Manufacturers Push EPA to Reassess Chemical Regulations Under Executive Order 14219

Regulatory Costs and Industry Burdens

Citing over $350 billion in annual compliance costs, NAM’s submission targets a wide array of EPA actions, including revisions to particulate matter and ozone standards, greenhouse gas limits on power plants, and expanded reporting duties under the Toxic Substances Control Act (TSCA). Many of these, NAM argues, impose unattainable benchmarks or are based on questionable scientific assumptions.

Of particular concern is the TSCA Section 8(a)(7) rule on PFAS reporting, which mandates retrospective data collection without a de minimis threshold. According to NAM, the EPA lacks the capacity to process the flood of data this rule will generate, creating legal and operational risks for thousands of manufacturers.

PFAS, Formaldehyde and 1,3-Butadiene Among Targeted Substances

The association also called for the reconsideration of specific chemical assessments. These include the 2024 draft risk evaluation for 1,3-butadiene (CAS 106-99-0), widely used in rubber and plastics, and the final assessment of formaldehyde (CAS 50-00-0), a key input in resins and adhesives. NAM questioned the scientific rigour of the EPA’s methods, particularly the reliance on non-peer-reviewed data and flawed exposure assumptions.

Similarly, NAM opposes the recent designation of PFOA and PFOS as hazardous under CERCLA and the final drinking water limits of 4 parts per trillion for these and related PFAS. It argues these levels are below reliable detection limits and pose significant liability risks for sectors ranging from manufacturing to agriculture and water treatment.

Broad Impacts Across the Chemical Value Chain

While spearheaded by manufacturers, the recommended changes would affect a wide range of stakeholders, including local governments, utility providers, healthcare suppliers, and downstream users of regulated substances. The call for a “commonsense” approach to risk assessment and regulation reflects broader concerns about regulatory fragmentation and the economic impacts of sweeping environmental rules.