On February 19, 2015, California Air Resources Board extended the response time to the 2013 Consumer and Commercial Products Survey (2013 Survey). But be careful – there are different extensions for different groups, and if businesses do not fall into the “Formulators” or “Small Business” groups, then they can only receive an extension if they apply by submitting the required email request by February 27, 2015.
Additional Extension Requests
The California Air Resources Board (ARB) recognized the substantial resources required to complete the 2013 Consumer and Commercial Products Survey (2013 Survey). In some cases, ARB announced, companies may need extra time to complete reporting of 2013 data beyond the 90 statutorily required days and the additional 90-days ARB staff already issued due to the 2013 Survey scope. Below is a summary of the additional extension request process announced by ARB.
1. Formulators: All formulators will receive a 30-day extension to submit formulation data to ARB. The due date for formulators is extended to April 1, 2015. Formulators automatically receive the extension and do not need to send an email to request one.
2. Small Businesses: Responsible parties who are also a small business have an additional extension until July 1, 2015 for reporting 2013 data. For purposes of the 2013 Survey, a small business is defined as a company or entity with 25 or less full-time, part-time and contract employees combined. The 25 employee count must also include seasonal workers. For example, a salon with their own product line of hair care products with a 12 part-time employees would quality for this extension. Small businesses automatically receive the extension and do not need to send an email to request one.
3. Responsible Parties (other than those who qualify as “Small Businesses”): Responsible party requests will be handled on a case-by-case basis, and must request an extension by email no later than February 27, 2015. To request an extension from the original survey due date of March 2, 2015, responsible parties must email firstname.lastname@example.org by February 27, 2015 to make a request, and the email must have the following title: “2013 Survey Additional Extension Request – Company Name (add your company name here)”. In order to receive an extension, responsible parties will need to provide the following information:
a) When did you learn about the 2013 Survey?
b) When did you start working on the 2013 Survey?
c) When did you finish your data collection effort for the 2013 Survey?
d) Approximately how many products will you report? labels?
e) How far along are you in entering data into the Consumer Products Reporting Tool (CPRT)?
f) How much time are you requesting to complete the 2013 Survey?
ARB staff will notify each company the results of their request via email.
ARB also reminded survey participants to submit complete data reports, as partial data sets will not be accepted.
Conkle, Kremer & Engel attorneys keep abreast of the latest developments in California regulatory laws to guide the firm’s clients through the shifting labyrinth that they must navigate.