HPBA Submits Comments to EPA on Proposed COVID-19 Sell-Through Relief from NSPS Deadlines

On July 6, 2020, HPBA submitted comments to EPA in support of its proposed sell-through package which, if enacted, would provide sell-through for Step 1 products from the date the rulemaking is finalized until November 30, 2020. Unless and until EPA formally adopts the sell-through proposal, it remains illegal to sell or offer for sale all Step 1 products in the U.S.


Almost every business has felt the economic impacts of COVID-19 on its sales, employees, and way of life. Our comments include updates from 77 retailers and distributors on how many Step 1 products they have left since we last surveyed them in March. These comments focused on the effect of state stay-at-home orders and business shutdowns on the ability to sell remaining Step 1 inventory in the two months leading up to the May 15, 2020 deadline. Read HPBA’s comments here.


The EPA held a public hearing on this proposed rule on June 17. Ryan Carroll, John Crouch, and Chairman of the Board Dick Hoffman offered comments. Written versions of their comments can be found on our website. All other comments can be accessed on EPA’s docket under “Browse Comments.” Dozens of retailers and distributors, many of whom are HPBA members, submitted comments in support of the sell-through proposal. Please contact Rachel Feinstein if you have any questions.



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