The Retail Industry Leaders Association (“RILA”), the Food Marketing Institute (“FMI”), the National Association of Chain Drug Stores (“NACDS”), the National Retail Federation (“NRF”), the National Grocers Association (“NGA”), and their members (collectively, the “Retail Associations”) are pleased to submit these comments in response to the above mentioned Notice of Proposed Rulemaking (“NPRM”). 79 Fed. Reg. 46,748 (Aug. 11, 2014). The Retail Associations applaud the Department of Transportation’s (“DOT’s”) continued effort to complete rules to address reverse logistics. Implementing separate rules for reverse logistics will improve the efficiency and scalability of reverse logistics for all parties in the supply chain, support DOT’s goals of continuing to ensure safe and environmentally responsible transportation of unsold and returned consumer goods, and provide better opportunities for both large and small companies to participate in reverse logistics activities.

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