Comment submitted by Ultium Cells LLC and General Motors LLC

Summary: Ultium Cells LLC and General Motors LLC oppose the proposed SNURs, arguing that they are based on insufficient data, create unnecessary regulatory overlap with existing environmental laws (CAA, CWA, RCRA), and threaten the U.S. critical minerals supply chain by penalizing domestic battery recycling. They request that the EPA conduct a required cost and efficiency analysis and suggest using TSCA Section 6 for a more consistent regulatory framework.