Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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ACA Written Testimony on Rhode Island House Bill 6207

ACA submitted written testimony to the Rhode Island House Environment and Natural Resources Committee on An Act Relating to Health and Safety (HB 6207). ACA recommended that the definition of ‘exempt materials’ in the bill be amended to clarify that packaging for products subject to the state's PaintCare program are not covered materials under HB 6207.

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ACA Written Testimony on Rhode Island House Bill 6205

ACA submitted written testimony to the Rhode Island House Environment and Natural Resources Committee on An Act Relating to Health and Safety – Extended Producer Responsibility for Packaging and Paper Act (HB 6205). ACA recommended that the definition of ‘packaging’ in the bill be amended to clarify that packaging for products subject to the state's PaintCare program are not covered materials under HB 6205.

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ACA Provides Feedback to OMB on Deregulation

ACA responded to the White House Office of Management and Budget's solicitation for comments on potential deregulation for industry. ACA highlights elements of regulatory frameworks that have particularly onerous requirements and present unnecessary challenges for industry. These include certain regulatory provisions under the Toxic Substances Control Act, Emergency Planning and Community Right to Know Act, and Federal Fungicide Insecticide and Rodenticide Act; EPA’s National Volatile Organic Compound Emission Standards for Aerosol Coatings Amendments; EPA’s Universal Waste Rules; Build America, Buy America Act; and EPA's recent amendments to the Risk Management Program.

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ACA Comments on New Jersey Assembly Bill 5009

ACA submitted written testimony to the New Jersey Assembly Standing Committee on Environment, Natural Resources, and Solid Wastes, regarding Assembly Bill 5009 – An Act Concerning the Disposal of Packaging Products. ACA urged the legislature to amend the bill to include additional exemptions commonly found in other states’ packaging extended producer responsibility laws. ACA maintains that doing so would promote ease of compliance by industry.

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ACA Comments on Massachusetts House Bill 926

ACA submitted comments to the Massachusetts Joint Committee on Environment and Natural Resources on House Bill 926 – An Act to Save Recycling Costs in the Commonwealth. ACA recommended that the legislature amend the definition of ‘packaging’ to include additional exemptions commonly found in other states’ packaging Extended Producer Responsibility laws, to provide consistency and promote ease of compliance for industry.

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ACA Comments on Massachusetts Senate Bill 571

ACA submitted comments to the Massachusetts Joint Committee on Environment and Natural Resources on Senate Bill 571 – An Act to Reduce Waste and Recycling Costs in the Commonwealth. ACA recommended that the legislature amend the definition of ‘packaging’ to include additional exemptions commonly found in other states’ packaging Extended Producer Responsibility laws, to provide consistency and promote ease of compliance for industry.

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ACA Testimony on Rhode Island SB 930

ACA submitted written testimony to Rhode Island Senate Environment and Agriculture Committee regarding Senate Bill 939, An Act Relating to Health and Safety – Extended Producer Responsibility for Packaging and Paper Act. ACA urged the Senate to amend the definition of ‘packaging’ to clarify that packaging for products subject to the state's PaintCare post-consumer paint program are not covered materials under SB 939.

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ACA Supports Litigation Transparency Act of 2025

ACA joined a coalition of organizations in a letter to Congress supporting H.R. 1109, the Litigation Transparency Act of 2025. The bill seeks to enhance transparency and oversight of third-party litigation funding (TPLF) by putting in place a uniform disclosure requirement of TPLF in all federal civil litigation. TPLF, an increasingly prevalent multi­ billion-dollar industry, allows hedge funds, sovereign wealth funds, foreign entities and other financiers to secretly invest in lawsuits in exchange for a share of the settlement or award.

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ACA Comments on EPA's Proposed Mitigation Rule for Pigment Violet 29

In its comments submitted to the U.S. Environmental Protection Agency, (EPA) ACA recommended that  EPA revise its underlying risk evaluation of Pigment Violet 29  to more accurately assess risk with an accurate exposure value, if needed, while considering current handling and practices in its exposure evaluation.

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