ACA, AAI Coalition Support Congressional Efforts for TSCA Improvements
ACA joined the American Alliance for Innovation (AAI) letter to members of Congress expressing support for efforts to improve the Toxic Substances Control Act (TSCA). The letter signed by more than 100 organizations lauded Congressional committee work to enhance TSCA to ensure a chemical regulatory program at U.S. EPA is properly resourced, does not impede or create unnecessary barriers to technological innovation while avoiding unreasonable risks of injury, and supports growth in the manufacturing sector.
ACA Comments on Maryland's Proposed Packaging Regulations
ACA submitted comments to the Maryland Department of Environment (MDE) on the agency's proposed Producer Responsibility Packaging and Paper Products Regulations. ACA urged MDE to define ‘de minimis producer’ as an individual that, in the most recent fiscal year, has generated less than a total gross revenue of $5,000,000. ACA also sought clear exemptions under the regulations for all primary, secondary, and tertiary packaging associated with products subject to Maryland’s paint stewardship program.
ACA Supports USMCA Extension in Letter to Senate Leaders
In a letter to leaders of the U.S. Senate Committee on Finance, ACA expressed strong support for the U.S.-Mexico-Canada Agreement (USMCA), as Canada and Mexico are the two largest trading partners for the U.S. coatings industry. ACA urged extension of the agreement for 10 to 16 years and that the United States focus on continued implementation of the USMCA during the Joint Review effort rather than a broad renegotiation of its elements, underscoring that preservation of the USMCA's key tax and tariff provisions are paramount.
ACA Comments on CARB's Proposed Regs for Climate Disclosure
ACA submitted comments to California's Air Resources Board on the agency’s Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation for the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261). ACA underscored in its comments that businesses in the paint and coatings industry should be exempt from the reporting requirements of SB 253 and SB 261, since they are already subject to a plethora of reporting requirements in air quality and toxics regulations in the state.
ACA Submits Comments to California DTSC on Possible Consumer Product Listing for Microplastics
ACA submitted detailed comments to California’s Department of Toxic Substances Control (DTSC) on the agency’s background document identifying consumer products for possible listing as priority products for microplastic pollution under the state’s Safer Consumer Products Program. ACA vigorously opposed the potential listing of water-based interior wall-paint cited in the background document, underscoring that paint particles are not microplastics and studies do not establish a clear correlation between paint and microplastic pollution.
ACA Comments on Washington HB 2271
ACA submitted comments to Washington state’s House Environment & Energy Committee on proposed House Bill 2271, An Act Relating to Postconsumer Recycled Content Requirements for Plastic Products. ACA urged that the bill’s language be amended to clarify that packaging for products subject to the state’s PaintCare program are considered exempted PCRC 2.0 products.
ACA, Coalition Comments on Proposed Changes to TSCA PFAS Reporting
ACA joined a coalition of organizations that submitted comments to U.S. EPA on the proposed revisions to the Toxic Substances Control Act (TSCA) Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). These changes seek to reduce regulatory burdens on businesses and according to EPA estimates, will significantly reduce the economic impact on businesses with cost savings of $786 to $843 million.
ACA Submits Comments to EPA on Proposed PFAS Reporting
ACA submitted detailed comments to U.S. EPA on the agency's proposed revisions to the Toxic Substances Control Act (TSCA) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). In its comments, ACA underscored the substantive compliance costs for industry and urged EPA to revisits its cost estimates, and also recommended other changes to the rule, including modifying the due diligence standard; establishing an additional volume-based threshold; clarifying scope of the exemption for articles with coatings; and restricting the scope of reportable PFAS, among other suggestions.
ACA Letter to California Law Revision Commission
ACA joined a multi-association letter California Law Revision Commission raising concerns with potential efforts by California to establish a legal standard for merger review that impedes, contradicts, or otherwise departs from the standard set by federal law. ACA believes such a move would risk disrupting national commerce, creating unnecessary regulatory burdens, and undermining the efficiency and predictability that businesses rely upon to operate and grow.
ACA Comments to CDPHE on Proposed Regs for Solid Waste Sites
ACA submitted comments to the Colorado Department of Public Health and Environment on revised Proposed Amendments to Section 18 of the Regulations for Solid Waste Sites and Facilities. In its comments, ACA urged that the proposed definition of ‘small business’ be revised. ACA also pressed for the revised proposed amendments to provide that producers may request a hearing to contest any assessed dues.