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Brake Manufacturers Council General Meeting Las Vegas, NV October 31, 2011 Agenda • Welcome and Introductions – Bob Wilkes • Review of Anti-trust Guidelines – Sarah Bruno • Industry Analysis – Paul McCarthy • MEMA Government Affairs Update – Ann Wilson • SAE Task Force Update – Greg Vyletel • Wrap-up and Adjourn – Bob Wilkes Antitrust Guidelines It is the unqualified policy of the Motor & Equipment Manufacturers Association to conduct its operations in strict compliance with the antitrust laws of the United States. MEMA's antitrust policy prohibits any discussions which constitute or imply an agreement or understanding concerning: 1) prices, discounts, or terms or conditions of sale; 2) profits or profit margins or cost data; 3) market shares, sales territories or markets; 4) allocation of customers or territories; 5) selection, rejection or termination of customers or suppliers; 6) restricting the territory or markets in which a company may resell products; 7) restricting the customers to whom a company may sell; or 8) any matter which is inconsistent with the proposition that each manufacturer, wholesaler and distributor must exercise its independent business judgement in pricing its services or products, dealing with its customers and suppliers and choosing markets in which it will compete. Aftermarket Point-of-View 11/2011 Paul McCarthy Vice President, Industry Analysis Automotive Aftermarket Suppliers Association This presentation is the property of the Automotive Aftermarket Suppliers Association (AASA) and subject to the protection of copyright, trademark and other intellectual property laws. No portion of this presentation may be reproduced or distributed (including by email) without the prior written consent of AASA. Agenda 1. Recent Publications 2. Aftermarket Outlook: A. Why to be Concerned B. Why to be Positive 3. Pulse: Supplier KPI Benchmarks 4. Upcoming Study: Longer Terms & Factoring Status Report, World Motor Vehicle Market Report, Replacement Rates Market size Product durability Parts demand trends Unperformed maintenance Aftermarket size and growth Size and growth of key subsectors Vehicle population and usage Outlet channel market share DIY market share trends World vehicle census by country Global production and assembly World trade in motor vehicles World motor vehicle markets On your memory cards and available for download on AASA website AASA Barometer: Very positive response to recent changes Barometer Changes • Insight, not data • “So what” and trends clear • More timely: use in quarterly management / investor reports • Participation at all-time high • Participants received a lot of this presentation’s content a month ago! If you’re one of the few that doesn’t participate, START! AASA Pulse: Supplier KPI Benchmarks Big Changes This Year • New multiple choice format took average completion time down to 6 minutes • Completely new report focused on the “so what” for your business Next Year • Survey out in April • So can better use in business planning • PLEASE PARTICIPATE – you’re missing out if you don’t • Very favorable AASA Board feedback • You’ll see select results in this deck Jeff Brekke (Gates): “I’m blown away by this report. This really is great business information you can’t get anywhere else.” Special Reports & Timely Analysis Follow-up to Aftermarket 2020: Leveling the Playing Field If you missed it, other recent AASA Industry Analysis: New fuel economy regulations: Why they may be good for the aftermarket High Gas Prices: Is It Different This Time? A copy should be on the table in front of each of you Timely Barometer feedback on the issues facing your business •Recession expectations •What recession would means for aftermarket •Impact of raw material prices •Impact of higher fuel prices •Japan disaster impact Agenda 1. Recent Publications 2. Aftermarket Outlook: A. Why to be Concerned B. Why to be Positive 3. Pulse: Supplier KPI Benchmarks 4. Upcoming Study: Longer Terms & Factoring Is the sky falling? • There has been a lot of talk about recession risk, economic stagnation, and slowing growth • What does this mean for the aftermarket? • Should we be concerned or positive about the outlook? Agenda 1. Recent Publications 2. Aftermarket Outlook: A. Why to be Concerned B. Why to be Positive 3. Pulse: Supplier KPI Benchmarks 4. Upcoming Study: Longer Terms & Factoring General economic trend is worrisome NAM Economic Conference • 35-40% chance of recession • Very vulnerable economy • Two risks could easily tip us into recession: 1. European meltdown causes a banking crisis 2. Ill-timed fiscal tightening (either tax increase or big near-term government cuts) Consumer Confidence at recession levels Best case: Slow-growth “new normal” Aftermarket suppliers are predicting a recession Do you believe the US economy has or will soon enter a recession? 