Does the requirement that a high volume of high-volume manufacturers produce a triennial inventory of mercury under the Reporting Rule and CDR Rule apply to high volume manufacturers?

Kilgour v. SEC , 942 F.3d 113, 122 (2d Cir. 2019) (internal quotation marks omitted). Petitioners argue that the amounts of mercury manufactured, imported, and exported can vary considerably from year to year. But notwithstanding this variance, petitioners do not establish that the asynchrony between the reporting obligations under the Reporting Rule and the CDR Rule will so significantly distort the results of the triennial inventory as to make the Reporting Rule's partial exemption for high-volume manufacturers unreasonable.