Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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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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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.

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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.

 

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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.

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ACA, Coalition Seek Extension of Canada's Hazardous Products Regulations (HPR) Amendments Transition Period

ACA and several other organizations sent a letter to Health Canada seeking an extension of the existing transition period for amendments to Canada's Hazardous Products Regulations, which is set to conclude on Dec. 14, 2025. ACA and other associations have asked that the date be extended to align with the United States' implementation timeline of July 19, 2027, for mixtures. 

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ACA Urges TPLF Act Inclusion in Congressional Reconciliation Package

ACA joined a coalition of organizations in a letter to Congress expressing strong support for the Tackling Predatory Litigation Funding (TPLF) Act (S. 1821/H.R. 3512). This legislation would correct the tax treatment of third-party litigation funding. In the coalition letter, ACA and others urged that this legislation be included in the pending Congressional reconciliation package. 

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ACA Supports Tackling Predatory Litigation Funding Act, S. 1821

ACA sent letters to to Congressional leaders expressing support for S. 1821, the Tackling Predatory Litigation Funding Act. This legislation helps to preserve the right of all litigants to control their own destiny and does not allow foreign investors to negatively offset the balance between parties in litigation. Ensuring transparency and appropriate tax treatment in these arrangements is key.

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ACA Comments on New York Senate Bill 1464

ACA submitted comments to the New York Senate Standing Committee on Finance regarding Senate Bill 1464, An Act to Amend the Environmental Conservation Law, in Relation to Enacting the Packaging Reduction and Recycling Infrastructure Act. ACA recommended that the definition of ‘packaging material’ in the bill be amended to clarify that packaging for products subject to PaintCare's postconsumer paint program are not included as packaging material.

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