| Since Inauguration Day, the Trump administration has launched an aggressive agenda aimed at rolling back key Biden-era decisions and advancing immediate changes across multiple fronts with potentially far-reaching impacts. As anticipated, the White House has taken actions or announced plans through more than two dozen executive orders and presidential memoranda, ranging from border security and immigration, trade and tariff policy, energy, environment and workplace regulations and resizing the federal bureaucracy.
Regulatory Freeze
The White House has also imposed a regulatory freeze on the issuance of both proposed and final rules across the agencies to allow senior political appointees to move into their new roles and engage in a broad review of federal rulemaking. NASF is closely monitoring offices at key federal agencies, including emerging personnel changes and announcements that impact the finishing industry.
Senate Confirmations
On Capitol Hill, the Senate acted to confirm the president’s appointments to several departments in recent days, including Homeland Security, Treasury, Department of Defense. The U.S. Senate also confirmed former New York congressman Lee Zeldin as the new EPA Administrator on Wednesday, January 29, 2025.
Tariffs on Canada and Mexico Could Come on February 1: President Trump on Thursday, January 30 announced he will impose 25 percent tariffs on Canada and Mexico beginning on Saturday, February 1, and highlighted his continued concerns over illegal migration, fentanyl and trade deficits as threats to the U.S. that must be addressed.
The Trump administration has been in ongoing discussions with Mexican and Canadian officials, with both countries preparing retaliation if the White House follows through on its plans.
The American Automotive Policy Council (AAPC), which represents Ford, GM and Stellantis, noted that the U.S. auto sector would be hit hard by the duties, and stated this week that cars and parts which meet the US-Mexico-Canada Agreement (USMCA) rigorous rules of origin should be exempt from any new tariffs.
“If these tariffs are imposed, all vehicles and parts that comply with current USMCA trade agreement rules should be exempt, as they meet the strict standards originally negotiated by President Trump to support jobs and investment in the United States,” Governor Matt Blunt, President of the AAPC, said this week.
During his Senate confirmation hearing on January 29, President Trump’s nominee for Commerce secretary, Howard Lutnick, said that Canada and Mexico were making progress on border security and other issues and could possibly avoid the tariff threat.
NASF Trivalent Chromium Coatings Transition Virtual Event with the Automotive Industry Action Group: The National Association for Surface Finishing is planning a virtual panel discussion and update on March 18 from 2:00 – 4:00 pm ET on key industry and regulatory developments in the transition from hexavalent to trivalent chromium coatings in the automotive supply chain.
NASF and Automotive OEM collaboration
In collaboration with the Automotive Industry Action Group (AIAG), the leading organization representing the automotive supply chain, NASF will host OEM, plating and supplier leaders on AIAG’s Electroplating Workgroup to discuss the direction of OEM efforts to voluntarily reduce and eliminate hexavalent chromium for decorative applications.
Industry Survey and Outreach
NASF and AIAG in 2024 conducted an industry survey and outreach across the supply chain to ensure the Electroplating Workgroup and OEMs gained a more in-depth understanding of industry capabilities, complexities and challenges to voluntarily eliminate hexavalent chromium in decorative electroplating as well as chromic acid etch. The workgroup also reached out to Tier 1 organizations last fall to discuss recent trends, outlook and industry needs.
Event Registration
NASF will be sending out an invitation to register as the landscape in 2025 continues to evolve on the transition from hexavalent to trivalent plating and coatings.
If you have any questions or would like more information about the webinar or NASF’s collaboration with the Automotive Industry Action Group, please contact Christian Richter or Jeff Hannapel with NASF at crichter@thepolicygroup.com or jhannapel@thepolicygroup.com.
Newly Proposed Federal Stormwater Permit Targets Finishers and Other Sectors for PFAS: In one of the Biden administration’s final regulatory actions, EPA published its proposed 2026 multi-sector general permit (MSGP) for stormwater discharges from industrial activities. When finalized, the 2026 MSGP would replace the 2021 MSGP that expires on February 28, 2026.
Additional Facility Monitoring Requirements
The proposed 2026 MSGP includes additional monitoring requirements such as quarterly indicator monitoring for PFAS. The PFAS monitoring would be for reporting purposes only, and facilities would not have to implement any control measures for PFAS at this time. It is, however, likely that based on monitoring results such control measures for PFAS in stormwater discharges would be required in the near future for many facilities.
The 2026 MSGP would also modify actions required for other contaminants for the additional implementation measures (AIM) that were included for the first time in the 2021 MSGP. Facilities that exceed monitoring thresholds for benchmark substances would be required to submit AIM reports to regulatory agencies identifying the reasons for the exceedances.
Potential Impacts Nationwide
While the MSGP is only binding in three states (those without authorized Clean Water Act programs), most states use the provisions in the MSGP as a model for their stormwater regulations. The proposed changes to the MSGP could have significant impact on stormwater discharges from surface finishing operations. Comments on the proposal are due February 28, 2025.
As the Trump administration reviews the rule, NASF will continue to work with regulators and industry stakeholder on the proposed changes to the MSGP. If you have any questions regarding the MSGP, please contact Jeff Hannapel or Christian Richter with NASF at jhannapell@thepolicygroup.com or crichter@thepolicygroup.com.
EPA’s New Effluent Guidelines Program Plan: Focus on Surface Finishing: In another late issuance from the Biden administration, EPA released its Preliminary Effluent Guidelines Program Plan 16 (Preliminary Plan 16) on December 16, 2024. It identifies the Agency’s efforts to study and develop technology-based limits on industrial wastewater discharges.
Latest Conclusions for Surface Finishing and PFAS
The document highlights the agency’s latest views on surface finishing and PFAS, as follows:
- PFAS-free fume suppressants are now available;
- Many facilities could switch to trivalent chromium;
- A number of facilities are successfully using granular activated carbon for PFOS and it may be effective for other PFAS wastewater treatment;
- Other technologies may be available, including membranes, ion exchange and PFAS destruction techniques.
Members should bear in mind that the Trump administration’s EPA leadership will not likely reverse or rescind the latest Plan 16 but will review these conclusions for the metal finishing industry as the agency determines how to move forward on next steps in the metal finishing PFAS effluent guidelines rule.
NASF will continue to be deeply involved in discussions with EPA at all levels about what an appropriate path forward will be for the metal finishing PFAS effluent guidelines proposed rule, which at this time is still scheduled for issuance in August 2026.
If you have any questions regarding EPA’s ELG program or Preliminary Plan 16, please contact Jeff Hannapel or Christian Richter with NASF at jhannapell@thepolicygroup.com or crichter@thepolicygroup.com.
Trump EPA May Review Final Biden Chemical Rules for TCE, PCE and CTC: The Trump administration may review another late Biden administration regulatory action from a few weeks ago for three solvents: trichloroethylene (TCE), perchloroethylene (PCE), and carbon tetrachloride (CTC).
The December action either banned or phased out most, if not all uses of these chemicals. EPA gave some exemptions to the bans and phase outs to avoid impacts to national security or critical infrastructure and to allow reasonable time for transitioning to alternatives but finalized stringent controls for continuing uses under a Workplace Chemical Protection Program.
The impact of these and other ambitious rules may be minimized if the Trump Administration halts the implementation dates of pending rules.
NASF will continue to monitor developments in the wide range of ongoing actions in EPA’s existing chemicals risk management program now under new leadership. If you have any questions regarding these or other chemicals rules, please contact Jeff Hannapel or Christian Richter with NASF at jhannapel@thepolicygroup.com or crichter@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. |
New England Chapter of NASF is an official chapter of