Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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ACA Supports USMCA in Feedback to U.S. Trade Representative

In a letter to the U.S. Trade Representative (USTR), ACA expressed strong support for the United States–Mexico–Canada Agreement (USMCA) as it approaches a Joint Review, required under Article 34.7 of the agreement. Canada and Mexico are the U.S. coatings industry's two largest trading partners. The U.S. paint and coatings industry has enjoyed the benefits of a well-developed trade infrastructure, including tariff-free markets as well as new digital trade provisions, a streamlined import-document submission procedure and higher de minimis shipment values. ACA notes that these and other benefits of the USMCA have helped to ease some of the regulatory burdens associated with an integrated North American supply and manufacturing chain. ACA urged the USTR to focus on continued implementation of the USMCA, rather than a broad renegotiation of its elements, noting that preservation of the USMCA's key tax and tariff provisions are paramount in the Joint Review effort.

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Letter to Senate EPW Subcommittee on Chemical Safety, Waste Management, Environmental Justice and Regulatory Oversight

ACA sent a letter to the leadership of the U.S. Senate Committee on Environment and Public Works' Subcommittee on Chemical Safety, Waste Management, Environmental Justice and Regulatory Oversight. The letter, sent in advance of the Subcommittee's hearing on on the "Beneficial Use and Regulation of Chemicals," underscored several challenges arising from implementation of the Lautenberg amendments to TSCA that continue to plague EPA and bottleneck the chemical review process, which in turn, has created significant obstacles to innovation and competitiveness in the paint and coatings industry.

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ACA Raises Concern about Staff Reductions at UNECE Transport Division

In a letter to the U.S. Mission to the United Nations and Other International Organizations in Geneva, ACA expressed concerns about proposed staff reductions at the UN Economic Commission for Europe (UNECE), Transport Division, and specifically the Dangerous Goods Section. ACA underscored the critical work overseen by the commission ensures uninterrupted multi-modal transport of goods that are essential to our daily lives,  supports national and multi-national security need, and establishes a harmonized transport safety baseline supporting fair economic competitive opportunities.

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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.’

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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.

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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.

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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.

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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.

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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. 

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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. 

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