What They Imported

From 2020 through 2023, a chemical importing company operating out of a facility on 5 Skidaway Village Walk in Savannah, Georgia brought more than 25,000 pounds per year of five separate chemical substances into the United States. The company is MacroSource, LLC. The chemicals are known in the public record only as Chemicals A, B, C, D, and E.

Their actual names are redacted. The EPA consent agreement filed July 13, 2026 states that any information which may support or form the basis for the case has been “intentionally redacted” and classified as Confidential Business Information. To determine the identity of the chemical substances, the document instructs readers to refer to an “Opportunity to Show Cause” letter dated October 2, 2025.

That letter is not attached to the public docket.

What we know is this: Chemicals A, B, C, D, and E were in the TSCA Master Inventory File at the beginning of the submission period described in federal regulation 40 C.F.R. Section 711.20. They were not chemical substances specifically excluded from Chemical Data Reporting requirements by 40 C.F.R. Section 711.6. MacroSource imported them for commercial purposes. MacroSource knew the reporting threshold. MacroSource did not report them.

For four years, the company operated in silence.

The Law They Broke

Section 8(b) of the Toxic Substances Control Act requires the EPA to compile, keep current, and publish a list of each chemical substance that is manufactured or processed in the United States. The list is commonly known as the TSCA Inventory. It is the baseline record of what chemicals exist in American commerce.

To maintain that list, Section 8(a) of TSCA requires companies that manufacture or import more than 25,000 pounds of a reportable chemical per year to file Chemical Data Reporting forms. The reporting threshold is not ambiguous. 25,000 pounds equals 11,340 kilograms. 2,500 pounds equals 1,134 kilograms. MacroSource crossed both thresholds annually from 2020 through 2023.

Pursuant to 40 C.F.R. Section 711.15, any person subject to the CDR rules must submit the required information for each chemical substance they manufacture or import for commercial purposes in an amount of 25,000 pounds or more. The 2024 submission period ran from June 1, 2024 until November 22, 2024. Companies were required to submit 2024 CDR Reports for all calendar years 2020, 2021, 2022, and 2023 during that window.

MacroSource did not submit a CDR Report for Chemicals A, B, C, D, and E by November 22, 2024. On September 25, 2025, ten months after the deadline, MacroSource submitted a 2024 CDR Report for Chemicals A, B, C, D, and E.

The EPA issued a Notice of Inspection on May 19, 2025. On June 6, 2025, MacroSource submitted certain records pertaining to exportation and importation of chemicals. The EPA conducted an inspection at the Savannah facility on June 17, 2025. On October 30, 2025, after reviewing the import records MacroSource provided, the EPA issued an Opportunity to Show Cause letter alleging violations of Sections 8 and 15 of TSCA.

On November 24, 2025, MacroSource provided a response to the Opportunity to Show Cause letter accepting the potential violation.

The Non-Financial Ledger

Chemical Data Reporting is not a punitive regulatory scheme. It is an information-gathering system. The EPA does not use CDR filings to issue fines or shut down facilities. It uses them to understand what chemicals are entering the country, where they are going, and in what quantities.

When a chemical importing company does not file CDR forms, the result is not a regulatory violation in the abstract. The result is a data void. Emergency responders do not know what substances are stored at the facility. State environmental agencies cannot track potential contamination sources. Community members cannot access the TSCA Inventory to understand what is being manufactured or imported in their area.

MacroSource’s Savannah facility is located at 5 Skidaway Village Walk. The surrounding area includes residential neighborhoods, wetlands, and the Skidaway River. Savannah is a major port city. Chemical importing operations are common. Transparency is not.

From 2020 through 2023, anyone searching the TSCA Inventory for information about what MacroSource was importing would have found nothing. Not because the chemicals were exempt. Not because the quantities were below the reporting threshold. Because MacroSource chose not to file.

The consent agreement does not quantify the impact of that silence. It does not estimate how many emergency planning committees lacked the data they needed. It does not count how many community meetings were held without knowledge of what was being stored less than a mile away.

It simply states the facts: MacroSource imported reportable chemicals. MacroSource did not report them. MacroSource has now paid a fine.

Legal Receipts

Societal Impact Mapping

Environmental Degradation

The consent agreement does not disclose what Chemicals A, B, C, D, and E are. It does not disclose their toxicity profiles, their environmental persistence, or their potential to bioaccumulate. What it does disclose is that MacroSource imported more than 25,000 pounds of each substance annually into a facility located in a coastal city with significant wetland ecosystems.

Savannah’s proximity to the Skidaway River and the Atlantic Ocean means that any chemical spill, leak, or improper disposal at the MacroSource facility could directly impact aquatic habitats. Without CDR data, state and federal environmental agencies cannot conduct proactive risk assessments. They cannot model contamination pathways. They cannot establish baseline monitoring protocols.

The absence of reporting creates an information asymmetry. The company knows what it is importing. The regulators do not. The public does not. The river does not care.

Public Health

Chemical Data Reporting exists to serve multiple regulatory functions, but its most direct public health application is emergency planning. Under the Emergency Planning and Community Right-to-Know Act (EPCRA), local emergency planning committees use CDR data to understand what hazardous substances are present in their jurisdictions.

When a fire breaks out at a chemical facility, first responders need to know what they are walking into. When a transportation accident occurs, hazmat teams need to know what chemicals are on the truck. When a storage tank ruptures, public health officials need to know what just entered the groundwater.

MacroSource’s failure to report Chemicals A, B, C, D, and E for four years means that emergency planning committees in Savannah were operating with incomplete data. If an incident had occurred at the facility between 2020 and 2023, responders would not have had access to CDR filings that should have existed.

The consent agreement does not mention any incidents. It does not state that harm occurred. But it documents a gap in the system that is designed to prevent harm. That gap existed for four years.

Economic Inequality

The $115,500 penalty is not small. For an individual, it would be financially catastrophic. For a limited liability company operating an international chemical importing business, it is a cost of doing business.

The consent agreement does not disclose MacroSource’s annual revenue. It does not disclose the market value of the chemicals the company imported. It does not disclose the profit margins on 25,000 pounds of Chemicals A, B, C, D, and E.

What it does disclose is that MacroSource’s CEO, Brent Harlander, signed the agreement on June 25, 2026. The signature appears on page 11 of the docket. His title is Chief Executive Officer. His address is 5 Skidaway Village Walk, Savannah, GA 31411.

The penalty will be paid. The chemicals will remain redacted. The business will continue.

What Now?

Corporate leadership at MacroSource, LLC:

• Brent Harlander, Chief Executive Officer (signed the EPA consent agreement on June 25, 2026)

If you live in Savannah or Chatham County, Georgia, you can file a Freedom of Information Act (FOIA) request with the EPA to obtain the unredacted “Opportunity to Show Cause” letter dated October 2, 2025. That letter may contain the actual identities of Chemicals A, B, C, D, and E.

You can also contact your local emergency planning committee to ask whether they have CDR data for the MacroSource facility at 5 Skidaway Village Walk and whether that data was available between 2020 and 2023.

Community organizing works. Transparency is not granted. It is demanded.