May 17, 2021 Agency Comments

Auto Innovators and MEMA Joint Comments on Persistent, Biaccumulative and Toxic Chemicals

Auto Innovators and MEMA jointly submitted comments on EPA’s reopening of the Persistent, Biaccumulative and Toxic (PBT) rulemaking. These comments reinforce that EPA’s previous actions to exempt automotive uses from PIP (3:1) requirements and require a sell down date of 15 years for replacement parts containing decaBDE are appropriate. However, recognizing that EPA is under pressure to limit these exemptions, Auto Innovators and MEMA highlight the lack of an alternative at this time and the long product cycles, suggesting that an exemption is needed for seven to ten years, assuming a viable alternative is determined within four years.  In addition, the comments ask to extend the automotive exemptions for motor vehicles (light, medium, and heavy duty and non-road applications), which have substantially similar parts, and for import of needed manufacturing and tooling equipment.