Member DashboardCBP Tightens Importer Data Enforcement
U.S. Customs and Border Protection (CBP) will step up enforcement of importer-of-record information beginning Sept. 18. Manufacturers and other importers should review CBP Form 5106, known as the Importer Identity Form and confirm that all information is accurate, complete and tied directly to the importer. CBP may immediately void an importer-of-record number if it finds inaccurate or incomplete information, preventing the company from entering merchandise into the U.S. until CBP reestablishes the number. Customs brokers also must verify importer information and maintain a valid power of attorney directly with the importer.
FTC warns companies about “Made in USA” claims
The U.S. Federal Trade Commission (FTC) recently warned several companies about potentially misleading “Made in USA” claims. Under the FTC’s Made in USA Labeling Rule, an unqualified U.S.-origin claim generally requires a product to be “all or virtually all” made in the U.S.
Manufacturers should review labels, websites and marketing materials to ensure they can substantiate U.S.-origin claims. The warning letters follow an executive order directing stronger enforcement against unlawful domestic-origin claims.
CKV task group addressing two timely challenges
During its recent meeting, the Commercial Kitchen Ventilation (CKV) task group addressed two topics – one a follow-up and one new:
- In May, the Task Group flagged concerns about changes to Section 507.2 of the 2024 International Mechanical Code (IMC) that removed an exception allowing certain electric cooking appliances to operate without a Type I hood when testing confirms compliance with the UL 710B. Letter reports from approved testing agencies were previously used to confirm compliance with 710B. The current code references UL 197, which does not include a grease-emissions test procedure. This omission has created confusion with authorities having jurisdiction (AHJs) when evaluating compliance. Through conversations facilitated by NAFEM among affected members and UL, a clarification document is being developed that companies will be able to provide to AHJs to verify compliance with UL 710B.
- In August, participants reported that the San Francisco City & County Department of Building Inspection is now requiring fire suppression for all ventless equipment. NAFEM members have discussed this issue with UL Solutions and they have offered to intercede with local officials to clear up any confusion. Members interested in this topic and the meeting should contact advocacy@nafem.org.
NY gas-stove labeling bill heads to governor
New York lawmakers approved S 1280B, the Healthy Homes Right to Know Act, which would require warning labels and retail signage for gas stoves. If approved by Gov. Hochul, the warnings would include information on emissions of nitrogen dioxide, carbon monoxide, benzene and formaldehyde. Although the bill primarily targets residential appliances, its language could reach commercial foodservice equipment. NAFEM is working closely with the New York State Restaurant Association (NYSRA) to address this issue.
Advocacy works: FinCEN ends beneficial ownership reporting
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) permanentlyended beneficial ownership reporting requirements under the Corporate Transparency Act and committed to deleting previously collected personal ownership information. NAFEM actively advocated for both outcomes.
Reporting reminders
Upcoming
- The Minnesota Pollution Control Agency’s PFAS reporting deadline is Sept. 15. Manufacturers of products sold in Minnesota that contain intentionally added PFAS must submit reports through the state’s PRISM system. Manufacturers that received an extension have until Dec. 14. The deadline for extension requests has passed.
- EPA has delayed reporting under the TSCA Section 8(a)(7) PFAS reporting rule. The rule generally requires companies that manufactured or imported PFAS or PFAS-containing articles between 2011 and 2022 to report information on uses, production volumes, disposal, exposures and environmental and health effects. The reporting period will now begin Jan. 31, 2027, or 60 days after the effective date of EPA’s forthcoming revisions to the rule, whichever comes first. EPA expects to finalize those revisions later this year.
- New Mexico PFAS reporting and labeling requirements take effect Jan. 1, 2027 for manufacturers of products containing intentionally added PFAS.
- Ice machines and refrigerated food processing and dispensing equipment subject to the EPA’s AIM Act Technology Transitions Program face new HFC restrictions and labeling requirements beginning Jan. 1, 2027. The agency provides a detailed fact sheet with labeling examples.
- California SB 253 requires U.S. companies with more than $1 billion in annual revenue that do business in the state to begin reporting Scope 3 greenhouse gas emissions in 2027. Companies must disclose no later than 180 days after the reporting of Scope 1 and 2 emissions.
Past due
- Certain chillers and industrial process refrigeration equipment became subject to EPA AIM Act HFC restrictions and labeling requirements Jan. 1, 2026. The EPA provides a detailed fact sheet with labeling examples.
- California SB 253 required U.S. companies with more than $1 billion in annual revenue that do business in California to submit their first Scope 1 and 2 greenhouse gas emissions reports by Aug. 10. Legal challenges are ongoing, but the reporting deadline has not changed.
Help us keep this section as complete as possible. Share additional information with NAFEM at advocacy@nafem.org.