| Issue Highlights
Automotive: NASF–AIAG Webinar on Decorative Chromium Transition | Review – NASF and the Automotive Industry Action Group (AIAG) held a virtual roundtable on the transition from hexavalent to trivalent chromium for decorative automotive applications. The session brought together OEM representatives from General Motors, Toyota, Volkswagen and Volvo Group with NASF member chemical suppliers and job shops for a discussion on policy direction, industry readiness, and implementation across the supply chain.
Trade Policy: CBP Launches Process for IEEPA Tariff Refunds – U.S. Customs and Border Protection (CBP) has launched the first phase of its CAPE process for refunds of duties paid under International Emergency Economic Powers Act (IEEPA) tariffs that were invalidated by the Supreme Court earlier this year. The process follows Court of International Trade orders directing CBP to remove the affected duties and process refunds for eligible importers. Importers of record, or their authorized brokers, must use the process to seek refunds for eligible entries.
Tax Policy: House Advances Narrow Tax Bills as Midterm Elections Loom – The House in late April advanced a series of bipartisan tax administration measures focused on IRS operations, taxpayer protections and a handful of narrower provisions. The bills are far more limited than last year’s major tax law, but they show that some noncontroversial tax items may still move even as broader tax policy becomes more difficult heading into the midterms.
Environmental Policy: EPA Releases Updated PFAS Destruction and Disposal Guidance – EPA published its updated 2026 Interim Guidance in April on the Destruction and Disposal of PFAS and PFAS-Containing Materials. The guidance is non-binding and updates EPA’s 2024 version. There are no requirements for finishing operations.
Safety Policy: OSHA Publishes Walking-Working Surfaces Proposal – On April 6, OSHA published its proposed update to the walking-working surfaces standard in the Federal Register. As anticipated in last month’s report, the proposal is narrowly focused on fixed ladder requirements and is intended to provide significantly greater compliance flexibility for certain general industry operations.
Environmental Policy: Historic EPA Greenhouse Gas Finding Repeal Takes Effect; Litigation Continues – EPA chief Lee Zeldin’s promised repeal of the Obama-era 2009 greenhouse-gas endangerment finding became effective April 20. That finding had served as the legal basis for federal greenhouse-gas standards for new motor vehicles and engines. EPA’s action also repeals those vehicle standards for light-, medium-, and heavy-duty vehicles and engines and has impacts on a range of other industries and may have broader significance for a range of other industries.
For more details on these topics, see below…
Automotive: NASF–AIAG Webinar on Decorative Chromium Transition | April Roundtable Review
NASF and the Automotive Industry Action Group (AIAG) held a virtual roundtable in April on the transition from hexavalent to trivalent chromium for decorative automotive applications. The session brought together OEM representatives from General Motors, Toyota, Volkswagen and Volvo Group with NASF member chemical suppliers and job shops for a discussion of policy direction, industry readiness and implementation across the supply chain.
OEM Planning, Specifications and Implementation Issues
OEM representatives provided updates on their transition plans, with companies describing new sourcing, approval and validation steps for trivalent or hexavalent-chrome-free decorative finishes. Chemical suppliers and job shops discussed the implementation environment, including color standards, quote activity, line-conversion options, mixed hexavalent/trivalent operations and the practical challenges of meeting evolving OEM requirements.
Feedback Signals Acceleration
Polling during the session confirmed that the transition is no longer theoretical for many companies. Questions addressed operational capacity, customer expectations and investment decisions as automotive planning for trivalent decorative finishes accelerates.
NASF and AIAG are making a recording of the session available to members and will continue coordination with OEMs, suppliers and applicators as the transition progresses.
Trade Policy: CBP Launches Process for IEEPA Tariff Refunds
U.S. Customs and Border Protection (CBP) has launched the first phase of its CAPE process for refunds of duties paid under International Emergency Economic Powers Act (IEEPA) tariffs that were invalidated by the Supreme Court earlier this year. The process follows Court of International Trade orders directing CBP to remove the affected duties and process refunds for eligible importers. For importers of record, or their authorized brokers, the CAPE process is the primary mechanism for seeking refunds for eligible entries.
Additional Phases Will Be Necessary
The scale of the refund process is substantial. According to CBP and court filings, approximately $166 billion in IEEPA duties were collected across more than 53 million entries filed by more than 330,000 importers. The first phase of the process does not cover every entry, and CBP has indicated that additional phases will be needed as implementation continues.
Other Trade Authorities Not Affected
The decision does not affect duties imposed under other trade authorities, including Section 232 tariffs on steel, aluminum, automobiles and parts, or Section 301 duties on China, which remain in place. NASF will continue to monitor CBP implementation and share updates where relevant to member companies and their supply chains.
Tax Policy: House Advances Narrow Tax Bills as Midterm Elections Loom
The House in late April advanced a series of bipartisan tax administration measures focused on IRS operations, taxpayer protections and a handful of narrower provisions. The bills are far more limited than last year’s major tax law, but they show that some noncontroversial tax items may still move even as broader tax policy becomes more difficult heading into the midterms.
The 2025 Law and New Data
The latest action comes as both parties define their tax messages for 2026 and beyond. The White House and Republican lawmakers are continuing to highlight the benefits of last year’s One Big Beautiful Bill Act, including measures aimed at supporting capital investment, equipment purchases, domestic R&D and business expansion. At the same time, a recent Atlanta Fed report from April suggests the law has not yet become a major driver of near-term firm planning for most businesses, with only 17 percent of firms reporting they increased planned capital investment for 2026.
