EPA Requests Information on Industrial Use of HDPE Containers
Update (Nov. 18): The EPA has granted ILMA’s request for extension of the comment period to Dec. 30, 2024. ILMA’s HDPE Task Force will continue to gather data from the membership and submit comments by the deadline. Key representatives are requested to look for a survey link by email and provide input to help strengthen ILMA’s comments.
Original story (Oct. 8): As discussed during the SHERA Committee meeting at the ILMA Annual Meeting, the U.S. EPA remains committed to regulating the by-product manufacture of per- and polyfluoroalkyl substances (PFAS) during the fluorination of high-density polyethylene (HDPE) containers. On September 30, the agency published a notice seeking information on the use of fluorinated containers to inform its regulatory approach under the Toxic Substances Control Act.
The EPA is seeking information on the number, location and uses of HDPE containers in the country, including any uses critical to the national economy and energy infrastructure. ILMA members are uniquely positioned to highlight the value of HDPE containers in the industry and beyond. Unless the agency grants an extension, comments must be submitted by November 29.
Given the EPA’s previous regulatory efforts on this matter, ILMA anticipates strict restrictions—potentially even a ban—that could threaten market access to fluorinated containers and cause significant supply chain disruptions for the lubricants industry. Accordingly, the Association will be actively engaged in this process to influence the outcome of the proceedings.
ILMA is seeking volunteers to form a task force under the Safety, Health, Environmental and Regulatory Affairs (SHERA) Committee to develop a survey to collect information regarding the use of fluorinated HDPE containers. This data will support our advocacy efforts to elevate the voice of the lubricants industry. If you are interested in joining, please contact Regulatory Counsel Jorge Roman before Wednesday, October 16.
Read the memo from the SHERA Committee to understand the potential implications for the industry’s supply chain.