The Automotive Recyclers Association (ARA) issued a comment letter on September 7, detailing concerns and its opposition to the California Department of Toxic Substances Control (DTSC)’s emergency rulemaking on the definition of scrap metal in the state.
While the proposed regulations were specific to metal shredding facilities, professional automotive dismantlers play a vital role in providing feedstock to metal shredding and scrap metal facilities in the form of dismantled, depolluted and inoperable hulk vehicles. ARA is very concerned about the unintended consequences that this proposed rule would have on its members’ businesses.
ARA maintains that motor vehicles, motor vehicle parts