ACA Comments to CalRecycle on Proposed Regs for SB54
In its comments submitted to the California Department of Resources Recycling and Recovery (CalRecycle) on the agency’s proposed permanent regulations for the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54), ACA made several recommendations to alleviate any undue burden imposed on the paint and coatings industry. Chief among those, ACA urged the agency to revise the proposed definitions for the terms ‘plastic’ and ‘plastic or polymers.’
ACA Supports Nomination of Douglas Troutman for Role at U.S. EPA
ACA joined a number of industry associations in supporting the nomination of Douglas M. Troutman as Assistant Administrator for U.S. EPA's Office of Chemical Safety and Pollution Prevention (OCSPP). In a letter submitted to the Senate Environment and Public Works Committee ahead of his confirmation hearing, ACA and the coalition of trade association noted that Troutman has been an effective advocate for risk-based policies based on the best available science, and a collaborative partner with decades of experience working with stakeholders and policymakers.
ACA Joins Rail Customer Coalition in Letter to the Surface Transportation Board
ACA joined the Rail Customer Coalition in a letter to the Surface Transportation Board, expressing concern about the proposed merger between Union Pacific and Norfolk Southern. The coalition underscored that a transcontinental merger could spark a new wave of consolidation, leaving captive shippers with even fewer Class I rail companies and competitive joint line options from which to choose. Notably, this is in direct contrast to the President’s executive orders aimed at promoting American prosperity, curbing anti-competitive practices, and preventing monopolistic behavior. Rather than fostering economic growth, it would invite supply chain disruptions and make American products less competitive in the global marketplace.
ACA Responds to DOJ Request for Input on Onerous State Laws and Regulations
ACA responded to a Department of Justice (DOJ) solicitation for input on state laws and regulations on industry. ACA highlighted eight state initiatives that unduly burden interstate commerce, raise costs for suppliers and manufacturers, and/or otherwise result in barriers to innovation in the coatings industry. These include varied chemicals management laws; out-of- state business income taxation; extended producer responsibility laws for packaging in California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington; California’s Accidental Release Prevention Program; Volatile Organic Compound regulations for architectural coatings and consumer products; New York’s registration and permitting requirements for anti-fouling paints regulated by EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); and varied state data privacy laws.
ACA Comments Address CARB’s August 2025 Climate Disclosure Workshop
ACA submitted detailed comments to the California Air Resources Board (CARB) regarding its Aug. 21, 2025 Climate Disclosure Workshop addressing regulation development and implementation of the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261). In its comments, ACA recommended several revisions to proposed approaches to alleviate undue burden imposed on the paint and coatings industry.
ACA, Coalition Amicus Letter in Product Liability Case before California Supreme Court
ACA joined a coalition amicus letter petitioning the California Supreme Court to grant cert in a product liability case, Ortiz v. Daimler Trucks North America LLC. In Ortiz, the appellate court opined that a product meeting all legal/regulatory requirements and which works as designed can still be considered defective if the manufacturer opts not to incorporate safety features that are beyond those which are required under applicable law. The appellate court is allowing product defect claims to proceed against Daimler Trucks because the company offered a collision avoidance system as an option on its trucks instead of making that feature mandatory for all customers. Notably, applicable regulations did not require trucks to include that feature at that time.
ACA Comments to TCEQ on Proposal for AIM Coatings
ACA submitted comments to the Texas Commission on Environmental Quality on the agency's proposal to add Architectural and Industrial Maintenance (AIM) coatings to the List of Applicable Surface Coating Processes. ACA's comments raised concerns about the practicality of the approach with regards to applicability, enforcement and compliance for industry.
ACA Comments to SCAQMD on Proposed Amendments to 12 VOC Rules
California's South Coast Air Quality Management District (SCAQMD) will convene a Working Group meeting on Aug. 12 to discuss proposed amendments to 12 separate VOC rules. In its comments, ACA notes that while the district aims to phase out the use of PCBTF and TBAC as quickly as possible through this amendment process, the plan to address all 12 VOC rules at once during the working group meeting is infeasible and will make it impossible for industry to provide accurate feedback.
ACA Supports ROAD to Housing Act of 2025
ACA's letter sent to Congressional leadership expresses strong support for the Renewing Opportunity in the American Dream (ROAD) to Housing Act of 2025. This bipartisan legislation aims to expand and preserve our country’s housing supply, improve housing affordability, and job growth, all of which are important to and backed by the paint and coatings industry.
ACA Comments on California DTSC Rulemaking to Amend Safer Consumer Product Regulations
ACA submitted comments to the California Department of Toxic Substances Control (DTSC) on the agency's proposed amendments to the framework regulations governing its Safer Consumer Products (SCP) program, as authorized by SB 502 (2022). Notably, the 2022-enacted SB 502 allows DTSC to rely on all or part of one or more applicable publicly available studies or evaluations of alternatives in lieu of an Alternatives Analysis to proceed directly to regulatory response. ACA comments raised concerns with DTSC's ability to sufficiently evaluate a potential alternative when limited to consideration of one or a few studies.