Earlier this week, the Congressional Sportsmen’s Foundation (CSF) joined the American Sportfishing Association (ASA) and the Coastal Conservation Association’s (CCA) California Chapter in opposing onerous regulations that have the potential to cripple the state’s fishing tackle suppliers.
As part of the Golden State’s “Green Chemistry Initiative,” the California Department of Toxic Substances Control (DTSC) has proposed a regulation on fishing weights and gear under the state’s Safer Consumer Product Regulations as a product category in the agency’s Priority Product Work Plan. Consequently, companies that manufacture, import, assemble or sell these products at retail locations could be subjected to extremely burdensome and unworkable requirements for many fishing-oriented businesses.
If adopted in its current draft form, DTSC’s Alternatives Analysis requirements could obligate fishing tackle manufacturers, suppliers and dealers to complete additional paperwork for each of the products they bring to the market and then submit it to the state for public review. Unfortunately, this would not simply be a matter of filling out a few forms. Instead, those who sell fishing tackle and gear would be required to evaluate process data, complete toxicological studies, review engineering and design phases for all products, assess the technical feasibility of using alternative substances during production, and conduct economic analyses to determine whether using different materials could generate revenue for private businesses. With much of the fishing tackle and gear industry being composed of small businesses and ‘mom-and-pop’ shops, many operate on thin profit margins that cannot absorb the added cost of these proposed regulations.
Making it more difficult for anglers to purchase gear and go fishing would also have unintended consequences. Each year, California’s recreational anglers provide $58 million in revenue to the California Department of Fish and Wildlife (CDFW) through license fees. Anglers generate $16.1 million in excise taxes for fisheries conservation efforts in California through the purchase of fishing tackle and gear -- the very products that DTSC’s regulations threaten to take off the shelves. By limiting consumers’ ability to purchase these goods and potentially shutting down small businesses through de-facto product bans, California’s proposed regulations would likely be detrimental to the wellbeing of its public trust resources.
To view the comments submitted to DTSC by CSF, ASA and CCA California, click here.
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