60% 40% 59% 41% 20% 0% Yes -20% No AASA members’ outlook continued to worsen Sentiment in the aftermarket in the range seen during last recession 50 40 30 20 10 0 -10 -20 -30 -40 -50 2007 Q1 2007 Q2 2007 Q3 2007 Q4 2008 Q1 2008 Q2 2008 Q3 2008 Q4 2009 Q1 2009 Q2 2009 Q3 2009 Q4 2010 Q1 2010 Q2 2010 Q3 2010 Q4 2011 Q1 2011 Q2 2011 Q3 Supplier Sentiment Index Persistently high gasoline prices remain a drag on performance $3.42/gal 10/24/11 Weekly U.S. Regular All Formulations Retail Gasoline Prices (Dollars per Gallon) Source: Energy Information Administration Miles driven is stagnating after 3 decades of steady growth Annual Vehicle Miles Driven (Billion Miles) 3,200 3,000 2,800 2,600 2,400 2,200 2,000 1,800 Source: US DOT 2011 2010 2009 2008 2007 2006 2005 2004 2003 2002 2001 2000 1999 1998 1997 1996 1995 1994 1993 1992 1991 1990 1989 1988 1987 1986 1,600 It’s harder for consumers to afford to maintain and repair vehicles Number of US Americans who: Can’t pay for a $2,000 repair % ~25% Can afford a $2,000 repair from savings 38% Can afford a $1,000 repair from savings 46% Neglected car repairs & maintenance in the last 12 months due to economy ~25% Holding on to older vehicle because they don’t want the financial burden of a new one >50% Sources: AAA Rate of aftermarket supplier sales growth has declined for four consecutive quarters 6% 55% -22% 2009 2009 2009 2009 2010 2010 2010 2010 2011 2011 2011 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Small Declines Large Declines Modest Growth Substantial Growth Note: “No change” is shown as neutral (as a zero value) on the chart to allow a visual depiction of trends Decline 120% 100% 80% 60% 40% 20% 0% -20% -40% -60% -80% Growth How strong are your company sales? Agenda 1. Recent Publications 2. Aftermarket Outlook: A. Why to be Concerned B. Why to be Positive 3. Pulse: Supplier KPI Benchmarks 4. Upcoming Study: Longer Terms & Factoring Addressable market – US parc – is enormous and stable Light Vehicles in Use 250 240 Millions 230 220 210 200 190 180 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Source: Polk Gas prices alleviating; a price spike is unlikely given slow global growth Every $0.01 decrease moves $1 Billion into vehicle owners’ pockets (annualized) Weekly U.S. Regular All Formulations Retail Gasoline Prices (Dollars per Gallon) Source: Energy Information Administration Aftermarket is growing robustly compared to other sectors There is no perfect measure, but all indicators are up Source Growth Rate Retail sales - Auto parts, accessories & tire store (US Census) +5.4% (Jan-Aug.) Same-store sales, retailers & distributors (BB&T) +3.2% in Q2 Manufacturer sales (AASA Supplier Barometer) +6.1% in Q3 Sources: US Census Department, BB&T, AASA Barometer Vehicle age – the primary aftermarket driver – continues to increase Average Age of Light Vehicles in Use (Years) 11.0 10.5 10.0 9.5 Next year, we will have the highest number of vehicles out of warranty ever 9.0 8.5 8.0 2002 Source: Polk, Ward’s 2003 2004 2005 2006 2007 2008 2009 2010 The aftermarket sweet spot is shifting and broadening “Age of vehicles that come into our shops used to be 6-10 years … but has widened to 4-12 years” – Rob Gross, Chairman, Monro • Vehicles >10 years old make up 46.6% of the aftermarket and will exceed 50% by 2013 • Weak economy and increasing vehicle durability changing the “repair or replace” equation Source: AASA Status Report, IMR, DesRosiers, Experian The trend is shifting back to DIFM after a DIY spike in the downturn Source: IMR Inc., AASA Status Report There is still pent-up demand for vehicle repair • 2010 tied with the second-highest level ever, reached during the recovery from the last economic downturn • Unemployment and tight household budgets caused many to put off maintenance and repairs unless they were unavoidable Source: AASA Status Report, IMR, Experian Which means our market could and should be much larger Source: AASA Status Report, IMR, Experian Even if a recession comes, 79% of suppliers think the aftermarket will outperform the general economy Do you think the aftermarket will outperform the general economy as it did during the last recession? 