Inadmissibility of Consumer Products and Industrial Equipment Noncompliant with Applicable Energy Conservation and Labeling Standards

PLEASE SEE ATTACHED COMMENTS OF THE TELECOMMUNICATIONS INDUSTRY ASSOCIATION REGARDING THE INADMISSIBILITY OF CONSUMER PRODUCTS AND INDUSTRIAL EQUIPMENT NONCOMPLIANT WITH APPLICABLE ENERGY CONSERVATION OR LABELING STANDARDS The Telecommunications Industry Association (TIA) appreciates the opportunity to provide comments on the Notice of Proposed Rulemaking regarding the Inadmissibility of Consumer Products and Industrial Equipment Noncompliant with Applicable Energy Conservation or Labeling Standards. TIA represents the global information and communications technology industry through standards development, advocacy, tradeshows, business opportunities and market intelligence. For over eighty years, TIA has enhanced the business environments for broadband, mobile wireless, information technology, networks, cable, satellite, and unified communications. TIA's 600 member companies' products and services empower communications in every industry and market, including healthcare, education, security, public safety, transportation, government, the military, the environment and entertainment. TIA's members produce the equipment and solutions that make up our Nation's rapidly evolving communications networks, and many TIA members produce products directly affected by the proposed rulemaking. As discussed in greater detail in the attached comments, TIA's primary concern with the proposed rule is that it will place an open ended burden on U.S. Customs and Border Protection, requiring its finite resources to be pulled from the other responsibilities of its mission. Additionally, if this rule is adopted, the proposed 30 day window is insufficient to allow companies to bring products into compliance.