Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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ACA Comments on New Jersey Assembly Bill 5009

ACA submitted written testimony to the New Jersey Assembly Standing Committee on Environment, Natural Resources, and Solid Wastes, regarding Assembly Bill 5009 – An Act Concerning the Disposal of Packaging Products. ACA urged the legislature to amend the bill to include additional exemptions commonly found in other states’ packaging extended producer responsibility laws. ACA maintains that doing so would promote ease of compliance by industry.

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ACA Comments on Massachusetts House Bill 926

ACA submitted comments to the Massachusetts Joint Committee on Environment and Natural Resources on House Bill 926 – An Act to Save 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.

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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.

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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.

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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.

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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.

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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

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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.

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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.

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