FPA Submits Comments on Proposed Changes to the Air Electronic Emissions Reporting Rule (AERR)

The Flexible Packaging Association (“FPA”) appreciates this opportunity to comment on proposed changes to the Air Electronic Emissions Reporting Rule (AERR) in the Notice of Proposed Rulemaking (“NPRM” or “Notice”). FPA is a national trade association, established in 1950, comprised of manufacturers and suppliers of flexible packaging. The industry produces packaging for food, healthcare, and industrial products using coating and lamination of paper, film, foil, or any combination of these materials to manufacture bags, pouches, labels, liners, wraps, rollstock, and tamper-evident packaging for food and medicine. Flexible packaging, a $42.9 billion industry, employs roughly 85,000 people in the United States and is the second largest and fastest growing segment of the U.S. packaging market.