May 27, 2020 Agency Comments

Auto Innovators Comments on EPA’s 13 High Priority Chemicals Scoping Documents

Auto Innovators provided comments to the EPA to assist in shaping and informing the risk evaluations for thirteen high priority chemicals. In general, the comments suggested improvements to ensure consistency with the Lautenberg Act’s provisions on articles and replacement parts, encourage EPA to provide detailed conditions of use and their associated risk for all ongoing uses reported by our industry, and to consider use of exemptions for de minimis and R&D uses of these chemicals. Auto Innovators believes these comments will help provide industry with regulatory certainty and EPA with an appropriately streamlined pathway for addressing these chemicals.