May 18, 2021 Agency Comments

Comments on EPA TSCA Fees Information Collection Request

Auto Innovators provided comments to EPA on an information collection request related to the TSCA Fees rule.  While the current TSCA Fees rule is proposed to focus on bulk chemicals and mixtures and not on articles, Auto Innovators still saw an opportunity to inform the agency regarding the costs and time associated with the agency’s actions, even on the more narrow aspects of import of mixtures.  In addition, Auto Innovators highlighted under estimation of time to comply and outdated wage costs.  This comment supports are broader engagement on the fees rule, where we continue to reinforce the challenges and burden associated with extending the rules reach to articles.