Future Tax Debate
If Democrats retake one or both chambers, tax-related activity is expected to focus heavily on oversight of IRS operations and implementation of the 2025 law, with possible broader debate over tax fairness and middle-class tax relief. Additional tax legislation this year remains uncertain.
NASF will continue to monitor tax policy developments and solicit member input on federal tax and manufacturing policy issues as we move toward the September Washington Forum.
Environmental Policy: EPA Releases Updated PFAS Destruction and Disposal Guidance
EPA published its updated 2026 Interim Guidance in April on the Destruction and Disposal of PFAS and PFAS-Containing Materials. The guidance is non-binding and updates EPA’s 2024 version, including additional research and data reviewed through September 2025.
The guidance addresses large-scale approaches for managing PFAS-containing materials, including thermal treatment, landfilling, and underground injection, and identifies continuing data gaps for destruction efficiency, air emissions, landfill leachate, byproducts, and emerging technologies.
No Requirements for Finishing
For the surface finishing industry, the guidance does not create new disposal requirements and should not be read as changing current waste management obligations. Its relevance is limited primarily to situations where facilities are already managing PFAS-containing residuals under state, permit, POTW, or vendor arrangements. NASF will continue to monitor the guidance and related state implementation issues as EPA considers comments and future updates.
Safety Policy: OSHA Publishes Walking-Working Surfaces Proposal
On April 6, OSHA published its proposed update to the walking-working surfaces standard in the Federal Register. As anticipated in last month’s report, the proposal is narrowly focused on fixed ladder requirements and is intended to provide significantly greater compliance flexibility for certain general industry operations.
What the Proposal Would Change
The proposal would remove the November 18, 2036 deadline by which all existing fixed ladders extending more than 24 feet above a lower level must be equipped with personal fall arrest systems or ladder safety systems. Removing this deadline would allow employers to update existing fixed ladders at the end of their service lives rather than incur retrofit costs to meet a fixed compliance date.
The requirement to equip new and replacement fixed ladders with personal fall arrest systems or ladder safety systems remains unchanged.
Comment on Cages and Wells
Notably, OSHA is also seeking comment on a broader option: whether to repeal or revise the requirement that employers use personal fall arrest systems or ladder safety systems on fixed ladders over 24 feet and instead allow continued use of ladder cages or wells.
This would represent a more substantive revisiting of one of the central technical assumptions in the 2016 final rule and would address concerns raised by industry regarding retrofit feasibility, cost and safety benefit in older facilities.
Outlook
Many finishing operations will not be affected by the proposed change, but those with older fixed ladders over 24 feet should evaluate the proposal closely. NASF will continue to monitor the rulemaking in the meantime.
Environmental Policy: Historic EPA Greenhouse Gas Finding Repeal Takes Effect; Litigation Continues
EPA chief Lee Zeldin’s promised repeal of the Obama-era 2009 greenhouse-gas endangerment finding became effective April 20. That finding had served as the legal basis for federal greenhouse-gas standards for new motor vehicles and engines. EPA’s action also repeals those vehicle standards for light-, medium-, and heavy-duty vehicles and engines and may have broader significance for a range of other industries.
Litigation in the D.C. Circuit
In response to the Trump administration’s action, multiple coalitions of environmental, public-health, and state plaintiffs have filed challenges in the U.S. Court of Appeals for the D.C. Circuit. The challengers are expected to argue that EPA’s action conflicts with the Clean Air Act, the scientific record, and the Supreme Court’s 2007 decision in Massachusetts v. EPA, which held that greenhouse gases fall within the Clean Air Act’s definition of “air pollutant.” Litigation is expected to take time to resolve, and the ultimate status of the repeal may depend on whether the courts uphold, stay, remand, or vacate the rule.
Broader Clean Air Act Significance
Finishing operations, of course, are not directly regulated under the repealed vehicle greenhouse-gas framework, and the action does not impose new compliance obligations on surface finishing facilities. However, EPA’s repeal of the underlying finding has broader significance for automotive, power, oil and gas, and energy-intensive manufacturing sectors, though the rule itself is technically tied to vehicle GHG standards. NASF will continue to monitor the litigation and related regulatory developments where they may affect customer sectors important to surface finishing.
For additional information on any of this month’s topics, please contact Christian Richter at crichter@thepolicygroup.com or Jeff Hannapel at jhannapel@thepolicygroup.com.
NASF 1000
The NASF 1000 program was established to ensure that the surface finishing industry would have resources to effectively address regulatory, legislative and legal actions impacting the industry, NASF members and their workplaces. All funds from the NASF 1000 program are used exclusively to support specific projects and initiatives that fall outside the association’s day-to-day public policy activities. The commitment to this program is one of the most vital contributions made in support of surface finishing and directly shapes the future of the industry.
The sustained commitment from industry leaders has helped the NASF remain strong and credible in informing regulatory decisions across the nation. Specific projects funded through the NASF 1000 make a measurable difference in how the industry navigates emerging challenges, communicates credibly with policy makers, and advocates for a strong science base for rules or standards that affect surface finishing.
Please consider supporting the NASF 1000 program. For more information, contact: Christian Richter (202-257-0250) or Jeff Hannapel (202 257-3756) with NASF.
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