ACA Comments on Massachusetts Senate Bill 571
ACA submitted comments to the Massachusetts Joint Committee on Environment and Natural Resources on Senate Bill 571 – An Act to Reduce Waste and Recycling Costs in the Commonwealth. ACA recommended that the legislature amend the definition of ‘packaging’ to include additional exemptions commonly found in other states’ packaging Extended Producer Responsibility laws, to provide consistency and promote ease of compliance for industry.
ACA Comments on Illinois Universal Waste Regulations for Paint
ACA submitted comments to letter to the Illinois Pollution Control Board regarding the state's proposed universal waste management regulations for paint and paint-related wastes. ACA's comments focused on ACA's forthcoming PaintCare program in the state.
ACA Testimony on Rhode Island SB 930
ACA submitted written testimony to Rhode Island Senate Environment and Agriculture Committee regarding Senate Bill 939, An Act Relating to Health and Safety – Extended Producer Responsibility for Packaging and Paper Act. ACA urged the Senate to amend the definition of ‘packaging’ to clarify that packaging for products subject to the state's PaintCare post-consumer paint program are not covered materials under SB 939.
ACA Supports Litigation Transparency Act of 2025
ACA joined a coalition of organizations in a letter to Congress supporting H.R. 1109, the Litigation Transparency Act of 2025. The bill seeks to enhance transparency and oversight of third-party litigation funding (TPLF) by putting in place a uniform disclosure requirement of TPLF in all federal civil litigation. TPLF, an increasingly prevalent multi billion-dollar industry, allows hedge funds, sovereign wealth funds, foreign entities and other financiers to secretly invest in lawsuits in exchange for a share of the settlement or award.
ACA Comments on EPA's Proposed Mitigation Rule for Pigment Violet 29
In its comments submitted to the U.S. Environmental Protection Agency, (EPA) ACA recommended that EPA revise its underlying risk evaluation of Pigment Violet 29 to more accurately assess risk with an accurate exposure value, if needed, while considering current handling and practices in its exposure evaluation.
ACA Comments on the Draft Scope of the Risk Evaluation for Vinyl Chloride
In comments submitted to U.S. EPA on the agency’s draft scope for the risk evaluation of vinyl chloride, ACA encouraged EPA to evaluate risks while considering current industry practices in safeguarding its workforce. ACA underscored that vinyl chloride is used to make polyvinyl chloride (PVC) resins and other vinyl acrylic polymers, containing residual amounts of the vinyl chloride monomer, which is then subsequently used in many paints, coatings, adhesives and sealants, resulting in the final end-use formulated products having only trace amounts of vinyl chloride, if at all
ACA Comments on New York Assembly Bill regarding Packaging EPR
ACA submitted comments to the New York Assembly Standing Committee on Codes regarding legislation, Assembly Bill 01749, 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 Assembly to amend the definition of ‘packaging materials’ to clarify that packaging for products subject to the state's PaintCare program are not covered products under A01749.
ACA Comments on EPA’s Interim Framework for Advancing Consideration of Cumulative Impacts
U.S. EPA's framework provides considerations designed to guide EPA decision-making addressing disproportionate impacts on communities, including tribal communities, low-income communities and rural communities. The framework emphasizes consideration of the impacts of pollution, socioeconomic disadvantage, lack of greenspace and other environmental benefits, and health susceptibility and vulnerability that tend to be clustered spatially in recurrent, persistent, and systematic patterns.
ACA Comments to EPA on Clarification of Toxic Chemicals from Automatic Additions of PFAS under NDAA
In January 2025, EPA published a proposed rule to amend the definition of “toxic chemical” at 40 CFR 372.3 so that any chemical listed pursuant to EPA’s authority under the National Defense Authorization Act FY 2020 would be a toxic chemical under the regulation. As a result, companies placing such chemicals on the market, including in mixtures, would be required to notify buyers. In recent comments submitted to EPA, ACA urged the agency not include PFAS chemicals as chemicals of special concern, pending further analysis of the listing criteria in EPCRA § 313(d)(2) for each chemical.
ACA Submits Testimony on Maryland Senate Bill 90, Packaging EPR
ACA submitted testimony to the Maryland Senate Education, Energy, and the Environment Committee regarding the proposed exemptions for the term ‘packaging materials’ in Senate Bill 901, An Act concerning Environment – Packaging Materials – Producer Responsibility Plans. ACA recommended that the definition of ‘packaging materials’ in SB 901 be amended to clarify that products managed under PaintCare are not covered products.