mass of chloranil/246 g/mol = Mass of PV 23/589 g/mol or

(246/589) x (mass of PV 23) = Mass of chloranil or

(0.42) x (mass of PV 23) = Mass of chloranil.

Therefore, 

(0.42) x (444,910 lbs.)l = Mass of chloranil = 186,862 lbs. chloranil.

If the price increase is [CBI]/lb. chloranil, then the cost of testing is approximately [CBI]/year (186,862 

lbs./year)[CBI]). As a check, 186,862 lbs. is equivalent to approximately 17 MT (186,862lbs.)/(11,000 

lbs/MT). If each lot is [CBI], then NFC would be shipping [CBI] lots of chloranil. At a testing cost of

[CBI]/lot and [CBI]/ lot, testing costs per year would amount to [CBI] and [CBI], respectively. To be 

conservative, EPA uses the highest of the three cost estimates for this method and assumes costs of 

testing each [CBI] lot will be approximately $[CBI]/year.

Additional Costs

In addition to laboratory costs, companies subject to the D/F Test Rule may experience other 

costs including administrative costs (including development of study plans, selection of laboratories, 
6

monitoring labs, and paperwork) and costs associated with complying with export notification

requirements under Section 12(b) of the Toxic Substances Control Act (TSCA). 

EPA has used costs of testing supplied by NFC of $200,000. Information provided by NFC (NFC, 

2014c) suggests that this estimate includes additional administrative costs, so no additional costs are 

included. Because NFC’s entire production of crude PV 23 (from chloranil) is estimated to be sold to Sun 

Chemicals (domestically), export notification requirements are not expected to be incurred and 

therefore, no costs have been added for export notification.

Economic Impacts and Analysis

EPA uses several approaches to evaluate the economic impact of required testing on companies. 

Two specific approaches are presented here followed by a qualitative discussion of the results. Each 

approach was designed to provide different information and, in this particular case, may be best 

considered together with the qualitative discussion.

Small Business Impacts Approach

NFC is a small business as defined by the SBA under 13 CFR 131. To evaluate the possibility of 

adverse effects on the business as a result of testing, EPAB employs an approach that compares the cost 

of testing to the company’s total sales. 

As previously stated, NFC’s total revenue is estimated to be $25 million (SOCMA, 2010). The 

cost-to-sales ratio is therefore estimated to be ($200,000)/($25 million), or 0.8 percent. When 

evaluating small business impacts for rulemakings, EPA generally has a higher level of concern when 

costs are greater than 1 percent of a company’s overall revenue.

However, NFC has stated that it is currently searching for ways to make the production of crude 

PV 23 more efficient to stem market share losses it is currently experiencing due to having a product 

priced higher than competitors (NFC, 2014c). Should the company decide that it cannot continue this 

line of business or if this line of business suffers because the business line cannot remain competitive, 

impacts could be larger for the company. Currently, estimated production volume of PV 23 is 444,910 

lbs. At the current selling price of $[CBI]/lb., this product line is valued at approximately $[CBI] million. 

Given an estimated total company revenue of $25 million, this product line would represent about [CBI]

percent ($25 million/[CBI] million) of the company’s business.1Loss of this entire business line would be 

a significant portion of the company’s overall business and decreased market share could also have 

some potential adverse impacts depending on the extent of business loss.

The cost of testing compared to the overall revenue is not at a level that would typically elevate 

concern for small business if EPA were evaluating a proposed rulemaking effort. Information was not 

provided with which to assess the level or significance of any impact on volume of sales and percent of 

market share specifically from the costs of required testing.

 

1 Approximately 40 percent of NFC’s manufacturing is toll manufacturing (SOCMA, 2010) and NFC reports that 

production of CPV23 is toll production for Sun Chemical. Therefore, it is reasonable to estimate that [CBI] percent 

of revenue is attributable to toll production of CPV23. 
7

Analysis for Adverse Economic Impacts on a Firm Approach

To evaluate whether there is a potential for adverse economic impacts as a result of the cost of

testing, EPA has employed (in the rulemaking context) a straightforward approach that compares the 

annualized cost of the testing to the annualized revenue from sales of the subject chemical. In general, 

the costs of testing are expected to increase the cost of manufacturing a chemical and could therefore, 

decrease overall profitability. If profitability falls below an acceptable level, firms may choose to 

discontinue production of that chemical, to raise prices of products, or to suffer reduced profitability

while testing costs are recouped.

