TSCA Fees Comments to EPA

Auto Innovators comments to the EPA on its TSCA Fees Notice use the comment period as an opportunity to raise and define issues for EPA’s consideration in its next TSCA fees rule. Auto Innovators agrees with EPA’s extension of the comment period and use of a “no action assurance” regarding reporting and fees for imported articles. However, the association more clearly defines the historical precedence, cost and burden associated with EPA’s unintended action. In addition, the association raises other issues for consideration, including impurities and byproducts, de minimis levels, and R&D exemptions, to name a few.