Auto Innovators and the ad-hoc Downstream Users Coalition (DUC) that we participate in submitted comments to OMB and OIRA on the information collection request (ICR) portion of EPA’s proposed rule for PFAS reporting. Both sets of comments raise concerns with undue burden, the resource intensive nature of the rule, and EPA’s underestimated costs to industry. Auto Innovators’ comments focus on demonstrating the cost and hours to comply if the importers of articles are required to report all PFAS content. The DUC focused on the specific criteria that OMB must evaluate for an ICR. In combination, these comments are complementary, providing an robust viewpoint on concerns with regulating articles. Both sets of comments also offer to work on solutions with EPA and to meet with OMB on these comments.
July 29, 2021 Agency Comments