FPA Submits Comments to the U.S. EPA Seeking Additional Clarification on the TSCA PFAS Reporting and Recordkeeping Rule

The Flexible Packaging Association (FPA) is seeking additional clarification on the TSCA PFAS Reporting and Recordkeeping Rule, with regard to its applicability to processors generally and to processors that import materials which they do not manufacture themselves but that may contain PFAS that are mixed in substrates and laminates and/or coatings and/inks that are applied in manufacturing flexible packaging. The proposed amendments also include an extension of the reporting time for affected reporters and revisions to the regulation to provide for a “0.1% de minimis exemption” for potentially affected reporters. FPA generally supports both of these proposed amendments to 40 CFR Section 705, but recommends that the “de minimis: be defined in a less restrictive manner.