³Ô¹ÏºÚÁÏÍø

Letters & Comments

Read ³Ô¹ÏºÚÁÏÍø’s letters and comments submitted to regulatory bodies and elected officials.
Click ‘Read More,’ to open the PDF, with the option for download.

³Ô¹ÏºÚÁÏÍø Submits Comments to New York Senate Finance Committee

³Ô¹ÏºÚÁÏÍø 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, ³Ô¹ÏºÚÁÏÍø 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.

Read More…

³Ô¹ÏºÚÁÏÍø Supports Amended 21st Century ROAD to Housing Act

³Ô¹ÏºÚÁÏÍø strongly supports the comprehensive housing legislative package currently under consideration by Congress. In a letter to Congressional leaders, ³Ô¹ÏºÚÁÏÍø 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.

Read More…

³Ô¹ÏºÚÁÏÍø Joins Coalition Comments on EPA’s RMP Proposal

³Ô¹ÏºÚÁÏÍø 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.

Read More…

³Ô¹ÏºÚÁÏÍø Comments on New York Senate Bill 1464A

³Ô¹ÏºÚÁÏÍø submitted comments to the New York Senate's Environmental Conservation 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, ³Ô¹ÏºÚÁÏÍø 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.

Read More…

³Ô¹ÏºÚÁÏÍø, AAI Coalition Support Congressional Efforts for TSCA Improvements

³Ô¹ÏºÚÁÏÍø joined the American Alliance for Innovation (AAI) letter to members of Congress expressing support for efforts to improve the Toxic Substances Control Act (TSCA). The letter signed by more than 100 organizations lauded Congressional committee work to enhance TSCA to ensure a chemical regulatory program at U.S. EPA is properly resourced, does not impede or create unnecessary barriers to technological innovation while avoiding unreasonable risks of injury, and supports growth in the manufacturing sector.

Read More…

³Ô¹ÏºÚÁÏÍø Comments on Maryland's Proposed Packaging Regulations

³Ô¹ÏºÚÁÏÍø submitted comments to the Maryland Department of Environment (MDE) on the agency's proposed Producer Responsibility Packaging and Paper Products Regulations. ³Ô¹ÏºÚÁÏÍø urged MDE to define ‘de minimis producer’ as an individual that, in the most recent fiscal year, has generated less than a total gross revenue of $5,000,000. ³Ô¹ÏºÚÁÏÍø also sought clear exemptions under the regulations for all primary, secondary, and tertiary packaging associated with products subject to Maryland’s paint stewardship program.

Read More…

³Ô¹ÏºÚÁÏÍø Supports USMCA Extension in Letter to Senate Leaders

In a letter to leaders of the U.S. Senate Committee on Finance, ³Ô¹ÏºÚÁÏÍø expressed strong support for the U.S.-Mexico-Canada Agreement (USMCA), as Canada and Mexico are the two largest trading partners for the U.S. coatings industry. ³Ô¹ÏºÚÁÏÍø urged extension of the agreement for 10 to 16 years and that the United States focus on continued implementation of the USMCA during the Joint Review effort rather than a broad renegotiation of its elements, underscoring that preservation of the USMCA's key tax and tariff provisions are paramount.

Read More…

³Ô¹ÏºÚÁÏÍø Comments on CARB's Proposed Regs for Climate Disclosure

³Ô¹ÏºÚÁÏÍø submitted comments to California's Air Resources Board on the agency’s 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). ³Ô¹ÏºÚÁÏÍø underscored in its comments that businesses in the paint and coatings industry should be exempt from the reporting requirements of SB 253 and SB 261, since they are already subject to a plethora of reporting requirements in air quality and toxics regulations in the state.

Read More…

³Ô¹ÏºÚÁÏÍø Submits Comments to California DTSC on Possible Consumer Product Listing for Microplastics

³Ô¹ÏºÚÁÏÍø submitted detailed comments to California’s Department of Toxic Substances Control (DTSC) on the agency’s background document identifying consumer products for possible listing as priority products for microplastic pollution under the state’s Safer Consumer Products Program. ³Ô¹ÏºÚÁÏÍø vigorously opposed the potential listing of water-based interior wall-paint cited in the background document, underscoring that paint particles are not microplastics and studies do not establish a clear correlation between paint and microplastic pollution.

Read More…

³Ô¹ÏºÚÁÏÍø Comments on Washington HB 2271

³Ô¹ÏºÚÁÏÍø submitted comments to Washington state’s House Environment & Energy Committee on proposed House Bill 2271, An Act Relating to Postconsumer Recycled Content Requirements for Plastic Products. ³Ô¹ÏºÚÁÏÍø urged that the bill’s language be amended to clarify that packaging for products subject to the state’s PaintCare program  are considered exempted PCRC 2.0 products.

Read More…