The profitability of a producing and selling a chemical is measured by the flow of costs and 

revenues associated with the chemical over time. Testing is a short-term effort. Evaluations of 

profitability, however, are not only based on one or even a very few years’ results, but rather on the 

total earnings stream associated (appropriately discounted) with a chemical over time. Thus, losses in 

one year may be appropriately balanced against revenues in another to assess the net present value of 

the stream of earnings of a chemical. 

The complete net present value analysis of the profitability of a particular chemical with and 

without testing costs requires specific information on costs revenues that is difficult to obtain and only 

limited information was provided in this case. Therefore, this analysis uses a simplified screening 

approach for the potential of adverse economic impacts based on the relationship between testing costs 

and revenues. Because chloranil is an intermediate in the manufacture of crude PV 23, the revenue from 

PV 23 sales considered to be the relevant value.

Annualized Costs

Annualized costs represent the amount one would have to pay each year to add up to the same 

amount as the overall cost of the testing when those costs are presented in present value terms. The 

standard formula for annualizing a lump sum cost is given by:

A=I x [I (1+i)n – 1)]

where A equals the annualized amount, I is the initial lump sum investment cost, I is the discount rate, 

and n is the useful life of the investment.

The Office of Management and Budget’s (OMB’s) economic analysis guidance recommends that 

analysts use the opportunity cost of capital for discounting in economic analyses of regulations (OMB, 

2003). The discount rate used in this analysis is seven percent and is consistent with OMB Circular A-4. 

To determine the number of years, n, to use in the annualization formula, EPAB applied a standard 

estimate for the life of a chemical of 15 years. Under these assumptions, the annualized cost of testing 

under to NFC as a result of the required testing is approximately $22,000/yr.

In NFC’s May 16, 2014 memo, they applied a [CBI] time horizon to their cost estimate. NFC 

indicates that this is a standard time frame for business decisions related to toll manufacturing because 

of the short-term nature of the contracts with customers (NFC, 2014c). According to the USITC (2004) 

report, the toll agreement between Sun and NFC is renegotiated each year for volume and price, and 

Sun has imported crude PV 23 from China during times when NFC has been switching to new production 

systems USITC, 2010). Therefore, EPA also estimated annualized costs using a [CBI] time horizon. With a 
8

[CBI] time horizon (and seven percent discount rate), the estimated annualized cost of testing under the 

D/F Test Rule requirements is approximately $[CBI]/yr. 

Compare Annualized Testing Costs to Annual Revenues 

To estimate if the annualized costs of testing could potentially result in an adverse economic 

impact, the annualized cost of testing is compared to annual revenue from the chemical, in this case, the 

final product (crude PV 23) providing an indicator of the effect on the profitability of the chemical. A 

threshold of 1 percent was used to determine if there is a potential for an adverse impact on the 

profitability of the chemical.

The revenue from sales was not provided to EPA, therefore, EPA estimated the value of sales of 

PV 23 based on a production volume of 444,910 lbs. (EPA, 2014) and a target selling price of $[CBI], for 

estimated revenue from the product line of approximately $[CBI]/year. Results are presented in Table 2.

This revenue was compared to annualized costs of testing under a 15-year and [CBI]-year scenario to 

estimate a percentage of revenue impact. 

Table 2. Annualized Testing Cost Percent Impact on Annual Revenue

Annualization Years Annual Revenue Annualized Cost Percent of Revenue 

Impact

15 Years $[CBI] $[CBI] [CBI]%

[CBI] $[CBI] $[CBI] [CBI]%

In evaluating testing rules, EPA has used a benchmark of 1 percent of annual sales to indicate a 

level that could potentially have an adverse effect on the profitability of the product line. The results of 

this analysis show that under the 15-year chemical life scenario, the percent impact of testing costs is 

well below 1 percent, however, at under the [CBI]-year time horizon, the estimated impact exceeds 1

percent of annual revenues from the chemical. 

A company facing impacts on profitability of a product line may choose a number of options including 

raising prices to cover the loss, discontinuing (or not implementing) a particular product line, or suffer 

reduced profit for a period of time while test costs are recouped. [CBI] Given the price sensitivity of PV 

23, it is less likely that NFC would raise prices to cover the cost of testing and the company could 

experience some level of profit loss from the PV 23 product line under the [CBI] scenario. And, given the 

significant portion of business that this product line appears to represent, [CBI], it is less likely that NFC 

can entirely forego profits to cover the costs of testing, however it is not possible to determine from the 

information provided if some level of profit loss could be sustained until testing costs are recouped.

