Foundry Reporting Burdens: An Opportunity to Weigh In

Posted By: Jess Marvin Government Affairs, NFFS,
The Foundry Brief
Regulatory Watch

EPA Seeks Comments on Nonferrous Foundry Reporting Requirements

EPA is seeking input on the renewal of reporting and recordkeeping requirements under existing air emissions standards for certain nonferrous foundries.

October 2026  |  Exclusively for NFFS Members

The Environmental Protection Agency (EPA) is seeking public comments on the renewal of the reporting and record keeping requirements under its National Emission Standards for Hazardous Air Pollutants for Aluminum, Copper and Other Non-Ferrous Foundries. The notice was published September 24, 2026, with comments due October 26.

At a Glance

What You Need to Know

What EPA Is Reviewing

Renewal of information collection under existing standards. This action would not establish new emissions limits.

Why It Matters

Affected foundries can provide feedback on the time and cost of reporting and record keeping, including opportunities to simplify the requirements.

Date to Watch

Public comments are due October 26, 2026.

Existing Standards

Which Foundries Are Covered?

The baseline standards apply to certain foundries which are area sources of hazardous air pollutants, melt 600 tons or more of metal per year and use materials which contain or may emit the pollutants covered by the rule. Depending on the applicable requirements, such facilities will be required to submit notifications and reports, conduct performance testing and maintain compliance records.

Reporting & Record keeping

EPA Estimates the Annual Burden

EPA estimates the information collection will cover 318 respondents and will impose a total annual burden of approximately 11,900 hours and $1.64 million. There is no change in the estimated burden as compared to the previously approved collection.

11,900 Hours  |  $1.64 Million
EPA’s estimated total annual reporting and record keeping burden across 318 respondents.
Public Comment Opportunity

What Can Comments Address?

The action would renew approval for collecting information under the existing standards rather than establishing new emissions limits. Comments may address the need for the information, the accuracy of the EPA’s burden estimates and opportunities for simplification of the reporting and recordkeeping requirements.

NFFS Perspective

What This Could Mean for Foundries

For affected foundries, this comment period offers an opportunity to explain the practical work involved in meeting reporting and record keeping requirements.

Compare the estimates with your experience
Consider the staff time and costs your facility devotes to preparing reports and maintaining compliance records.
Identify opportunities to simplify
Specific examples of duplicative work or difficult reporting processes can help explain where improvements may be possible.
Keep the scope in view
The notice concerns renewal of information collection under existing standards; it does not propose new emissions limits.
Timeline

Key Dates

September 24, 2026
EPA publishes the notice seeking comments on renewal of the information collection.
October 26, 2026
Public comments are due.

Review the official notice for details and instructions on submitting comments.

Review the EPA Notice
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