Representatives from the RV Industry Association (RVIA) met with officials from the U.S. Environmental Protection Agency (EPA) on July 25 to discuss concerns related to the federal PFAS reporting rule under Section 8(a)(7) of the Toxic Substances Control Act.
The meeting, held with the EPA’s Office of Chemical Safety, focused on the agency’s new rule requiring companies to report information on per- and polyfluoroalkyl substances (PFAS) manufactured or imported—including those contained in articles—between January 2011 and December 2022.
According to a News and Insights report of RVIA, representatives of the RVIA were Bill Erny, senior manager of regulatory Affairs, and Chad Reece, chair of the government affairs committee.
The pair outlined specific challenges the RV industry faces in complying with the rule’s extensive data collection and reporting obligations.
A central issue raised was the difficulty of retrieving detailed chemical composition data for parts and components sourced globally.
“A particular concern raised during the meeting is the difficulty of obtaining detailed chemical composition data from global supply chains, especially from overseas suppliers who may not have historically tracked this type of information,” the RVIA indicates.
Participants also questioned the practicality of the “lookback period.”
EPA officials responded by confirming that the agency is reviewing several elements of the rule, including the definition of PFAS, how imported articles will be addressed, and the feasibility of the proposed timeline.
“The agency is planning to publish a proposed rule as early as this fall requesting public input,” according to the RVIA. This step is expected to open a formal comment period during which industries can provide feedback on implementation.
Serving the RV industry for 50 years, RVIA is the leading national trade voice representing the $140 billion RV sector.
With offices in the Washington, D.C. area and Elkhart, Indiana, the association represents more than 500 manufacturers, component suppliers, and aftermarket companies that collectively produce 98% of all RVs made in the United States and approximately 60% of those produced globally.
The association also works to unite the diverse segments of the RV industry, building alliances and advocating with a unified voice.
In partnership with its members, the association promotes industry growth, supports innovation, and helps shape the future of the outdoor recreation market.