Under 40 CFR 705.10, the reporting obligation falls to the “persons who have manufactured” (including imported) the PFAS. It is ultimately the domestic manufacturer’s (including importer’s) responsibility to report appropriately under the rule, notwithstanding the complexity of its own business structure. If a foreign company is reporting on behalf of a manufacturing site, they must provide their U.S. site address in CDX to comply with CROMERR (Cross-Media Electronic Reporting Regulation; see https://www.epa.gov/cromerr). Further, the rule requires information to reflect all known or reasonably ascertainable information in possession or control of that manufacturing site and its subsidiaries or general partnerships and their relevant employees, as defined in the rule.
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