FPA Submits Comments on the April 11, 2022, Notice of Proposed Rulemaking to Amend the SEC’s 2010 Climate Guidelines

The Flexible Packaging Association (FPA) appreciates this opportunity to submit comments on the April 11, 2022, Notice of Proposed Rulemaking (“NPRM” or “Notice”) to amend the SEC’s 2010 Climate Guidelines. This rulemaking, if finalized, would require publicly-traded entities to include a significant amount of information related to a registrant’s climate-related risks that are reasonably likely to have a material impact on its business, results of operations, or financial conditions. FPA’s members include public companies as well as many privately-held entities, all of whom will be directly affected if the proposed rule is adopted, because of their role in a registrant’s “value chain.”