Key takeaways
- CROMERR sets no deadline for pretreatment programs. The December dates in circulation belong to the NPDES eReporting Rule. On EPA’s approved-deadlines list (updated May 14, 2026), most states hold alternate deadlines, nearly all of them December 21, 2028. Those deadlines cover the program’s own annual report, not industrial user reporting.
- CROMERR applies only if a pretreatment program chooses to accept electronic reports from industrial users in lieu of paper. CROMERR itself never forces a program off paper. Separate state or permit requirements can differ.
- No software carries blanket CROMERR approval. EPA can pre-vet an off-the-shelf system, but each program still needs EPA approval of its own application.
- Per EPA’s CROMERR FAQ (updated October 2025), most approvals typically run 6 to 12 weeks. That timeline covers applications built on pre-vetted off-the-shelf solutions or Shared CROMERR Services. Custom-built systems can take a year or more.
- EPA’s sign-off is one approval among several. Pretreatment program changes also go through the program’s Approval Authority under 40 CFR 403.18. The Approval Authority decides whether a change needs full review or 45 days’ notice.
Most of what’s circulating about CROMERR gets at least one thing wrong
If you run an industrial pretreatment program, you’ve probably heard CROMERR mentioned with some urgency lately: a December deadline, sometimes a software pitch, usually secondhand from a conference session or a neighboring program. Details get lost that way. Working alongside programs going through this, we’ve seen the same five misunderstandings come up again and again. Here they are, checked against EPA’s current guidance.
Mistake 1: “There’s a CROMERR deadline coming.”
CROMERR has no deadline. It’s the Cross-Media Electronic Reporting Rule, on the books since October 2005 at 40 CFR Part 3. It sets standards for how programs receive electronic reports, not dates by which to do it. The December dates you’ve heard belong to a different regulation: the NPDES eReporting Rule. EPA describes those deadlines on its approved-deadlines page (updated May 14, 2026):
“A State may request to establish an alternative compliance deadline of up to three years beyond the currently applicable date but not beyond December 21, 2028.”
— EPA, Approved Alternate Phase 2 Compliance Deadlines (page updated May 14, 2026)
That passage covers state requests under the eReporting rule. CROMERR appears nowhere in it. The eReporting rule’s Phase 2 deadline was December 21, 2025. Per EPA’s list, most states hold approved alternate deadlines, nearly all December 21, 2028. The rule fixes that ceiling (40 CFR 127.24, current as of August 2026); no state request can go beyond it.
The eReporting rule still touches pretreatment programs. Its Appendix A lists POTW pretreatment program annual reports (the 40 CFR 403.12(i) report) among the data states must collect electronically; the deadline is your state’s approved date. That report is the program’s own. Reports your industrial users send you are a separate question, covered in mistake 2.
EPA’s memos on the November 2025 extensions went to state NPDES agencies and regional offices, not pretreatment programs. If your state’s deadline changed and nobody told you, that’s why.
Mistake 2: “Going electronic is one decision.”
Going electronic is two decisions, not one, and programs often blur them. Your program reports out on one track; its own annual-report deadline belongs there. Your industrial users submit to you on the other. CROMERR governs only the second. EPA’s May 2024 guide for pretreatment programs says CROMERR applies when:
“you receive submissions electronically from regulated facilities … those submissions are required to be received by an EPA-authorized program, and … electronic submissions are accepted in lieu of paper submissions.”
— EPA, CROMERR: A Guide for POTW Pretreatment Programs (May 2024)
All three conditions have to hold. The third carries the most weight: in lieu of paper. You choose whether to accept electronic reports from your industrial users. CROMERR never forces you off paper. It applies once you decide electronic IU reporting is worth having, and many programs decide it is.
EPA’s “in lieu of” phrasing also permits an arrangement many programs already run: an emailed copy establishes timeliness, and the signed paper original remains the legal record. EPA’s guide says CROMERR “does not prevent programs from receiving non-CROMERR compliant regulatory data submissions by email as a ‘courtesy’ copy, so long as paper-based records of this submission with appropriate signature are separately retained as the legal copy of record.” If that’s your setup, you’re running the most common arrangement we see, and EPA explicitly allows it.
The line to watch is quiet drift. The arrangement is lawful while the signed paper original remains the legal record. If electronic copies have become the record and the paper has stopped arriving, you’re no longer in the courtesy-copy arrangement; you’re in the one that requires approval.
One group does face a real clock: programs whose regulators allowed electronic records during the pandemic and are now ending that allowance. For them the choice is binary — get approved, or go back to paper. That deadline marks the end of an accommodation, not anything in CROMERR. Mistakes 3 through 5 map the approval path.
