Thank you to everyone who has signed this petition. While this petition is an important way to show the size and strength of public concern around HB 2421 and SB 6119, it’s important to understand that official public comments submitted through the Washington State Legislature’s website carry the most weight in the legislative process.
Petitions help lawmakers see that an issue matters to many people, but formal bill comments are what legislators and committees actively review and track as these bills move forward. If you want your voice to have the greatest impact, we strongly encourage you to take a few extra minutes to submit an official comment on the Legislature’s website in addition to signing this petition.
To make this easy, I’ve included the exact comments I submitted for HB 2421 and SB 6119 below. You are welcome to copy and paste them, modify them, or use them as a starting point for your own submission. When submitting, please remember to select OPPOSE for each bill.
Large numbers matter, but clear, official opposition matters most. Thank you for taking the time to do both.
HB 2421 Comment: (Link to comment submission: https://tinyurl.com/yhp7pufk)
House Bill 2421 establishes a seller-paid mitigation fee on certain replacement vehicle tires while restricting sellers from disclosing the regulatory cost impacts to consumers at the point of sale. Although structured as a compliance fee rather than a consumer tax, the measure will predictably result in higher retail prices and may, over time, increase overall consumer costs. At the same time, limiting disclosure of the regulatory causes of those price increases raises concerns about transparency and sets a troubling policy precedent. Environmental progress should not require concealing cost drivers from the public or advancing policy assumptions that are not yet supported by market realities.
Beginning in 2027, HB 2421 requires tire sellers to remit a mitigation fee of $3 per tire for load ratings up to 2,500 lbs. and $6 per tire ratings over 2,500 lbs., with the fee increasing by 10 percent annually after 2028. While the legal obligation to pay this fee rests with the seller, economic reality dictates that these costs will be incorporated into retail pricing and ultimately borne by consumers.
What is particularly concerning is that HB 2421 not only prohibits sellers from itemizing or passing through the mitigation fee as a separate charge, but also prevents them from referencing the regulatory origin of these price increases on receipts or sale documents. Sellers may raise prices, but they are restricted from explaining to customers why prices have increased at the point of sale. Preventing disclosure does not eliminate the cost; it merely obscures it, undermining basic price transparency and consumer trust.
The bill further appears to rely on an assumption that imposing costs at the retail level will accelerate the development of suitable 6PPD-free tire compounds. However, the structure of HB 2421 places the financial burden almost entirely on sellers and consumers, not on tire manufacturers who control product formulation, research, and development decisions. Sellers do not design tires, and consumers cannot meaningfully reduce demand for replacement tires. As a result, the fee provides little direct incentive for manufacturers to accelerate innovation or bring proven alternatives to market.
In absence of viable, widely available 6PPD-free products with comparable durability and performance, consumers will continue to purchase the only tires available to meet their needs, regardless of fee structure. In this context, the mitigation fee functions primarily as a cost increase rather than as a driver of technological change. When a policy increases costs without creating a meaningful pathway to compliance alternatives, it risks operating as a revenue mechanism rather than an innovation incentive.
Over time, this dynamic may convert what is described as a seller-side compliance fee into a de facto consumer tax. If limited alternatives or reduced durability lead to more frequent tire replacement, consumers face compounded financial impacts through higher per-unit prices, increased purchase frequency, and higher overall sales tax collections.
Environmental policy is most effective when incentives are properly aligned and when implementation timelines reflect technological readiness. HB 2421 currently establishes a fixed compliance date without tying enforcement to the demonstrated availability of suitable alternatives. A more balanced approach would include mechanisms such as delaying implementation until comparable products are available, tying activation of the fee to objective market criteria, or requiring periodic state review of available tire technologies before escalating costs.
Finally, I am concerned about the broader legal and policy implications of government mandated nondisclosure. HB 2421 goes beyond prohibiting a pass-through charge and instead restricts sellers from providing truthful, factual information about regulatory cost drivers on transaction documents, even as those costs will inevitably be incorporated into prices.
Environmental stewardship and consumer transparency should not be mutually exclusive. I respectfully urge the Legislature to reconsider the structure, timing, and incentive alignment of HB 2421 to ensure that it reflects market realities, targets the appropriate actors, and preserves the public’s right to understand the policies affecting what they pay.
I urge you to carefully reconsider the structure and implications of HB 2421.
SB 6119 Comment: (Link to comment submission: https://tinyurl.com/4jkh6354)
Senate Bill 6119 proposes a phased prohibition on the manufacture and sale of tires containing 6PPD or certain substitutes in Washington, along with a mitigation fee imposed on tire sellers beginning in 2027. While the environmental intent of this bill is clear and widely shared, its structure raises serious concerns about incentive alignment, market readiness, and the practical effectiveness of the proposed approach.
SB 6119 establishes a mitigation fee on replacement tires that contain 6PPD, followed by an outright ban beginning in 2035. Although framed as a long transition period, the bill presumes that functionally equivalent, durable, and affordable 6PPD-free alternatives will be available statewide by that date. At present, such alternatives have not been proven at scale, and the bill provides no objective mechanism to ensure market readiness before enforcement.
A central concern is that SB 6119 places the economic burden primarily on tire sellers and consumers, while the entities responsible for tire formulation and chemical innovation, manufacturers, are largely insulated from direct regulatory or financial pressure. Sellers do not design tires, and consumers cannot meaningfully reduce demand for replacement tires. As structured, the bill relies on downstream actors to absorb costs and compliance risks, rather than directly incentivizing manufacturers to accelerate research, testing, and deployment of proven alternatives.
The bill further grants broad authority to the Department of Ecology to identify “regrettable substitutes” and determine what qualifies as a safer alternative. While regulatory oversight is necessary, this approach introduces uncertainty for manufacturers, sellers, and consumers alike. Without clear, objective, and predictable standards, substitutes may be discouraged or prohibited before their real-world performance and durability are fully understood, potentially leading to unintended consequences such as reduced product lifespan, increased replacement frequency, and higher overall environmental and economic costs.
Additionally, SB 6119’s mitigation fee and eventual prohibition risk functioning more as a cost-shifting and revenue-generating mechanism than as a true driver of innovation. Consumers will continue to require tires regardless of regulatory timelines, and increased replacement frequency whether due to limited alternatives or reduced durability could result in higher aggregate consumer spending and increased tax collections without a corresponding improvement in environmental outcomes.
Environmental policy is most effective when incentives are properly aligned and when enforcement timelines reflect technological and market realities. A more balanced approach would include mechanisms such as tying enforcement milestones to the demonstrated availability of viable alternatives, requiring periodic market-readiness reviews, or directly engaging manufacturers through targeted research incentives or performance-based standards.
Without meaningful changes to its structure and enforcement triggers, SB 6119 risks becoming a costly mandate that shifts burdens onto consumers and sellers while failing to deliver the technological innovation and environmental outcomes it purports to achieve.