Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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ACA Supports Passage of Maine Bill, LD 1214

ACA testified in support of Maine legislation, LD 1214, An Act to Clarify the Laws to Combat Perfluoroalkyl and Polyfluoroalkyl Substances Contamination, before the Joint Standing Committee of Environment and Natural Resources.

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ACA Comments on FTC Revision of Green Guides

ACA submitted detailed comments to the U.S. Federal Trade Commission on the agency's contemplation of updating its Guide for the Use of Environmental Marketing Claims (“Green Guides”), which have remained unchanged since 2012.

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ACA Supports California AB 1526: Aerosol Coatings Management under California’s PaintCare Program

ACA supports California legislation, AB 1526, which makes technical but important changes to California’s architectural paint recovery program, among other unrelated changes in the bill. Specifically, the proposed changes will incorporate spray paint within the definition of architectural paint, as defined, and permit this type of paint to be managed under the scope of California’s existing PaintCare program.

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ACA Seeks Congressional Action on Miscellaneous Tariff Bill

The Miscellaneous Tariff Bill will temporarily eliminate and reduce border taxes on a set of products that have been found through a transparent and rigorous process at the U.S. International Trade Commission to not to be produced at all or in sufficient capacity in the United States. Many raw materials used in paint and coatings formulas are produced solely outside of the United States.

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ACA Urges Senate Action on Miscellaneous Tariff Bill

The Miscellaneous Tariff Bill will temporarily eliminate and reduce border taxes on a set of products that have been found through a transparent and rigorous process at the U.S. International Trade Commission to not to be produced at all or in sufficient capacity in the United States. Many raw materials used in paint and coatings formulas are produced solely outside of the United States.

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ACA Comments to OMB on BABA Guidance for Grants and Agreements

On March 13, ACA submitted comments to the White House Office of Management and Budget on its proposed Guidance for Grants and Agreements supporting the implementation of the Build America, Buy America Act (BABA) provisions of the Infrastructure Investment and Jobs Act. ACA comments focused on paints and coatings as construction materials.

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Opposition to Minnesota HF-1000

On March 3, ACA joined a coalition letter in opposition to Minnesota HF 1000, legislation that would impose broad reporting requirements on manufacturers of all products containing PFAS sold in Minnesota; ban the sale of products containing PFAS in a variety of product categories; and establish a future regulatory scheme to ban additional product categories containing PFAS.

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Opposition to Minnesota SF 834

ACA joined a coalition letter opposing Minnesota legislation, SF 834, which would impose broad reporting requirements on manufacturers of all products containing PFAS sold in Minnesota; ban the sale of products containing PFAS in a variety of product categories; and establish a future regulatory scheme to ban additional product categories containing PFAS.

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Opposition Letter to Congress on FTC's Non-Compete Proposal

On Feb. 28, ACA joined a long list of organizations in a letter to Congress oppose the Federal Trade Commission’s (FTC) proposed rule to impose a nationwide ban on almost all noncompete clauses. The letter seeks Congressional oversight and close examination of the FTC’s proposed rulemaking.

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ACA Comments on Washington Senate Bill 5369

On Feb. 17, ACA submitted written comments to the Washington State Senate Ways and Means Committee, in advance of a hearing on Senate Bill 5369, reassessing standards for polychlorinated biphenyls in consumer products.

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