The U.S. Environmental Protection Agency (EPA) issued a proposed rule to reduce the regulatory burden of per- and polyfluoroalkyl substances (PFAS) reporting under the Toxic Substances Control Act (TSCA).
Under current regulations, manufacturers and importers are required to report certain PFAS data in any year from 2011 to 2022.
According to the EPA, PFAS are a group of synthetic chemicals known for their water- and grease-resistant properties, often referred to as “forever chemicals” because of their persistence in the environment and human body.
RVIA said the association and its members have advocated consistently for common-sense changes to the TSCA look-back reporting rule. This summer, RVIA said it participated in multiple in-person meetings with EPA leadership to outline the challenges of collecting chemical composition data.
“The proposed rule includes several exemptions and modifications that would maintain important reporting requirements on PFAS,” RVIA said, “while exempting certain low-value activities impacting the RV industry.”
The proposed changes would provide exemptions for imported articles, PFAS manufactured and imported in mixtures or products at concentrations of 0.1% or lower, certain byproducts, impurities, research and development chemicals and non-isolated intermediates.
RVIA said under the imported articles exemption, RVIA members who import finished products from overseas sources would not be required to collect and report PFAS information on those products to the EPA.
“Further, products that contain de minimis levels of PFAS less than 0.1% would be excluded from reporting,” RVIA said. “These two exemptions alone would exempt much of the RV industry’s reporting obligations under the TSCA, eliminating significant costs and regulatory burden on RV manufacturers and suppliers.”
The proposed changes are expected to be published in the Federal Register in December. The public will have 45 days to comment on the potential changes.
For more, email Senior Manager of Regulatory Affairs Bill Erny at [email protected].
