Details on EPA’s Sell-Through Proposal

3 June 2020

EPA’s latest sell-through proposal was published in the Federal Register on May 22nd, starting a 45-day comment period with written comments due on July 6, 2020. HPBA issued a statement in response to the proposal on May 15th when a pre-publication draft was made public.

The proposal was made in response to the impact of COVID-19 closures on sales of Step 1 products as the May 15, 2020 deadline to sell Step 1 appliances approached.
EPA is taking comments on allowing additional time to sell Step 1 appliance.
In order to grant this additional sell-through period, EPA needs to be able to justify the need for additional time due to COVID-19 interruptions or closures on your ability to clear out Step 1 inventory between March 15, 2020 and May 15, 2020.

What is in the Proposal

If enacted, the new deadline would be Monday, November 30, 2020; it would not be legal to begin selling Step 1 products until the proposal is finalized, which could be months from now.
It is currently illegal to sell, offer for sale, or transfer ownership of any Step 1 products in the United States.
The only way this changes is if – after consideration of all testimony and public comments – EPA decides to publish a Final Rule in the Federal Register granting sell-through.

Public Hearing Information

A public hearing (virtual) will be held on Monday, June 8th from 9:00 am EDT to 3:00 pm EDT.

To sign up to speak at the hearing or register to listen in, visit EPA’s website.
If you wish to provide testimony at the meeting, you must register by the end of the day on Thursday, June 4th.
Testimony will be limited to five minutes per presenter.
In order for EPA to consider your testimony, it is important that you address the need for sell-through as a result of the closures or lost business due to COVID-19 in the two months leading up to May 15, 2020.

HPBA Webinar on Testimony and Public Hearing

HPBA will hold a webinar on Thursday, June 4th at 2:00 pm EDT to provide information and answer questions for members who wish to testify at the public hearing.

To register for the HPBA webinar, please click here.

HPBA Webinar on Written Comments

HPBA will hold a second webinar on Wednesday, June 17th at 12:00 pm EDT for members who want to provide written comments, which is most important.

Source: HPBA Communications

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