On Thursday, January 11, 2018, the Association of Global Automakers and the Alliance of Automobile Manufactuers submitted joint comments to the U.S. Environmental Protection Agency (EPA) in response to its proposed rule, Reporting Requirements for Toxic Substances Control Act Mercury Inventory.

The two associations comments on the following main points:

  • There is a need for increased clarity regarding who must report.
    • While, it is our understanding that based on the proposed regulatory language that automobiles (and many automobile parts) containing mercury-added components would not have to report under this regulation, the rule is not clear about this requirement and should be updated accordingly.
  • EPA should eliminate duplication with the Interstate Mercury Education and Reduction Clearinghouse (IMERC) reporting requirements, since this information is readily and publicly availabe.
  • EPA should explicitly exempt replacement parts, which are kept in inventory for future use, because it would not add significant value to the accuracy of data.
  • Additional clarity is needed on the exemption for mercury-containing waste and by-products sent to recyclers.