Using an approach comparing estimated annualized revenues of the PV 23 product line and the 

annualized cost of testing to identify the potential for adverse impacts on PV 23’s profitability, it appears 

that there is a potential for adverse impacts to the profitability of NFC’s PV 23 product line as a result of 

test costs. However, the information supplied is insufficient to assess the magnitude of any adverse 

impact on profits, how long that adverse effect might occur, the implications of any adverse impact 

(such as whether impacts are short-term with a subsequent return to normal or increased profits after 

testing costs have been recouped or are a more permanent effect on profits), or whether the impact 

would effectively prevent NFC from importing the intermediate, chloranil. 
9

Conclusions

NFC has applied for a waiver to requirements for testing chloranil under the D/F Test Rule citing 

40 CFR 766.32(a)(2)(ii) which states that the regulations allow for a waiver from testing if "in the 

judgment of EPA, the cost of testing would drive the chemical substance off the market, or prevent 

resumption of manufacture or import of the chemical substance, if it is not currently manufactured, and 

the chemical substance will be produced so that no unreasonable risk will occur due to its manufacture, 

import, processing, distribution, use, or disposal.” NFC is interested in importing chloranil for the sole 

purpose of manufacturing crude PV 23. Currently, there is one domestic source of chloranil, Clariant 

Corporation, who is also a direct competitor with NFC in the crude PV 23 market. Because chloranil is an 

intermediate used to create an end product for NFC, this analysis evaluates the effects of the cost of 

testing on the end product (PV 23) assuming that it will drive decisions on the intermediate, chloranil.

NFC is currently in a position whereby a significant portion of its revenues (estimated to be38 

percent) are derived from a toll agreement to produce crude PV 23 for Sun Chemical. According to NFC, 

they are currently [CBI] (NFC, 2014c). This was not verified by an observed [CBI]; however, the most 

current production volume data are from 2012. Because price plays an important role in customer 

decisions about PV 23 suppliers (USITC, 2010), it is not unreasonable to expect that [CBI]. NFC has 

identified a process to produce PV 23 at a competitive price ([CBI]) that would require using chloranil. In 

order to move to this alternative production process, NFC would like to be able to import chloranil 

directly rather than have to purchase it from Clariant, Corporation.

Using a standard approach for evaluating small business impacts for purposes of rulemaking, 

the cost of testing is below one percent of overall company sales. EPA generally has a higher level of 

concern when costs are greater than 1 percent of a company’s overall revenue. Should the company 

decide that it cannot continue this line of business, or if this line of business suffers because the 

business line cannot remain competitive, impacts could be larger for the company because of the 

significance of this business line for NFC. However, under this part of the assessment, the information 

supplied by NFC did not give EPA a reasonable basis to determine that testing costs would cause the 

company to discontinue this business line. Information was also not provided that EPA could use to

assess the level and significance of any impact on volume of sales and percent of market share 

specifically from the costs of required testing.

EPA also evaluated the potential for adverse impacts on the product line of PV 23 by comparing 

the discounted stream annualized of costs to the annual revenue of PV 23. Assuming a 15 year time 

frame as the “life of the chemical”, the estimated impact is [CBI] percent of sales. However, assuming a 

shorter time frame of [CBI], which NFC has claimed is the term of a toll contract, the estimated impact is 

[CBI] percent of the sales of PV 23. In evaluating testing rules, EPA has used test costs as 1 percent of 

annual sales as a benchmark to indicate a level that could potentially have an adverse effect on the 

profitability of a product line. While it does appear that there is a potential for an adverse effect on 

profitability, the information provided did not allow EPA to assess the level of adverse impact on profits, 

how long that adverse effect might occur, the implications of any adverse impact (such as whether 

impacts are short-term with a subsequent return to normal or increased profits after testing costs have 

been recouped or are a more permanent effect on profits), or whether the costs would cause NFC to

discontinue the product line and not import the intermediate, chloranil. 
10

Under EPA’s standard measures for impacts of costs for rulemakings, it seems that there is 

potential for some adverse effects on the profitability (e.g., reduced or lost profit) of NFC’s PV 23

production line. However, the information provided by NFC did not give EPA a reasonable basis to 

determine the likelihood or level of any potential adverse effect, and thus, did not give EPA a reasonable 

basis to determine that NFC would be effectively prevented from importing chloranil if it had to pay for 

the testing of the imported chloranil as specified under the D/F Test Rule. 
11

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