ACA signed onto a letter sent to U.S. International Trade Commission and International Trade Administration leadership regarding the anti-dumping investigations of tin mill products. "As you continue your antidumping duty investigations into tin mill products from eight countries, including key U.S. allies and partners, the undersigned organizations remain concerned that the imposition of new tariffs is not supported by market dynamics, including the reason for subject imports. The imposition of duties without merit would degrade the role of a fair trade remedy process in protecting U.S. manufacturers, while leading to higher consumer costs and the loss of thousands of good American manufacturing jobs in the can and consumer product manufacturing industries.
ACA and the coatings industry believe the existing regulatory framework for the management of used industrial containers works. "However, if the agency determines that action needs to be taken, then ACA encourages EPA to develop non-regulatory guidance to promote compliance with the existing regulations," ACA comments read.
ACA joined some 200 organizations and businesses urging Congress to act this year on critical and long overdue trade legislation to provide U.S. businesses with a robust set of tools to compete with China and other countries around the world. The MTB, which temporarily reduces or eliminate tariffs on products that are not available in the U.S., has been expired since December 2020. Since then, manufacturers and other businesses have paid more than $1.4 billion in anti-competitive tariffs.
On Oct. 31, ACA submitted comments to the Maine Department of Environmental Protection regarding Maine’s Extended Producer Responsibility Program for Packaging. ACA's comments included recommendations that would streamline compliance requirements and offer greater clarity for the coatings industry.
ACA joined several organizations in a letter to Congressional Armed Services Committee leadership urging the removal of Section 333 from the final National Defense Authorization Act for Fiscal Year 2024 conference agreement that would restrict procurement of certain products containing PFAS.
ACA submitted comments to the California Department of Toxic Substances Control (DTSC) regarding the agency’s proposal to add microplastics to its Candidate Chemicals List under the Safer Consumer Products Program.
ACA joined a coalition letter to Congressional leadership, urging withdrawal of S. 2283, from consideration at the Homeland & Government Affairs Committee’s business meeting on July 26. “This legislation, which was just introduced on July 12, 2023, involves serious and complex issues that require more education, deliberation, and engagement among all stakeholders.”
ACA letters to Congressional leadership for the House and Senate on the Committees on Homeland Security and Governmental Affairs urged immediate passage of legislation to reauthorize the Chemical Facility Anti-Terrorism Standards (CFATS) program. The U.S. Department of Homeland Security (DHS) implements the CFATS program under a variety of short-term authorizations by Congress; and authorization for the current CFATS standards will expire after July 27, 2023, if Congress does not reauthorize the program.
ACA sent a letter to U.S. senators on a bipartisan bill addressing PFAS that aims to provide a consistent and practical definition of PFAS compounds for use by federal agencies, state governments, and other entities. ACA supports the exclusion of polymers in the proposed definition as it helps to focus regulatory efforts on compounds based upon their potential for presence in the environment and human exposure.
In its comments, ACA asked EPA to consider several suggestions, including that the agency consider the risk mitigation strategies typically used in industry when conducting a risk evaluation and during risk mitigation.