Are manufacturers of household products exempt from reporting under 311 and 312?

Is a facility that manufactures household products exempt from reporting under Sections 311 and 312 due to the household products exemption in Title III?

Section 311(e) exempts from the definition of "hazardous chemical"  any substance to the extent it is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use by the general public.  This exclusion applies to household or consumer products, either in use by the general public or in commercial or industrial use when the product has the same form and concentration as that intended for use by the public.  It also applies to these products when they are in the same form and concentration prior to distribution to the consumer, even when the substance is not intended for use by the general public.  

The term "form" refers to the packaging, rather than the physical state of the substance.  However, the manufacturer is exempt from reporting the manufactured product only when the product is in the final consumer form.  The manufacturer is not exempt from reporting the raw or processing materials.