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 79% 21% Yes No The automotive aftermarket is much less cyclical than the OE market Note: gray bars = recessions Sources: AASA Status Reports (2003, 2010), Census Bureau, Ward’s, NBER, AASA analysis This counter-cyclical behavior helps the attractiveness of the aftermarket to investors Strong Operating Results Translates to Stock Outperformance 150% 120% 90% 60% 30% 0% -30% -60% S&P 500 AAM Index Suppliers Professional Repair Retailers & Distributors Collision Oct-11 Jul-11 Apr-11 Jan-11 Oct-10 Jul-10 Apr-10 Jan-10 Oct-09 Jul-09 Apr-09 Jan-09 Oct-08 Jul-08 Apr-08 Jan-08 Oct-07 Jul-07 Apr-07 Jan-07 Oct-06 -90% Automotive Aftermarket Suppliers: CTB, DORM, FDML, GT, MPAA, SPM, SNA; Professional Repair: MDS, MNRO, PBY; Retailers & Distributors: AAP, AZO, GPC, KAR, ORLY, PBY, PRTS, UNS; Collision: BYD.UN, CPRT, KAR, LKQX, SLH Source: BB&T Longer term, new U.S. fuel economy regulations are good for the aftermarket New fuel economy standards will reduce the cost per mile driven, incentivizing miles driven and the aftermarket Sources: AASA Status Reports (2003, 2010), Census Bureau, Ward’s, NBER, AASA analysis Global vehicle population growth provides increasing opportunities We’ve passed a billion vehicles globally CAGR 2005-2010 5.7% Source: Polk, Ward’s Outlook is positive: 89% of aftermarket suppliers are predicting growth for their company in 2012 What level of revenue growth are you planning for in your preliminary 2012 budget? 80% 70% 60% 50% 40% 30% 20% 10% 0% 76% 13% Substantial growth 7% Moderate growth No change 4% Moderate decline Conclusion • The sky is not falling in the aftermarket • Aftermarket offers products and services that remain remarkably resilient even in difficult economic times • Though we see shifts in: • Demand drivers • Winners and losers Agenda 1. Recent Publications 2. Aftermarket Outlook: A. Why to be Concerned B. Why to be Positive 3. Pulse: Supplier KPI Benchmarks 4. Upcoming Study: Longer Terms & Factoring AASA Pulse Excerpts: Supplier KPI Benchmarks Returns 2011 AASA Pulse: Supplier KPI Benchmarks 38 Total returns generally declined year-over-year 2011 AASA Pulse: Supplier KPI Benchmarks 39 Share of Total Returns by Category Warranty and Stock/Obsolescence returns make up 87% of total returns 2011 AASA Pulse: Supplier KPI Benchmarks 40 Warranty Returns Warranty returns decreased significantly year-over-year 2011 AASA Pulse: Supplier KPI Benchmarks 41 Stock and Obsolescence Returns However, median stock adjustments increased significantly; customers appear to be watching inventory carefully given the uncertain demand 2011 AASA Pulse: Supplier KPI Benchmarks 42 Fill Rates & Operations 2011 AASA Pulse: Supplier KPI Benchmarks 43 Fill Rate – by Unit Volume Performance decreased year-over-year, especially for low performers; this is perhaps due to the challenges of meeting increased demand However, competitive differentiation is small for most suppliers: median is close to top quartile, and at the industry target of 95% 2011 AASA Pulse: Supplier KPI Benchmarks 44 Order Turnaround Order fill rate improved dramatically year-over-year, especially for the highest performers, as less than 24 hour turnaround become more common 2011 AASA Pulse: Supplier KPI Benchmarks 45 Order Turnaround In 2010, two models appear to predominate: either order turnaround in less than 24 hours (26% of respondents) or 2-3 days (54%) 2011 AASA Pulse: Supplier KPI Benchmarks 46 Financial Metrics 2011 AASA Pulse: Supplier KPI Benchmarks 47 Published Prices Results indicate a significant year-over-year decline in supplier pricing power Decline is shocking considering increases in input prices and demand Note: Responses do not represent actual price changes; just changes in listed prices on published jobber price sheets 2011 AASA Pulse: Supplier KPI