The Mandatory CCR Summary Section
Starting January 1, 2027, every Consumer Confidence Report must open with a plain-language summary placed at the front of the report before any contaminant data. The requirement is 40 CFR § 141.156, a new section added by the 2024 CCR Rule Revisions (89 FR 46013, May 24, 2024).
This page explains what § 141.156 requires, what to put in the summary, and how to draft one that satisfies the rule without losing your customers.
What § 141.156 requires
Section 141.156 is a new addition to Subpart O of 40 CFR Part 141, which now spans §§ 141.151 through 141.156 since the 2024 revisions expanded the range. Before 2024, Subpart O ended at § 141.155.
The core mandate is at § 141.156(a): every report must include "a summary displayed prominently at the beginning of the report, including a brief description of the nature of the report." Both "prominently" and "at the beginning" are explicit — the summary cannot be a buried section or an appendix.
The statutory authority runs from the Safe Drinking Water Act 1996 (42 U.S.C. § 300g-3(c)(4)) through the America's Water Infrastructure Act of 2018 (AWIA, Pub. L. 115-270) to the 2024 Rule Revisions. The compliance date is January 1, 2027, covering reports for calendar year 2026 data. See the full timeline in our 2027 CCR Rule Changes overview.
What the summary section must contain
Section 141.156(b) sets the minimum required content. Every summary must include, at minimum:
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A summary of violations and compliance. Specifically, information required under § 141.153(d)(6), § 141.153(d)(8), § 141.153(f), and § 141.153(h)(6)-(7). These cross-references cover MCL violations, maximum residual disinfectant level violations, treatment technique violations, and health-based action level exceedances. If your system had no violations or exceedances in the reporting year, the summary must state that clearly.
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Contact information for the owner, operator, or designee of the community water system — a name and way to reach someone with questions.
Section 141.156(c) adds conditional requirements:
- If your system delivers the CCR electronically (rather than mailing paper copies), the summary must include directions for how customers can request a paper copy (§ 141.156(c)(1)).
- If your service area has a significant population of consumers with limited English proficiency, the summary must include information on how to obtain a translated copy (§ 141.156(c)(2)).
- If the report also serves as a Tier 3 public notification under Subpart Q, the summary must identify which violations or situations that notification covers and where in the report to find them (§ 141.156(c)(3)).
Section 141.156(f) requires a specific standard-language statement — the rule's version of a distribution reminder: "Please share this information with anyone who drinks this water (or their guardians), especially those who may not have received this report directly." The rule specifies that this language or language to similar effect must appear in the summary.
The infographic allowance
Section 141.156(d) says the summary "should be written in plain language and may use infographics." That "may use infographics" is not incidental. It is an explicit regulatory permission for visual communication of health-effects information — something the prior CCR framework did not address.
In practice, this means a system can meet the § 141.156 summary requirement with a one-page visual layout: icons representing each tested contaminant category, a color-coded compliance status, a contact box, and the required distribution statement. None of that requires prose tables. The rule was designed to push CCRs toward documents that customers actually read, and visual formats are an approved path.
One constraint applies: the summary must still be "prominent" and appear "at the beginning" of the report per § 141.156(a). An infographic that is physically the first page satisfies this. An infographic appended after the contaminant tables does not.
How it differs from the rest of the CCR
The rest of the CCR — the contaminant detection tables, the MCL columns, the source water statement, the educational boilerplate for specific contaminants — is governed by §§ 141.153 and 141.154. That content is dense and prescribed, including the exact language for some disclosures.
The summary section is different in character. Section 141.156 gives systems latitude on format (including infographics) and calls for plain language rather than the regulatory phrasing required elsewhere. The summary functions as a one-page executive overview; the full report is the compliance document. A customer who calls you after reading the CCR probably only read the summary — getting that page right matters more than most of the fine-print sections that follow.
Step-by-step: composing your summary section
The following steps describe one approach to producing a compliant § 141.156 summary. Your primacy agency may have additional guidance.
Step 1 — Determine your violation status for the reporting year. Pull every MCL violation, MRDL violation, treatment technique violation, and action level exceedance from monitoring records for the calendar year covered by the report. No violations means your summary says so clearly; any violations require identification.
Step 2 — Write the brief description of the report. Section 141.156(a) requires "a brief description of the nature of the report." One to three sentences — system name, reporting year, what the data covers — is enough.
Step 3 — Add contact information. Name, title, phone, and email of the system owner, operator, or designee. Required by § 141.156(b)(2).
Step 4 — Check for conditional requirements. Electronic delivery: add paper-copy request instructions. Significant LEP population: add translation instructions (confirm threshold with your primacy agency). Tier 3 public notice: include the required § 141.156(c)(3) cross-reference.
Step 5 — Add the distribution statement. Include the § 141.156(f) language encouraging recipients to share the report with household members who may not have received it directly.
Step 6 — Choose your format. Prose section or infographic. If using an infographic, confirm it is physically at the beginning of the report and that all § 141.156(b) required elements are present visually. Good design does not substitute for required content.
Step 7 — Review against § 141.156 before finalizing. Read 40 CFR § 141.156 one final time. Confirm: (a) placement, (b)(1)-(2) minimum content, (c) conditional items, (d) plain language, (f) distribution statement. Your primacy agency uses the same checklist.
Common pitfalls
Placing the summary after the contaminant tables. Section 141.156(a) requires prominence at the beginning. A summary buried after the detection tables fails this requirement.
Pasting violation language verbatim from § 141.153. The summary is supposed to be plain-language. Regulatory phrasing that requires a glossary to parse defeats the purpose.
Skipping the contact information. Section 141.156(b)(2) makes contact information a minimum requirement, not optional. Systems sometimes overlook this when drafting a visual summary.
Using an infographic that omits required text elements. The infographic allowance in § 141.156(d) does not waive the content requirements in § 141.156(b) and (f). Visual formats must still carry all mandatory content.
Conflating the summary with the rest of the report. The summary should stand alone. A reader who only reads it should know: what system this is, whether any violations occurred, who to call, and how to get a translation. If they have to flip to page 3 to answer those questions, the summary isn't doing its job.
Last reviewed: 2026-05-03. Next scheduled review: every 3 months until Jan 1, 2027 effective date.