I manufacture a chemical on the Inventory however I manufacture it solely for export. Persons who manufacture chemicals solely for export are considered manufacturers for purposes of the IUR and do need to comply with the regulations. I manufacture an substance solely for export for what would be considered a non-TSCA use such as a cosmetic or device as those terms are used in TSCA section 3. We hasten to add that under the specific circumstances you have described the line between reportability and nonreportability is very thin. It is certainly safer practice to simply report the substance in question if there is any doubt in your mind about the applicability of the exemption.
Some substances are exempt.
These four categories are described at 40 CFR 719.26 and are briefly described below. Persons are reminded that each of these exemptions are qualified, meaning the applicability is dependent on a variety of circumstances. The regulations clearly describe the circumstances when the exemptions are applicable. Persons should review the applicable regulations carefully if they believe an exemption may be applicable. Note that there is no penalty for reporting substances which one is not required to report.