Benchmarks 48 Gross Margin GM performance varies widely in the industry: 34% are above 35% GM, while 32% are at worrisome levels of 19% or below 2011 AASA Pulse: Supplier KPI Benchmarks 49 Aftermarket R&D Aftermarket R&D intensity is generally very low, but there are exceptions to this rule 38% spend <1% of sales on R&D, while 7% are at 5% or higher spending 2011 AASA Pulse: Supplier KPI Benchmarks 50 Sales Force 2011 AASA Pulse: Supplier KPI Benchmarks 51 Sales Commissions 1-3% is the most common range of sales commissions for manufacturer reps, but some give much higher commissions (average is 3.3%) 2011 AASA Pulse: Supplier KPI Benchmarks 52 Results Segmented by Company Size 2011 AASA Pulse: Supplier KPI Benchmarks 53 Returns Smaller suppliers appear to keep their return rates lower; this may be a function of the product segments they compete in Metric Total returns Upper Quartile Median Lower Quartile Mean (Avg.) Respondent Revenue Size <=$150M $151-500M >$500M 6.2% 2.9% 1.1% 3.8% 2011 AASA Pulse: Supplier KPI Benchmarks 54 9.6% 4.7% 3.6% 8.1% 5.5% 5.2% 3.8% 4.5% Fill Rates Larger enterprises appear to have an advantage in terms of fill rate Respondent Revenue Size Metric <=$150M $151-500M >$500M Fill rate as a % of unit volume Upper Quartile 97.0% 97.0% 97.0% Median 93.0% 95.0% 97.0% Lower Quartile 85.0% 92.0% 93.0% Mean (Avg.) 90.7% 92.5% 95.2% 2011 AASA Pulse: Supplier KPI Benchmarks 55 Operational & Shipping Metrics There are much higher rates of vendor direct and drop shipments for larger companies; in future, those business models may migrate to smaller players Respondent Revenue Size Metric <=$150M $151-500M >$500M Vendor direct (% of business) Upper Quartile 1.5% 4.0% 15.5% Median 1.5% 3.0% 6.5% Lower Quartile 0.0% 1.0% 3.5% Mean (Avg.) 1.9% 2.8% 11.9% Drop shipments/cross docking (% of business) Upper Quartile 5.5% 10.0% 15.0% Median 0.8% 3.5% 12.5% Lower Quartile 0.0% 3.5% 3.1% Mean (Avg.) 3.0% 6.0% 11.6% 2011 AASA Pulse: Supplier KPI Benchmarks 56 Financial Metrics Pricing power appears to be stronger at the extremes - larger companies and smaller niche players Respondent Revenue Size Metric <=$150M $151-500M >$500M Jobber price sheet (weighted % change) Upper Quartile 4.5% 2.0% 3.5% Median 2.5% 1.5% 3.5% Lower Quartile 1.5% 0.0% 2.8% Mean (Avg.) 2.8% 1.1% 3.9% 2011 AASA Pulse: Supplier KPI Benchmarks 57 Financial Metrics Aftermarket supplier SG&A costs tend to increase as the company size increases Respondent Revenue Size Metric <=$150M $151-500M >$500M SG&A (% of aftermarket sales) Upper Quartile 15.0% 15.0% 15.0% Median 8.0% 10.0% 12.0% Lower Quartile 5.0% 5.0% 10.0% Mean (Avg.) 9.8% 10.9% 11.3% 2011 AASA Pulse: Supplier KPI Benchmarks 58 Financial Metrics Larger companies appear to have significantly lower GM than their smaller competitors Respondent Revenue Size Metric <=$150M $151-500M >$500M Gross margin (weight average, aftermarket) Upper Quartile 37.5% 40.0% 27.5% Median 37.5% 37.5% 23.5% Lower Quartile 20.5% 19.0% 18.3% Mean (Avg.) 29.8% 29.9% 22.5% 2011 AASA Pulse: Supplier KPI Benchmarks 59 Agenda 1. Recent Publications 2. Aftermarket Outlook: A. Why to be Concerned B. Why to be Positive 3. Pulse: Supplier KPI Benchmarks 4. Upcoming Study: Longer Terms & Factoring AASA Pulse: Terms & Conditions 2011 AASA Pulse: Supplier KPI Benchmarks 61 Longest Terms with a Major Customer Terms are being extended due to factoring and high customer bargaining power: avg. longest terms are 165 days and the lower quartile is at 270 days 2011 AASA Pulse: Supplier KPI Benchmarks 62 Days Sales Outstanding DSO went down year-over-year, likely due to increasing use of factoring High DSO at a small set of outliers increased the 2010 mean over 2009 2011 AASA Pulse: Supplier KPI Benchmarks 63 Terms of doing business are unusual in our industry General Retailers Note: Quarter ending 7/31/2011 Sources: AASA MFSG from public filings Aftermarket-only Retailers 64 The example of one AASA member shows the potential exposure of reverse factoring Metric Impact Days Sales Outstanding (DSO) 36 DSO without reverse factoring 275 Sensitivity to a 1% increase in interest 10.5% reduction in expense net income Source: 10Ks, Public filings, market assumptions, analysis. Findings are directionally correct only 65 This is symptomatic of the general lack of manufacturer leverage with customers noted in Aftermarket 2020 Booz Aftermarket 2020 Study: Average Gross Margin 47% 48% 47% 49% 48% Top 3 Retailers (+ ~2% points) 21% 21% 19% 17% 19% Select Manufacturers (– ~2% points) 2005 2006 2007 2008 2009 1) Average of gross margins weighted by company sales; includes global aftermarket segment of Federal Mogul, Standard Motor Products, Tenneco, and Dorman. 