928. If a federal facility manufactures 19,000 pounds of an EPCRA section 313 chemical and imports another 7,000 pounds of that same chemical during the reporting year, is the facility required to report for this chemical?
Yes. For the reporting year, the federal facility would have exceeded the manufacture threshold of 25,000 pounds ([19,000 manufacturing] + [7,000 importing] = 26,000) for this EPCRA section 313 chemical. Note that importing is the equivalent of manufacturing, and therefore the two “manufactured” quantities must be added for threshold determinations.