In the manufacturing sector, the U.S. Census Bureau reports shipments and inventories figures for many durable and non-durable goods categories. One of the segments reported on a monthly basis aggregates adhesive manufacturing (NAICS 32552) with paint and coating manufacturing (NAICS 32551). The resulting report does provide some useful directional data. This is particularly true in that adhesives demand is driven by many of the same drivers as paints and coatings; specifically, durable goods manufacturing and construction.
The Census data for the combined industries show a steady increase in the value of shipments following the end of the severe 2007-09 recession. However, as shown in Figure 1, while the value of shipments has risen 61.5 percent, the total inventories held in the two industries has only risen approximately 25 percent.
As a result, the inventory to shipments ratio for coatings and adhesives is now slightly above 1.0. The lean inventories held by the combined industries, as shown in Figure 2, compares quite well to the overall chemical industry, where inventories to shipments levels have held steady at approximately 1.3 over the past two years, and with the durable goods manufacturing sector, where the ratio of inventories to shipments has historically been lower than in coatings and adhesives, but which has seen steady, but higher inventories to shipments ratios than the combined coatings and adhesives industries since early 2015.
Contact ACA’s Allen Irish for more information.
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Ohio’s Environmental Protection Agency’s (EPA) adopted final changes to its Universal Waste rules on Dec. 8. The amendments designate hazardous non-empty aerosol containers, hazardous antifreeze, and hazardous paint and paint-related wastes as “universal wastes,” to promote proper handling, recycling, or disposal of the hazardous waste. ACA extensively participated in the interested party review portion of the rulemaking process, and is pleased that Ohio EPA incorporated many of its suggested comments into the final rules.
The rules will be effective on Dec. 21, 2017. ACA will release a brief guidance document explaining what the final rule amendments mean for member facilities in Ohio.
On Nov. 21, 2016, the agency released proposed amendments to its Universal Waste Regulations, which included defining aerosols and paint and paint-related waste (PPRW) as universal waste in Ohio. In advocating for this proposed rule, ACA underscored to Ohio EPA, 1) the environmental benefits that would result from classifying PPRW as universal waste; 2) how classifying PPRW as universal waste would create better facility management; and 3) provided specific examples of why classifying PPRW as universal waste would alleviate regulatory burdens, costs, and encourage more recycling and reuse.
Over the past year, ACA’s Ohio Paint Council has been working with the Ohio Manufacturers’ Association and Ohio EPA to develop universal waste regulations for PPRW.
ACA submitted comments to the agency on its proposal in December 2016. ACA’s comments addressed the proposal’s definitions of “aerosol” and “paint,” methods for puncturing, shredding or crushing containers, and capturing of VOCs. ACA has long maintained that paint and paint-related waste satisfy the criteria for designating a new universal waste. Paint is used by a wide range of different manufacturing industries and establishments, and does not pose a significant risk when accumulated and transported. This designation as a universal waste will promote the proper recycling or disposal of the hazardous waste and divert it from non-hazardous waste management systems.
ACA hopes this new regulation will serve as a model that can now be used to promulgate analogous regulations in other interested states. Currently, only Texas and New Jersey have universal waste rules for paint and paint-related waste: Texas has rules for managing Paint and Paint-Related Wastes under its Universal Waste Rule (see its guidance document and regulations); New Jersey has rules for managing Oil-Based Finishes such as oil-based paints, lacquers, stains, and aerosol paint cans under its Universal Waste Rule (see its information site).
ACA believes that including both paint and paint-related waste is very important as certain materials are not incorporated into the actual product itself, but are nonetheless critical for paint application and should be listed along with paint.
Earlier this month, ACA urged Congress to expedite passage of the “Miscellaneous Tariff Bill Act of 2017” (H.R. 4318 and S. 2108) to temporarily eliminate out-of-date and distortive taxes on imported products not manufactured or available domestically.
ACA signed onto a letter of support organized by the National Association of Manufacturers (NAM), which was signed by some 200 industry associations and organizations and sent to members of Congress.
The Miscellaneous Tariff Bill (MTB) plays an important role in the operations of domestic manufacturers as it corrects, on a temporary basis, historical distortions in the U.S. tariff code by eliminating border tariffs on imported products for which there is no or insufficient domestic production and availability. ACA believes such distortions undermine the competitiveness of manufacturers in the United States by imposing unnecessary costs and, in some cases, imposing a higher cost on manufacturers’ inputs than the competing foreign imported finished product.
While Congress had effectively addressed such distortions through the enactment of MTB legislation with strong bipartisan support for three decades, Congress has not passed an MTB since the U.S. Manufacturing Enhancement Act in 2010 expired at the end of 2012. Since 2012, businesses have paid billions of dollars of tariffs on products not even made in the United States, to the detriment of American jobs and American competitiveness.
“Congress now can address this self-imposed tax on U.S. competitiveness,” the letter stated. “Through a transparent and thorough process created by the American Manufacturing Competitiveness Act of 2016 (AMCA), which passed Congress with near unanimous bipartisan support, the U.S. International Trade Commission (ITC) scrutinized thousands of petitions for duty-relief and received input from across the manufacturing sector and from the U.S. Department of Commerce and U.S. Customs and Border Protection to determine eligibility under the AMCA requirements.”
The Miscellaneous Tariff Bill Act of 2017 includes nearly 1,700 petitions that the ITC reported to Congress in August were eligible for duty-relief as products not produced or available in the United States.
“Our organizations strongly support passage of the Miscellaneous Tariff Bill Act of 2017, which would bolster manufacturers and other businesses in the United States, especially small- and medium-sized manufacturers, in industries ranging from chemicals, agriculture, textiles and footwear to electrical equipment, machinery and sporting equipment.”
According to analyses by the National Association of Manufacturers, this legislation would eliminate import tariffs of more than $1.1 billion over the next three years and boost U.S. manufacturing output by more than $3.1 billion.
Contact ACA’s Allen Irish for more information.
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