2) Includes AutoZone, Advance Auto Parts, and O’Reilly. Average of gross margins weighted by company sales. Source: Company financials; Analyst reports; Booz & Company analysis 66 There are reasons suppliers are doing this • Reverse factoring is seen as a financially attractive way to retain or grow sales – Interest expense is modest at the current time – A low cost of financing versus other facilities • Incentives/threats from customers to accept longer terms/reverse factoring • Expedites cash flow into business Source: 10Ks, Public filings, market assumptions, analysis. Findings are directionally correct only 67 Risks are low as long as money is essentially free … • … the Fed rate can reasonably be expected to rise by 500 to 600 basis points when inflation or economic growth returns; similar impact on LIBOR • Mode (most common value) for Fed funds rate is 5.5% (1990present) • Early in the Reagan administration, the Fed Funds rate exceeded 19% Source: US Federal Reserve; Fed Fund effective rate, monthly data 1990 to 8/2011 68 … But are rising interest rates the Achilles heel for aftermarket suppliers – in the same way an economic downturn was for US automakers? Detroit 3 Automakers Aftermarket Manufacturers Scenario planning matrix, 2006 Scenario planning matrix, 2012 • Economic cycle • Fuel price spike • Interest rate increase? High likelihood, High impact High likelihood, High impact Impact Likelihood Likelihood Impact Result: they weren’t prepared for inevitable risk and went bankrupt Result: ??? Are we prepared for a similar high likelihood/high impact risk? 69 What will study cover? P0tential next steps Value 1) Determine the real costs and risks to the industry • Now • In a rising interest rate environment • 2) Investigate alternatives to factoring • Other ways to address working capital and credit insurance needs • Help broaden supply base alternatives 3) Suggestions welcome • Needs to be member-driven • Open dialogue with customers As per past successful study on pay-on-scan Please contact if you are interested in serving on Advisory Committee 70 Thank you! Paul T. McCarthy Vice President Industry Analysis, Planning & Member Services AASA | Automotive Aftermarket Suppliers Association 10 Laboratory Drive | Research Triangle Park | NC | 27709 Office: 919.406.8812 | Mobile: 248.914.2567 www.aftermarketsuppliers.org Brake Break Be back at 3:30 Legislative Update Ann Wilson Senior VP Government Affairs Motor & Equipment Manufacturers Association Brake Manufacturers Council • • • • • Washington Signed into law March 19, 2010 2014 – no more than trace amounts of asbestos, cadmium, chromium, lead, & mercury January 1, 2013 – industry to provide baseline data on regulated substances 2015 – risk assessment begins 2021 – 5% copper content for brake friction materials Brake Manufacturers Council Washington • On-ramp important • Inventory run-off essential • Tough Issues – OES exemption broader than inventory run-off – Encouraged other states! Brake Manufacturers Council • • • • California Signed into law September 28, 2010 2014 – no more than trace amounts of asbestos, cadmium, chromium, lead, & mercury 2021 – 5% copper content of brake friction materials 2025 – 0.5% copper content of brake friction materials Brake Manufacturers Council California • • • • No fee No specific Green Chemistry But no on-ramp Extensions process outlined for 2025 Washington Better Brakes • Stakeholders meet via conf call bi-weekly – Includes Reps from Industry (MEMA/BMC, SAE, AAIA), Wash DEC and Calif DTSC, Environmental NGOs, Retailers • Issues discussed so far: – – – – – Self-certification Edge code marking Package Labeling/Certification Mark Exemptions/Exclusions SAE Test Methodology Task Force • Timeline Targets – – – – – Oct. 28 -1st Draft Rule Jan/Feb - Public Workshop May 23 – Formal Rule June/July - Mandatory Public Hearings Oct. 17 – Final Rule State of California • DTSC has not