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Helpful Hints for Completing EPA's Class II Reporting Forms

Overview

This “helpful hints” document for completing EPA’s Class II reporting forms provides insight to common errors made by reporting entities when completing reporting forms.  It also highlights notable revisions made to previous versions of reporting forms.  This quick reference serves to clarify EPA’s data collection needs and improve data quality.

There are 7 Class II reporting forms available for use from EPA.

  1. Class II Producer Quarterly Report
  2. Class II Importer Quarterly Report
  3. Class II Exporter Quarterly Report
  4. Notification of Class II Allowance Transfers
  5. Request for Additional Class II Consumption Allowances
  6. Class II 2nd Party Destruction Annual Report
  7. Class II 2nd Party Transformation Annual Report

*Note: For Petitions to Import Used Class II Substances, please see http://www.epa.gov/ozone/title6/imports/usedclasstwo.html

Click on the link(s) for the form you are interested in.  If you are not sure what form(s) pertains to your company, please refer to What Forms Should I Complete?  If you need further assistance, please contact:

Elizabeth Whiteley
Stratospheric Protection Division
United States Environmental Protection Agency
(202) 343-9310
whiteley.elizabeth@epa.gov

Hints for Completing the "Class II Producer Quarterly Report"

Purpose: This form is used to capture U.S. production of Class II substances.

Reporting Frequency: Quarterly

Helpful Hints:

  1. Companies should report production totals to EPA for every quarter.  If an entity has zero production for a given quarter, the entity should submit a fax or email to Mike James (fax #: 202-343-2336) to confirm zero production.  If a company fails to report or indicate no production for a quarter, EPA is unable to determine whether that is an indication of zero production or if an entity’s report was not received.  If your company has not produced a Class II substance for at least a year and does not intend to produce a Class II substance during the following year, it is not necessary to report zero production.

  2. In “Section 2.2: Company Production Totals”, In-House Transformation (column C) refers to the amount of Class II substance produced in a particular quarter for the purpose of transformation.  It does not capture the amount of Class II substance actually transformed in the quarter, although the amount may be the same if the total amount produced for transformation was transformed in that same quarter.  2nd Party Transformation (column D) refers to an amount of Class II substance that was produced for 2nd party transformation.  Only the actual producer of Class II substance should use this form to report.  This form should not be used by an entity transforming Class II substances that it did NOT produce the Class II substance.  The “Class II 2nd Party Transformation Report” is available for entities reporting transformation of Class II substances that they did not produce. 

  3. In “Section 2.2: Company Production Totals”, In-House Destruction (column E) refers to the amount of Class II substance produced in a particular quarter for the purpose of destruction in-house.  It does not capture the amount of Class II substance actually destroyed in-house in the quarter, although the amount may be the same if the total amount produced for destruction was destroyed in that same quarter.  2nd Party Destruction (column F) refers to amounts of Class II substances that were produced for 2nd party destruction.  Only the actual producer of the Class II substance being destroyed should complete this reporting form.  This form should not be used by an entity destroying Class II substances that it did NOT produce.  The “Class II 2nd Party Destruction Report” is available for entities reporting destruction of Class II substances that they did not produce. 

  4. In “Section 2.2: Company Production Totals,” Net Production of HCFC (Column I) should be calculated by subtracting amounts captured in columns C through H from Gross Production (Column B).  Please use this equation to accurately capture data.

  5. Any producer that reports producing material that will be destroyed or transformed by a 2nd party must include a 2nd Party Destruction and/or 2nd Party Transformation verification letter where the 2nd party states their “intent to destroy and/or transform” the Class II substances during the given reporting year.  This ensures both the producer and EPA that material will be destroyed and/or transformed. In addition, if the material is sold to more than one 2nd party, the producer must provide a list of quantities shipped to each 2nd party destroyer and/or transformer during that quarter.

  6. Any producer that produces HCFC-141b under the HCFC-141b exemption must provide in Section 3.3 the name(s) of HCFC-141b exemption allowance holders from whom orders were received and the associated quantity of HCFC-141b requested and produced.

Notable Changes: None


Hints for Completing the "Class II Importer Quarterly Report"

Purpose: This form is used to capture information related to all imports of Class II substances into the United States and how the Class II substances will be used.

Reporting Frequency: Quarterly

Helpful Hints:

  1. 1.    Companies should report import totals to EPA for every quarter.  If an entity has zero imports for a given quarter, the entity should submit a fax or email to Mike James (fax #: 202-343-2336) to confirm zero imports.  If a company fails to report or indicate no import for a quarter, EPA is unable to determine whether that is an indication of zero imports or if an entity’s report was not received.  If your company has not imported a Class II substance for at least a year and does not intend to import a Class II substance during the following year, it is not necessary to report zero imports.

  2. In “Section 2: Transaction Records,” the “Source Country” should be the country where the Class II substance originated.  If, for instance, the Class II substance is shipped from Country A, then to Country B, and then to U.S., the importer should list Country A as the “Source Country.

  3. In “Section 3.2: Company Import Totals,” Gross Imports (Column B) does not include ‘Heels’ or ‘Used’ Class II substances for EPA’s reporting purposes.  Please do not include “used” and “heel” imports in the “gross import” total (Column B).  Those amounts should be reported separately in columns I and J, respectively. 

  4. In “Section 3.2: Company Import Totals,” “In-House Transformation/Destruction” refers to amounts of Class II substances transformed or destroyed by the importing company.  “2nd-Party Transformation/Destruction” refers to amounts of Class II substances transformed or destroyed by an entity other than the importing company (i.e., an importer brings in the substance and then sends it offsite for destruction).

