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Reporting Requirement on Import of Ozone-Depleting Substances Under Review

Wednesday, November 30, 2011
Sandler, Travis & Rosenberg Trade Report

The Environmental Protection Agency is soliciting comments no later than Jan. 30, 2012, on the proposed renewal of the recordkeeping and reporting requirements on the production, importation, recycling, destruction, transshipment and feedstock use of ozone-depleting substances. These substances include chlorofluorocarbons, halons, and quarantine and preshipment methyl bromide.

Under the Montreal Protocol on Substances that Deplete the Ozone Layer, the United States is obligated to cease production and import of Class I controlled substances, excluding CFCs that are subject to essential use exemptions, methyl bromide that is subject to critical use exemptions or exemptions for quarantine and preshipment uses, previously used material, and material that will be transformed, destroyed or exported to developing countries. The Protocol also establishes limits and reduction schedules leading to the eventual phaseout of Class II controlled substances with similar exemptions beyond the phaseout. Under EPA regulations, producers, importers, exporters and distributors of Class I ozone-depleting substances must meet quarterly, annual and/or transactional recordkeeping and reporting requirements.

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