yet started their rulemaking process – Partly due to change in Governorship and delays in getting state agency appointments for key CalEPA and DTSC posts – DTSC will continue to work and coordinate with WA DEC. – DTSC will issue guidance. Guidance centers on analytical procedures, certification, and edge codes. Areas of concern exist. • MEMA/BMC have been looking at the state’s screening process and expects to prepare recommendations Self-Certification & Federal Law • U.S. Code definition: “manufacturer” means a person— – (A) manufacturing or assembling motor vehicles or motor vehicle equipment; or – (B) importing motor vehicles or motor vehicle equipment for resale. • National Traffic and Motor Vehicle Safety Act – It is the responsibility of a manufacturer of vehicles and/or items of motor vehicle equipment to self-certify that each motor vehicle and/or equipment item is in full compliance with the minimum performance requirements of all applicable Federal Motor Vehicle Safety Standards (FMVSSs) • U.S. has a self-certification system; not type-approval system 81 How Self-Certification Compliance Works • According to NHTSA Office of Vehicle Safety Compliance: – The manufacturer must not only be concerned with the initial certification, but should also monitor continued compliance of vehicles and/or items of motor vehicle equipment throughout the production run. To accomplish this, an effective quality control program must be established to periodically inspect and test vehicles and/or items of motor vehicle equipment randomly selected from the assembly line to ensure that the original performance is carried through to all other units. • When no FMVSS apply, it is reasonable to measure the product’s design against existing, accepted product standards, such as a set of voluntary industry standards. – Self-certification could include conformity assessment from a 3rd party certification body – International Standards Organization (ISO) is just one example of a 3rd party certification body 82 Self-Certification Program Goals • • Develop an industry-wide, self-certification program that ensures friction material suppliers (domestic and imported) manufacture, sell and distribute within NAFTA only products which comply with applicable California and Washington requirements (as amended). Program will use accredited laboratories (ISO 17025 or NELAC certified) to ensure compliance with applicable state regulations for copper and other constituents contained in brake friction material products, based on: – SAE testing protocol (currently in-process) – Edge Code Markings • • Program will use a third-party registrar to confirm regulatory compliance and provide public access to list of certified companies and products. Develop successful implementation and marketing of the Program to: – OEM vehicle and truck manufacturers, aftermarket spare parts manufacturers – Legislative, regulatory and environmental stakeholders – Integral tool to achieve a NAFTA solution in the absence of federal legislation 83 Self-Certification: Essential Program Elements • • • • • • • • Industry accepted 3rd party registrar to certify program compliance. Importer of Record or other suitable US based entity must obtain certification for imported product. Suitable product testing, edge code markings and product packaging labels utilized to confirm and advertise product compliance with Program. SAE approved testing protocol and accredited laboratories (ISO 17025 or NELAC certified) required. Initial certifications valid for 3 years – then may be renewed for subsequent 3 year periods upon updated testing results. Product and packaging labels shall be marked with required edge code markings which include notation of regulatory compliance and product date code. Product edge code and compliance confirmation will be available on Registrar’s Internet site for stakeholders’ confirmation and review. Consumer focused product marking (i.e. Low Copper Product, Complies with California Copper Requirements, etc.) will be the decision of retail box designer. 84 Thank you! Ann Wilson [email protected] (202) 312-9246 SAE Material Testing Greg Vyletel Sr. Global Technical Expert Meritor Wrap-up • Next BMC Meeting June 1, 2012 Longboat Key, FL (The day before FMSI meeting June 2-3) Save the Date! Thank You!