Your state, permit, or Approval Authority can also set requirements CROMERR doesn’t, in either direction. Some Approval Authorities require CROMERR approval to keep accepting electronic records. For those programs the deadline is real; it just isn’t EPA’s.
Others are ready to move while their state agency hasn’t pursued e-reporting at all; one state still requires a wet signature. If that’s you, your state’s inaction doesn’t lock you out.
Per EPA’s May 2024 guide, a POTW submits its CROMERR application directly to EPA’s CROMERR program, whatever its state has or hasn’t done. The program-modification approval is what runs through your Approval Authority: your state where the pretreatment program is state-approved, your EPA Regional Office where it’s not. Confirm your Approval Authority’s position before scoping any work.
Mistake 3: “We need to buy CROMERR-approved software.”
No software carries CROMERR approval, not in the way vendors mean it. EPA’s May 2024 guide for pretreatment programs says:
“CROMERR is a rule and not a software certification program… EPA approves revisions to authorized, delegated, or approved governmental programs, not software packages.”
— EPA, CROMERR: A Guide for POTW Pretreatment Programs (May 2024)
EPA does pre-vet. The same guide has a category for “EPA-Vetted” off-the-shelf solutions: systems EPA has approved before, inside another program’s application. The guide also states that prior vetting “does not mean that the COTS has blanket CROMERR approval for use by any other entity.” When a vendor says “CROMERR-approved,” ask: approved for whom? Each program needs its own approval. That approval attaches to the program, not the product.
That definition protects you: the approval belongs to your program, so no vendor holds it.
You can also earn approval without buying commercial software. EPA provides Shared CROMERR Services (SCS) through its Central Data Exchange. These are pre-built components covering user registration, identity proofing, electronic signatures, and document submission and recordkeeping. You can use them through a hosted interface or plug them into an existing system. Programs we’ve worked with find these the heaviest pieces to build, and EPA has already built them. Per EPA’s CROMERR overview (updated March 2026), about 90 percent of 2022 applicants pursued off-the-shelf solutions for at least part of their system.
As of August 2026, EPA’s public SCS pages list no pricing. They note that third-party identity-proofing services carry costs. Ask EPA’s SCS team about costs before you budget.
Mistake 4: “The application is the long part.”
The application is usually the fast part. Applications built on pre-vetted components typically clear EPA in 6 to 12 weeks. EPA’s CROMERR FAQ states:
“Currently, 80-90 percent of CROMERR applications are for systems using pre-vetted commercial off-the-shelf solutions or all Shared CROMERR Services components. EPA typically approves these applications within 6 to 12 weeks and conducts the action of both completeness and approval at the same time.”
— EPA, CROMERR Frequently Asked Questions (updated October 28, 2025)
Custom-built systems are the exception: the same FAQ says those “may not achieve approval for a year or more.”
“Pre-vetted” doesn’t contradict mistake 3. Vetting means EPA approved those components before, inside other programs’ applications. EPA’s May 2024 guide still requires an application for each system, even one built from those components alone. The approval belongs to your program; the vetting explains why review runs in weeks rather than years.
The long part is the work around the application, and only your program can do it. You complete the application itself, with its checklist mapping how your system meets each requirement of 40 CFR Part 3. You also certify that electronic signatures are legally valid under your state and local statutes. The “two years” a neighboring program quoted you comes from here. In our experience, programs quoting years mean total elapsed time. Ordinance changes, public notice, and meeting calendars consume most of it; EPA’s review was rarely the longest step.
Budget most for onboarding your industrial users. Their skills range from contract-lab scientists to front-office staff. Their submissions range from two handwritten pages to a hundred pages of lab results. Give that teaching more room in the timeline than feels necessary.
Mistake 5: “Once EPA approves us, we’re done.”
EPA’s approval is one approval among several, and other people control the calendars for the rest. Accepting electronic reports from your industrial users changes your pretreatment program. Program changes go through your Approval Authority under 40 CFR 403.18. That rule sorts modifications into two categories. Substantial ones get the full approval procedure with public notice. Non-substantial ones need 45 days’ notice. The rule’s list of substantial modifications includes this catch-all:
“Other modifications designated as substantial modifications by the Approval Authority on the basis that the modification could have a significant impact on the operation of the POTW’s Pretreatment Program.”
— 40 CFR 403.18(b), current as of August 2026
The Approval Authority decides which category your change falls into. Under 403.18(d)(3), it can even reclassify a change you submitted as non-substantial during its review. The same e-reporting change can be a 45-day notification in one state and a full public-notice review in another. Ask your Approval Authority which category it expects before you submit.
EPA plus your Approval Authority still isn’t the whole list. The gating items often sit inside your own government: a commission, then a council, then a state submission packet, each with its own meeting calendar. We’ve talked with programs that cleared EPA and still sat months from requiring electronic reporting. Start early to give those slow steps the room they need.
