Document 1gqgbNk0eGbDky0m0dbbKDava

To: From: Sent: Subject: Jackson, Ryan[jackson.ryan@epa.gov] Liebowitz, Daniel Thur 6/1/2017 1:33:05 PM Impact of Delays for New Chemical Substance Registrations Hello Mr. Jackson, We spoke over the phone a few weeks ago regarding the impact of delays related to the EPA PMN review process under the revised TSCA regulations. You requested information regarding the value of each PMN in annual sales for our business. It is difficult to provide an accurate value for annual sales as these are all new products to the coatings market. However a rough estimate would be in the $300,000-$500,000/year range for all 13 delayed PMNs assessed under the revised regulations. The biggest impact of these delays is the delay in availability of these new products for customer evaluations and the uncertainty of whether they will be successfully registered. In one case that has been under review for over 1-year, the primary customer for this new product has indicated that during this 1-year delayed review period, they have developed another technical solution and may not need to purchase this product. In addition to the impact of the delays in the review process, another concern is the assessment of uses that some of our products were not designed for and were never intended. Regards, Dan Daniel Liebowitz Allnex USA Inc. Regulatory Compliance Manager, Americas Product Stewardship & Regulatory Affairs 78 Rivergate Drive Wilton, CT 06897 Office: 203-834-0426 Cell: 203-685-3616 17cv1906 Sierra Club v. EPA ED_001523_00003374-00001 Legal Notice: This electronic communication, including any attachments, contains information from an allnex Group company that may be legally privileged, confidential, and exempt from disclosure under applicable law. If you are not the intended recipient, any use or dissemination of this communication or its attachment(s) is strictly prohibited and may be illegal. If you have received this communication in error, please notify the sender immediately, destroy any printed copies and delete it from all computers on which it may be stored. Notice: Trademarks indicated with , TM or * as well as the allnex name and logo are registered, unregistered or pending trademarks of Allnex IP s..r.l. or its directly or indirectly affiliated allnex Group companies. 17cv1906 Sierra Club v. EPA ED_001523_00003374-00002