Significant New Use Rules on Certain Chemical Substances (26-2)

Redwood Materials opposes the proposed Significant New Use Rules (SNURs) because they create regulatory overlap with existing frameworks (RCRA, CAA, CWA, OSHA), impose technically unfeasible fenceline monitoring requirements, and mandate unnecessary hazardous waste disposal. The company argues that the EPA's economic impact analysis significantly understates the true compliance costs and that the rule contradicts Department of Energy initiatives to expand the domestic battery supply chain.

Panasonic Corporation of North America opposes the proposed rule because it eliminates the article exemption at the point of reclamation, which they argue creates undue burdens and confusion for battery producers and importers. They request that the EPA instead utilize existing authorities like RCRA or OSHA to regulate recycling operations rather than using a Significant New Use Rule (SNUR).

The Consumer Technology Association (CTA) opposes the proposed requirement for batteries and battery packaging to be labeled with TSCA-restricted substance information. They argue that the labels would likely not reach the intended audience at recycling facilities, create unnecessary operational costs, and conflict with ongoing voluntary labeling initiatives.

Ultium Cells LLC and General Motors LLC oppose the proposed SNURs, arguing that they are based on insufficient data, create unnecessary regulatory overlap with existing environmental laws (CAA, CWA, RCRA), and threaten the U.S. critical minerals supply chain by penalizing domestic battery recycling. They request that the EPA conduct a required cost and efficiency analysis and suggest using TSCA Section 6 for a more consistent regulatory framework.

The Alliance for Automotive Innovation opposes the proposed Significant New Use Rules (SNUR) because they argue the rules impose unreasonable lifecycle responsibilities on manufacturers for post-use battery recycling. They contend that the rules will create regulatory burdens, incentivize offshoring of recycling, and hinder the development of a domestic battery supply chain.

The Chemical Users Coalition (CUC), an association representing major companies like Boeing and IBM, opposes the proposed Significant New Use Rules (SNUR) for certain chemical substances. They argue the rules are unclear, impracticable for downstream users and importers, and could disrupt ongoing TSCA-compliant recycling and manufacturing of batteries.