Where to start (everything here is free)
- Check your state’s date on EPA’s approved alternate deadlines list (updated May 14, 2026).
- Read EPA’s May 2024 guide for POTW pretreatment programs. It’s short, and EPA wrote it for this decision.
- If you’re weighing the SCS route, ask EPA’s SCS helpdesk about costs before you budget: sharedcromerrservices@epa.gov or 888-890-1995, option 2. Note the scope: SCS covers registration, identity proofing, signatures, and submission. Nothing in that list manages your sampling data, scheduling, or enforcement tracking, so plan for those separately.
- EPA publishes every approved CROMERR application, including a dedicated table of approved POTW applications (page updated January 21, 2026). Read a few from programs your size to see what approval takes. As of August 2026, EPA’s public pages offer no standalone list of “vetted” systems. This table is also the practical way to see which systems have been through approvals before.
- If you want the operational win before the legal one, the courtesy-copy arrangement in mistake 2 is available today. Some programs use it to shift data entry to their industrial users now, verifying against the signed paper original. They capture most of the time saving while the paper record stays the legal one.
Frequently asked questions about CROMERR
Is there a CROMERR deadline?
No. CROMERR has been on the books since October 2005 at 40 CFR Part 3, and it sets standards for how programs receive electronic reports, not dates by which to do it. The December dates in circulation belong to the NPDES eReporting Rule. Most states hold approved alternate deadlines, nearly all of them December 21, 2028.
What is the difference between CROMERR and the NPDES eReporting Rule?
They cover different tracks. The eReporting Rule sets deadlines for what your program reports out, including the 40 CFR 403.12(i) annual report. CROMERR sets standards for the reports your industrial users submit to you, and only if you accept them electronically in lieu of paper.
Does CROMERR require our program to accept electronic reports?
No. CROMERR applies only once you choose to accept electronic submissions from industrial users in lieu of paper. It never forces a program off paper. State, permit, or Approval Authority requirements can differ, so confirm your Approval Authority’s position before assuming the choice is yours.
Is any software CROMERR-approved?
No software carries blanket CROMERR approval. EPA’s May 2024 guide states that CROMERR is a rule, not a software certification program, and that EPA approves program revisions rather than software packages. EPA does pre-vet off-the-shelf systems used in other programs’ applications, but each program still needs its own approval.
How long does CROMERR approval take?
Per EPA’s CROMERR FAQ (updated October 2025), applications built on pre-vetted off-the-shelf solutions or Shared CROMERR Services typically clear in 6 to 12 weeks. Custom-built systems may take a year or more. The long part is usually ordinance changes, public notice, and onboarding industrial users, not EPA’s review.
Can we keep accepting emailed reports without CROMERR approval?
Yes, as a courtesy copy. EPA’s guide explicitly allows programs to receive non-CROMERR-compliant submissions by email, so long as signed paper records are separately retained as the legal copy of record. The risk is drift: once paper stops arriving and the electronic copy becomes the record, you need approval.
Do we need CROMERR approval if our state hasn’t moved to e-reporting?
Your state’s inaction doesn’t lock you out. Per EPA’s May 2024 guide, a POTW submits its CROMERR application directly to EPA’s CROMERR program whatever its state has or hasn’t done. The program-modification approval runs through your Approval Authority: your state where the pretreatment program is state-approved, your EPA Regional Office where it is not.
Who else has to approve the change besides EPA?
Your Approval Authority, under 40 CFR 403.18. It decides whether your change is a substantial modification needing full public-notice review or a non-substantial one needing 45 days’ notice, and it can reclassify a change during review. Local commissions and councils often add their own meeting calendars on top.
What does Shared CROMERR Services cost?
As of August 2026, EPA’s public SCS pages list no pricing, though they note that third-party identity-proofing services carry costs. Ask EPA’s SCS helpdesk before you budget. SCS covers registration, identity proofing, signatures, and submission; it does not manage sampling data, scheduling, or enforcement tracking.
Sources
Verified August 19–23, 2026: 40 CFR 403.18, POTW Pretreatment Program Modifications (eCFR) · 40 CFR Part 127, NPDES Electronic Reporting (eCFR) · EPA Approved CROMERR Applications (updated January 21, 2026) · EPA CROMERR program page (updated June 10, 2026) · EPA Approved Alternate Phase 2 Compliance Deadlines (updated May 14, 2026) · EPA NPDES eReporting Rule Phase 2 Extension · EPA, CROMERR: A Guide for POTW Pretreatment Programs (May 2024) · EPA CROMERR FAQ (updated October 28, 2025) · EPA Shared CROMERR Services
