The U.S. Environmental Protection Agency (EPA) announced on October 21, 2021, that it is proposing to extend further the compliance dates related to articles containing phenol, isopropylated phosphate (3:1) (PIP (3:1)) to ensure supply chains for key consumer and commercial goods are not disrupted. As reported in our September 3, 2021, memorandum that addresses a September 17, 2021, final rule, EPA provided a short-term extension of certain compliance dates for PIP (3:1) to March 8, 2022, “to address the hardships inadvertently created by the original applicable compliance dates in the January 2021 final rule.” 86 Fed. Reg. 51823. EPA is announcing a proposal to extend further the compliance date applicable to the processing and distribution in commerce of certain PIP (3:1)-containing articles and the PIP (3:1) used to make those articles until October 31, 2024, along with the associated recordkeeping requirements for manufacturers, processors, and distributors of PIP (3:1)-containing articles. Comments will be due 60 days after EPA publishes the proposed rule in the Federal Register. EPA has posted a pre-publication version of the proposed rule (proposed rule). For more information, please read the full memorandum.
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