  5. Any importer that is providing material to be destroyed and/or transformed by a 2nd party must include a 2nd Party Destruction and/or 2nd Party Transformation verification letter where the 2nd party states their “intent to destroy and/or transform” the Class II substance during the given reporting year.  This ensures both the importer and EPA that material will be destroyed/transformed. In addition, if the material is sold to more than one 2nd party, the importer must provide a list of quantities shipped to each 2nd party destroyer and/or transformer during that quarter.

  6. Any importer that imports HCFC-141b under the HCFC-141b exemption must provide in Section 4.3 the name(s) of HCFC-141b exemption allowance holders from whom orders were received and the associated quantity of HCFC-141b requested and imported.

Notable Changes:

  1. The ‘Quantity of Commodity’ and ‘Port of Exit from Source Country’ are no longer required fields in Section 2.


Hints for Completing the "Class II Exporter Quarter Report"

Purpose: This form is used to capture information about Class II exports.

Reporting Frequency: Quarterly

Helpful Hints:

  1. In “Section 2: Transaction Records,” a transaction should be marked as ‘Produced or Imported with Production and/or Consumption Allowances’ if allowances were expended when the material was produced or imported.  This is the case even when the exporting company was not the company that expended the allowances.

Notable Changes:

  1. The ‘Quantity of Commodity’ and ‘Exporting Vessel on which the export was shipped’ are no longer required fields in Section 2.

 

Hints for Completing the "Notification of Class II Allowance Transfers"

Purpose: This form is used to capture trades of Class II Production Allowances, Consumption Allowances, or Article 5 Allowances.

Reporting Frequency: A form should be sent by the transferor to EPA for every transfer request.  This may happen more than once, or not at all, in any particular quarter.

Helpful Hints:

  1. Note that inter-pollutant transfers of Baseline Year Allowances will not be approved
  2. When calculating 2.6 and 2.9 in Section 2, please note that these values should not be rounded. Only the quantities calculated in 2.10 and 2.11 should be rounded to the closest whole number.

Notable Changes: None


Hints for Completing the "Request for Additional Class II Consumption Allowances"

Purpose: This form is for exporters requesting consumption allowances after exporting Class II material that was produced or imported into the U.S. with expended consumption allowances.

Reporting Frequency: For every request for additional Class II consumption allowances.

Helpful Hints:

  1. For each transaction that is reported, the following documentation must be provided: (1) a copy of the bill of lading indicating the net quantity of Class II material shipped and (2) a copy of the invoice documenting the sale of the Class II material to the purchaser.  To assist in the timely review of these requests, EPA requests that reporters number the bill of ladings and invoices to indicate which documents correspond to each transaction.  In addition, EPA requests that reporters highlight or circle the quantity of interest on the bill of lading and invoice so that it is clear which entry corresponds to the quantity in the request.
  2.  Please consider timing when making requests for additional consumption allowances. The agency will review all documentation and issue a notice to either deny the request or grant the request. If the agency reimburses consumption allowances, the granting of such allowances will be effective on the date the notice is issued.  Companies may not engage in any activity that expends these allowances prior to the date the notice is issued.

Notable Changes:

  1. The ‘Quantity of Commodity’ is no longer a required field in Section 2.

Hints for Completing the "Class II 2nd Party Destruction Report"

Purpose: The form is used to collect information on Class II substances that were destroyed by any entity that did not produce or import the material (a “2nd” party).

Reporting Frequency: Annually

Helpful Hints:

  1. EPA has found that some companies will submit 2nd-party destruction amounts on the producer report, even if they are NOT the producer of the chemical that was destroyed.  This is not the correct procedure.  Only the actual producer of the chemical should indicate, on the Producer Report, the amount that they “produced” for 2nd party destruction.  Therefore, EPA has created a Class II 2nd Party Destruction Report. This report should be used by any purchaser that destroys the chemical as a “2nd party” (i.e., an entity that did NOT produce the chemical).
  2. All parties that purchase or receive Class II controlled substances for destruction must provide the producer or importer of the Class II substance with a destruction verification that includes: (a) Identity and address of the person intending to destroy the Class II controlled substances; (b) Indication of whether the Class II substances will be completely destroyed, or less than completely destroyed, in which case the destruction efficiency at which such substances will be destroyed must be included; (c) Period of time over which the person intends to destroy the Class II controlled substances; and (d) Signature of the verifying person.

Notable Changes: None


Hints for Completing the "Class II 2nd Party Transformation Report"

Purpose: The form is used to collect information on Class II substances that were transformed by any entity that did not produce or import the material (a “2nd” party). 

Reporting Frequency: Annually

Helpful Hints:

  1. EPA has found that some companies will submit 2nd-party transformation amounts on the producer report, even if they are NOT the producer of the chemical that was destroyed.  This is not the correct procedure.  Only the actual producer of the chemical should indicate, on the Producer Report, the amount that they “produced” for 2nd party transformation.  Therefore, EPA has created a Class II 2nd Party Transformation Report. This report should be used by any purchaser that destroys the chemical as a “2nd party” (i.e., an entity that did NOT produce the chemical).

  2. All parties that purchase Class II controlled substances for transformation must provide the producer or importer of the Class II substance with a transformation verification that includes: (a) Identity and address of the person intending to transform the Class II controlled substances; (b) The quantity (in kilograms) of Class II controlled substances intended for transformation; (c) Identity of shipments by purchase order number(s), purchaser account number(s), by location(s), or other means of identification; (d) Period of time over which the person intends to transform the Class II controlled substances; and (e) Signature of the verifying person.

Notable Changes: None


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