California doesn't use Tier2 Submit at all. Every facility files through the California Environmental Reporting System, and the fees and deadlines that apply to you depend on which local agency actually administers your area.
CERS -- the California Environmental Reporting System -- was built by CalEPA to consolidate hazardous materials reporting under the state's Unified Program. It's the only way to file; .t2s exports from Tier2 Submit aren't accepted.
California layers its own reporting thresholds on top of the federal ones: facilities must report at 500 pounds of a solid, 55 gallons of a liquid, or 200 cubic feet of compressed gas -- lower, in some cases, than the federal 10,000-pound default.40 CFR 370.10 Both aboveground and underground storage tanks containing hazardous materials need to be reported.
The annual deadline is March 1st statewide -- but here's the part that catches people out: your local Certified Unified Program Agency, or CUPA, can set its own deadline on top of that. If your facility operates in multiple jurisdictions, don't assume every location is working from the same date.
You register for a CERS account using your EPA ID number and business information, then work through the Tier II module: facility information, contacts, chemical storage locations, inventory, and attached SDSs. Once certified, you generate a submittal batch and submit it to your administering agency -- your CUPA, or in some jurisdictions the state acting as PA.
The fee isn't a fixed statewide number the way it is in some other states. After you submit, your CUPA sends an invoice, and the amount depends on their own fee schedule. This is the single biggest structural difference between California and most other states in this list: there's no one number to budget for in advance, and a facility with locations across several counties may be paying several different rates.
Hazardous materials recycled entirely on-site are exempt from reporting, but the moment they're sent to an off-site recycling facility, full reporting kicks back in -- a distinction that's easy to miss if you're thinking of recycling as categorically exempt rather than location-dependent. Battery reporting also has its own specific guidelines, updated as recently as March 2022, so if your facility stores various battery types, don't assume older guidance still applies without checking.
And any substantive change to your inventory -- not just the annual filing -- has to be reported to your CUPA within 30 days. That's a shorter, more frequent obligation than the once-a-year rhythm most facilities plan around.
HazRecord tracks your chemical inventory, storage locations, and SDS records continuously, which matters more in California than in most states given the 30-day substantive-change reporting window. When it's time to file, having current data ready to transcribe into CERS turns a multi-day CUPA-by-CUPA reconciliation into a much shorter task.
This guide is for general informational purposes only. It is not legal advice. Facilities remain responsible for verifying and submitting required reports to the appropriate federal, state, tribal, and local agencies.
HazRecord helps facilities organize chemical inventory, SDS records, storage locations, and Tier II reporting preparation in one place.