Yes. In 1998, after Section 1417 was amended to prohibit the introduction into commerce of any pipes, pipe or plumbing fittings or fixtures, EPA issued guidance on the enforcement and implementation of Section 1417. In the guidance, EPA explained that it “interprets ‘introduce into commerce’ as used in Section 1417 of SDWA to cover not only the initial offering of products for sale but also the sale or distribution from an inventory of products.” (WSG #129, Sept. 24, 1998, at 2).
Has EPA interpreted the term ?introduction into commerce? in SDWA Section 1417(a)(3)?
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