It has been two months since the comment period for EPA’s COVID-19 sell-through proposal closed. EPA has indicated they likely will not issue a Final Rule until late September or early October. Keep in mind that it is still illegal to sell a Step 1 product unless the EPA acts. The sell-through period would come into effect only if a Final Rule is published in the Federal Register and would expire for good on a specific date – in the proposal, this date is November 30, 2020.
In addition, some states have passed regulations that would make it illegal to sell Step 1 products even if the EPA acts, so make certain you follow your state’s rules.
We know this is frustrating with the busiest sales time quickly approaching, but you must follow the current regulations as published. HPBA will notify you as soon as anything official happens.