ACA, Coalition on EPA Implementation Approach to PFAS Reporting Requirements
ACA and a coalition of trade associations urged the U.S. EPA to finalize revisions to the agency’s PFAS reporting requirements under the Toxic Substances Control Act (TSCA) that improve the effectiveness, implement ability, and practicality of the reporting program. This includes, but is not limited to: appropriate alignment with longstanding TSCA reporting concepts and retain the proposed exemptions for PFAS manufactured (including imported) in mixtures or products at concentrations 0.1% or lower; imported articles; certain byproducts; impurities; research and development chemicals; and non-isolated intermediates in the final rule.
ACA Supports American Affordability and Jobs Act of 2026
In a letter to Senate leadership on the Environment and Public Works and Energy and Natural Resources Committee, ACA urged swift passage of bipartisan permitting reform legislation. ACA supports the American Affordability and Jobs Act of 2026, which would enable faster, more predictable permitting for planned investment in commercial and industrial construction, and would have a beneficial economic effect in terms of job creation and expanding the nation's production capacity.
ACA Comments to NMDE on Fluoropolymers Exemption
ACA submitted comments to New Mexico’s Department of Environment on its report to the legislature considering exemptions to the NM PFAS Protection Act. This issue remains relevant since the district court's injunction only relates to the labeling requirement under the rules. In its comments ACA underscored the lack of environment and safety risk coupled with the need for fluoropolymers in specialty coatings indicate that the state would benefit from maintaining the act’s current exemptions for fluoropolymers, while also exempting fluoropolymers from the labeling requirement implemented in the rule. Considering safety with environmental and other benefits, labeling these products as “PFAS” is fundamentally misleading.
ACA Submits Comments on Washington State Recycling Reform Rulemaking
ACA submitted comments to the Washington State Department of Ecology on the agency’s proposed new regulations under the state's Recycling Reform Act. This law creates an extended producer responsibility (EPR) program for materials used to package consumer goods and paper products. In its comments, ACA urged the department to clarify that the definition for ‘exempt materials’ under the proposed regulations refers to packaging associated with products subject to the state’s PaintCare program.
ACA Submits Comments to CARB on Proposed Climate Regulations
ACA submitted comments to the California Air Resources Board (CARB) on the agency’s Modified Text – 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 stressed that businesses within the paint and coatings industry should be exempt from the reporting requirements of SB 253 and SB 261. ACA also underscored that the proposed regulation's definition for the term ‘doing business in California’ should clearly indicate that it refers to either the sales of a parent company or a subsidiary company.
ACA Submits Comments to the Minnesota Pollution Control Agency
ACA submitted comments to the Minnesota Pollution Control Agency (MPCA) regarding the agency’s development of new rules governing implementation of the Packaging Waste and Cost Reduction Act (PWCRA). In its comments, ACA urged the agency to clarify that the definition under § 115A.1441(16)(12) of the PWCRA refers to packaging for products subject to the state’s PaintCare program.
ACA Comments on Washington State Recycling Reform Rulemaking
ACA submitted comments to the Washington State Department of Ecology regarding the agency’s proposal to adopt new regulations related to recycling. In its comments, ACA recommended that section 173-950-030 of the Proposed Regulations be revised to provide that the term ‘covered material’ does not include any secondary and tertiary packaging associated with products subject to Washington’s paint stewardship program. This modification would reduce additional burdens for manufacturers’ compliance efforts with Washington's Recycling Reform Act and other states’ existing packaging and paint stewardship programs.
ACA Submits Comments to New York Senate Finance Committee
ACA submitted comments to the New York Senate Finance Committee on Senate Bill 1464A, An Act to Amend the Environmental Conservation Law, in Relation to Enacting the Packaging Reduction and Recycling Infrastructure Act. In its comments, ACA urged the committee to amend the definition of ‘packaging material,’ ‘packaging,’ or ‘covered material,’ to clarify that packaging for products subject to a post-consumer paint program under N.Y. Env’t Conserv. Law § 27-20 are not included under S1464A.
ACA Supports Amended 21st Century ROAD to Housing Act
ACA strongly supports the comprehensive housing legislative package currently under consideration by Congress. In a letter to Congressional leaders, ACA underscored the need for expanding and preserving the country’s housing supply, improving housing affordability, and driving job growth, and urged Congress pass the amended 21st Century ROAD to Housing Act.
ACA Joins Coalition Comments on EPA’s RMP Proposal
ACA joined a coalition of organizations in comments submitted to the U.S. Environmental Protection Agency (EPA) on its proposal related to the Risk Management Programs (RMP). The comments, which address the agency’s accidental release prevention requirements under the RMP, underscore that any final rule stemming from EPA’s proposal should be fully consistent with statutory authority; supported by the administrative record; and structured to preserve the effectiveness of the performance-based RMP framework.