Dear Mr. Zients,

As members of the Manufacturers for Sensible Regulations coalition, representing hundreds of thousands of businesses across the nation that collectively employ millions of Americans, we write to express our concern with the regulatory burden, which is hindering our ability to create well-paying jobs, grow the economy and create the products that will improve the quality of life for everyone.

President Biden has made strengthening the manufacturing sector a priority for his administration. Historic legislation like the Bipartisan Infrastructure Law, the CHIPS and Science Act, key energy provisions of the Inflation Reduction Act and the initial permitting reforms in the Fiscal Responsibility Act underscores the commitment that policymakers have made to our industry. However, the onslaught of new regulations, some of which are previewed in the recently released Spring 2023 Unified Agenda of Regulatory and Deregulatory Actions,1 is chilling manufacturing investment, curtailing manufacturers’ ability to hire new workers and suppressing wage growth, especially for the small and medium-sized manufacturers that are the backbone of the supply chain.

According to the National Association of Manufacturers’ Q2 2023 Manufacturers’ Outlook Survey,2 more than 63% of manufacturers report spending more than 2,000 hours per year complying with federal regulations, while more than 17% of manufacturers report spending more than 10,000 hours. That is time that cannot be spent on more productive activities, including delivering products to customers, and it expends resources that otherwise could go toward hiring, raises or capital investments.

The Outlook Survey demonstrates that there are clear consequences to burdening companies with higher compliance costs: “Concern about an unfavorable business climate was the highest in six years […] 65.0% of manufacturers would purchase more capital equipment if the regulatory burden on manufacturers decreased, with 46.9% increasing compensation, 43.2% hiring more workers, 40.1% investing in research and 38.1% expanding their U.S. facilities.”

The cost of complying with regulations can be enormous, particularly when it comes to regulations that impact hiring and retention. The most current data on the cost of regulations shows that the average U.S. company paid $9,991 per employee per year to comply with federal regulations, but the average manufacturer in the United States pays nearly double that amount: $19,564 per employee per year. Small manufacturers face an even higher and

Regulations create tremendous uncertainty, which can stall or even prevent manufacturers from growing their workforce, purchasing equipment, conducting research and development and investing in their communities. This puts manufacturers in the U.S. at a competitive disadvantage with countries such as China, threatening America’s global leadership. To ensure manufacturers remain competitive, we respectfully request that a senior-level adviser be designated to coordinate efforts within the White House to ensure that federal regulators are implementing policies that align with the president’s promise to promote the growth of manufacturing in America.

Our industry has been extraordinarily resilient in recent years, leading the country forward amid global upheaval. The federal regulatory barrage threatens our ability to continue growing and creating jobs and to compete on the global stage. Manufacturers are committed to commonsense legal and regulatory reforms that ensure public health and safety, and we look forward to continuing working with you to find solutions that foster sensible regulations that support manufacturers’ continued job creation and economic competitiveness.

Sincerely,

Adhesive and Sealant Council

Aerospace Industries Association

AICC, The Independent Packaging Association

Alaska Chamber

Alliance of Wyoming Manufacturers

Aluminum Association

American Bakers Association

American Boiler Manufacturers Association

American Chemistry Council

American Cleaning Institute

American Coatings Association

American Coke and Coal Chemicals Institute

American Composites Manufacturers Association

American Forest & Paper Association

American Foundry Society

American Frozen Food Institute

American Iron and Steel Institute

American Wood Council

AMERIPEN – American Institute for Packaging and the Environment

AMT – The Association For Manufacturing Technology

Arizona Manufacturers Council

Arkansas State Chamber of Commerce and Associated Industries of Arkansas, Inc.

Associated Equipment Distributors

Associated Industries of Florida

Associated Industries of Massachusetts

Associated Industries of Missouri

Associated Industries of Vermont

Association of Home Appliance Manufacturers

Association of Washington Business

Autos Drive America

Beer Institute

Business + Institutional Furniture Manufacturers Association

Business and Industry Association of New Hampshire

California Manufacturers & Technology Association

Can Manufacturers Institute

CBIA

Cellulose Insulation Manufacturers Association

Chamber of Commerce Hawaii

CIBO

Colorado Chamber of Commerce

Composite Can and Tube Institute

Composite Panel Association

Consumer Technology Association

Council of Industrial Boiler Owners

Delaware State Chamber of Commerce and the Delaware Manufacturing

Association

Electronic Components Industry Association

Flexographic Pre-Press Platemakers Association

The Food Industry Association

Forest Resources Association

Georgia Association of Manufacturers

Greater North Dakota Chamber

Household & Commercial Products Association

Hydraulic Institute

Idaho Association of Commerce & Industry

Illinois Manufacturers’ Association

Association of the Nonwoven Fabrics Industry

Independent Lubricant Manufacturers Association

Indiana Manufacturers Association

Industrial Packaging Alliance of North America

Industrial Truck Association

Institute of Makers of Explosives

International Molded Fiber Association

International Sign Association

Iowa Association of Business and Industry

Irrigation Association

ISRI, Voice of the Recycled Materials Industry

Kansas Chamber of Commerce

Kentucky Association of Manufacturers

Laboratory Products Association

Louisiana Association of Business and Industry

Maine State Chamber of Commerce

Maryland Chamber of Commerce

Metal Building Manufacturers Association

Metal Powder Industries Federation

Metal Treating Institute

Metals Service Center Institute

Michigan Manufacturers Association

Minnesota Chamber of Commerce

Mississippi Manufacturers Association

Montana Chamber of Commerce

Motorcycle Industry Council

National Association of Manufacturers

National Electrical Manufacturers Association

National Glass Association

National Lime Association

National Mining Association

National Propane Gas Association

National Wooden Pallet & Container Association

Nebraska Chamber of Commerce and Industry

Nevada Manufacturers Association

New Jersey Business & Industry Association

New Mexico Business Coalition

Non-Ferrous Founders’ Society

North American Association of Food Equipment Manufacturers

North Carolina Chamber

Oregon Business & Industry

Paper Receipts Converting Association

Paperboard Packaging Council

Pennsylvania Manufacturers’ Association

Plastics Pipe Institute

Plumbing Manufacturers International

Portable Generator Manufacturers’ Association

Power Tool Institute

PRINTING United Alliance

Railway Supply Institute

Recreational Off-Highway Vehicle Association

Rhode Island Manufacturers Association

Society of Chemical Manufacturers & Affiliates

South Carolina Chamber of Commerce

South Dakota Chamber of Commerce

Specialty Equipment Market Association

Specialty Vehicle Institute of America

Steel Manufacturers Association

Tennessee Chamber and Manufacturers Association

Texas Association of Business

Textile Care Allied Trades Association

The Business Council of Alabama

The Business Council of New York State

The Carpet and Rug Institute

The Hardwood Federation

The Ohio Manufacturers’ Association

The Plastics Industry Association

The State Chamber of Oklahoma

The Sulphur Institute

Utah Manufacturers Association

Valve Manufacturers Association

Vinyl Institute

West Virginia Manufacturers Association

Window & Door Manufacturers Association

Wisconsin Manufacturers & Commerce

Wood Machinery Manufacturers of America