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.
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.
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.
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.
ACA Urges Gov. Pritzker to Veto S.B. 328
ACA urged Gov. J.B. Pritzker to veto Illinois Senate Bill 328, which would change Illinois to a “general jurisdiction” state and subject product manufacturers to unprecedented liability exposure.
ACA Supports Ohio SB 10, Third-party Litigation Funding Reform
ACA sent a letter of support to Ohio State Senators expressing support for Senate Bill 10, which places appropriate guardrails on third-party litigation funding arrangements. ACA supports third party litigation funding reform that ensures transparency and fairness to all parties.
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.
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.
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.
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.