Comment Log Display

Dear Colleagues in the California Air Resources Board,

We are reaching out concerning this proposed rulemaking action
published in the California Regulatory Notice Review Register on
May 30, 2025 at
https://oal.ca.gov/wp-content/uploads/sites/166/2025/05/2025-Notice-Register-No.-22-Z-May-30-2025.pdf
beginning on page 13.

We understand that comments can be provided until July 14, 2025.

Per the attached, on behalf of China, we are requesting an
extension of the comment period, from July 14 to August 28, 2025.

Is CARB able to accept comments up to August 28, 2025, or even to
August 8, 2025? 

Included in the attached is a document with the symbol
G/TBT/N/USA/2218 (the symbol is similar to docket or reference
number) assigned to this CARB action by the Committee on Technical
Barriers to Trade at the World Trade Organization (WTO TBT
Committee), to which our office is obligated to submit certain U.S.
state and Federal proposed rules and related actions that could
affect international trading partners. A basic overview of the
notification of certain regulatory and related actions by the USA
to the WTO TBT Committee is available at
https://www.nist.gov/standardsgov/usa-wto-tbt-enquiry-point.

The Committee recommends a comment period of 60 days on
notifications of draft technical regulations and conformity
assessment procedures.  Information and details concerning the
recommendations and decisions of the TBT Committee can be found in
the publication "Decisions and Recommendations Adopted by the WTO
Committee on Technical Barriers to Trade Since 1 January 1995." The
most recent version of the publication was circulated on November
15, 2022 under the symbol G/TBT/1/Rev.15. On page 33 of the
document in section 6.3.1.8 "Length of time allowed for comments",
it states that at least 60 days should be provided for comments,
and longer if possible. The document is available from the WTO's
website at
https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S006.aspx?DataSource=Cat&query=@Symbol=%22G/TBT/1/Rev.15%22%20OR%20@Symbol=%22G/TBT/1/Rev.15/*%22&Language=English&Context=ScriptedSearches&languageUIChanged=true.

While our office carries out the transparency (notification)
obligations under the TBT Agreement, the Office of the United
States Trade Representative (USTR) represents the United States at
the WTO.  While I do not think that California is obligated to
extend the comment period on the rulemaking action in question, if
comments can be received and taken into account by CARB after July
14, we respectfully ask for consideration of the request.  

Please confirm receipt of this message as well as China's request
and contact us if there are questions or if additional information
is needed.  Please also feel free to pass this along to other
relevant agency colleagues as/if needed.  We look forward to
hearing from the CARB soon so that we can respond to China's
request.  
 
Thank you and best regards,

MaryAnn Hogan
USA WTO TBT Enquiry Point
Standards Coordination Office (SCO)
National Institute of Standards and Technology (NIST)
E-mail: usatbtep@nist.gov 
ePing SPS&TBT Platform: https://epingalert.org/ 
About Us:
https://www.nist.gov/standardsgov/usa-wto-tbt-enquiry-point