A Consumer Confidence Report only counts when customers receive it and the state has your certification. Writing the report is half the job. Delivery and certification are the half that shows up as a violation when they slip.

The controlling rule is 40 CFR Part 141 Subpart O. Community water systems must deliver by July 1, then certify that delivery to the state primacy agency. This isn't legal advice. Confirm the method and the form your state accepts this year.

Who has to deliver a CCR

Community water systems must produce and deliver a CCR. Transient systems and most non-transient non-community systems are on a different path. If you're unsure of your classification, look up the official EPA profile. The identifier on that profile is your PWSID.

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Size doesn't remove the federal obligation. A system serving 200 people still has to deliver. How you deliver can differ. The duty doesn't. If you still need the definition, start with What Is a CCR for Public Water Systems. This page is the delivery and certification work.

July 1 is a delivery date, not a writing date

Community water systems must deliver the CCR to customers by July 1 each year. Missing that date is a reporting violation, not an MCL exceedance. Plan backward from July 1. Freeze the content, finish any required translation, and start mail or electronic delivery with enough time for the last customer to have the report on July 1, not July 8.

Keep a dated copy of what you sent. If the state or a customer asks what was delivered, you should be able to produce the same file, the same URL, or the same printed packet.

How you may deliver the report

Federal Subpart O and your state decide which methods count. Typical accepted paths:

  • Mail or hand-deliver the full report to bill-paying customers.
  • Electronic delivery, where the rule and your state allow it, using a direct URL to the current CCR.
  • An email that attaches the current CCR, or that carries that direct URL.
  • A bill insert that is the report, or that carries the direct URL with clear instructions.

Don't assume last year's process still qualifies. Ask your primacy agency which options they'll accept for this year's July 1 delivery before you print or post.

Electronic delivery has one hard rule

If you deliver electronically, the link must open the current CCR. A homepage, a reports landing page, or a generic water-quality page isn't enough. The customer should land on this year's report in one click. If that URL 404s in August, you've got a delivery problem, even if the file lived on your server in June.

Write the URL down. Screenshot the live report on the delivery date. Keep both with the certification packet.

Good-faith effort for people who don't get a bill

Renters, multi-family buildings, and people who never see a water bill still need a path to the CCR. Subpart O expects a good-faith effort to reach them. What counts is state-specific, but the work is the same:

  • Give landlords and building managers the report or the direct URL and ask them to post it.
  • Post the CCR in common areas you control.
  • Post the direct URL on a public site the community already uses.
  • Use an extra channel your state accepts.

Document each step with a date. A good-faith effort you can't show later is hard to defend in a sanitary survey.

Language requirements are state-specific

Some states require Spanish, or another language, when a set share of customers needs it. The threshold and the required statement aren't the same in every state. Confirm the current language rule with your primacy agency. Don't copy last year's language block without checking.

See exactly what your system is up against

Search by system name or PWSID and get your EPA violation history, open requirements, and upcoming deadlines in under a minute. Free, no account, no obligation.

Certification is a separate filing

Delivery to customers is one duty. Certification to the state is another. You must certify delivery to the state primacy agency. Timing is typically within three months of delivery. Many systems treat October 1 as the backstop. States vary. Some want the certification with a copy of the CCR. Some have their own form. Some accept a letter that names the PWSID, the delivery date, the methods used, and the good-faith steps for non-bill-paying customers.

Build the certification packet before July 1:

  • Final CCR file, identical to what customers received.
  • Direct URL, if you used electronic delivery, plus a dated screenshot.
  • Mailing list, email log, or hand-delivery log.
  • Proof of posting and landlord outreach.
  • The state's certification form or your signed letter, and any confirmation the state sends back.

Federal SDWIS can trail the state file by a quarter or more. If the federal record later looks empty, your packet is what you show the primacy agency. Orevant doesn't file the CCR or the certification for you.

What changes on January 1, 2027

The Revised CCR Rule has a compliance date of January 1, 2027. Systems serving 10,000 or more people move to biannual delivery. Smaller systems stay annual. Electronic delivery still has to use a direct URL to the current CCR, not a homepage. If you serve 10,000 or more, 2026 is the year to pick a second delivery window and test a URL that won't break between cycles.

Don't wait until January 2027 to change a homepage link into a direct URL. That practice is already the right reading of electronic delivery.

A CCR is not a public notice

A public notice is what you issue when a rule is violated or a situation requires timely notice (Tier 1, Tier 2, or Tier 3). A CCR is the annual water-quality summary. You can owe both in the same year. Putting a violation in the CCR doesn't replace a public notice you already owed. Putting a public notice in the mail doesn't replace July 1 delivery of the CCR.

Operator checklist

  • Confirm you're a community water system and write down the PWSID.
  • Ask the state which delivery methods and which certification form they accept this year.
  • If you deliver electronically, publish a direct URL to the current CCR and test it from a phone that isn't on your office network.
  • Reach non-bill-paying customers and keep dates for each good-faith step.
  • Deliver by July 1. File the certification on the state's timeline, often within three months.
  • Keep the packet through the next sanitary survey, not just through October.

FAQ

Do I still have to certify if I posted the CCR on our website?

Yes. Posting is a delivery method, and only if the post is a direct URL to the current CCR and your state accepts electronic delivery. Certification is the separate notice to the primacy agency that delivery happened. A live webpage isn't a certification.

When is CCR certification due?

Federal practice is to certify to the state after delivery, typically within three months. States set the exact date and the form. Ask your primacy agency. Don't use a neighbor system's date as yours.

Is a missed July 1 delivery an MCL violation?

No. It's a reporting violation under 40 CFR Part 141 Subpart O. It still lands on the public record and it still needs a correction. It isn't a finding that the water exceeded a maximum contaminant level.

What changes for systems over 10,000 on January 1, 2027?

Under the Revised CCR Rule, systems serving 10,000 or more people move to biannual delivery. Smaller systems stay annual. Electronic delivery still requires a direct URL to the current CCR. Confirm the 2027 calendar with your state.

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Orevant provides compliance information tools. This page isn't legal advice. Confirm current CCR delivery and certification rules with your state primacy agency.