ԹϺ

Letters & Comments

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

ԹϺ, Coalition Seek Extension of Canada's Hazardous Products Regulations (HPR) Amendments Transition Period

ԹϺ and several other organizations sent a letter to Health Canada seeking an extension of the existing transition period for amendments to Canada's Hazardous Products Regulations, which is set to conclude on Dec. 14, 2025. ԹϺ and other associations have asked that the date be extended to align with the United States' implementation timeline of July 19, 2027, for mixtures.

Read More…

ԹϺ Urges TPLF Act Inclusion in Congressional Reconciliation Package

ԹϺ joined a coalition of organizations in a letter to Congress expressing strong support for the Tackling Predatory Litigation Funding (TPLF) Act (S. 1821/H.R. 3512). This legislation would correct the tax treatment of third-party litigation funding. In the coalition letter, ԹϺ and others urged that this legislation be included in the pending Congressional reconciliation package.

Read More…

ԹϺ Supports Tackling Predatory Litigation Funding Act, S. 1821

ԹϺ sent letters to to Congressional leaders expressing support for S. 1821, the Tackling Predatory Litigation Funding Act. This legislation helps to preserve the right of all litigants to control their own destiny and does not allow foreign investors to negatively offset the balance between parties in litigation. Ensuring transparency and appropriate tax treatment in these arrangements is key.

Read More…

ԹϺ Comments on New York Senate Bill 1464

ԹϺ submitted comments to the New York Senate Standing Committee on Finance regarding Senate Bill 1464, An Act to Amend the Environmental Conservation Law, in Relation to Enacting the Packaging Reduction and Recycling Infrastructure Act. ԹϺ recommended that the definition of ‘packaging material’ in the bill be amended to clarify that packaging for products subject to PaintCare's postconsumer paint program are not included as packaging material.

Read More…

ԹϺ Written Testimony on Rhode Island House Bill 6207

ԹϺ submitted written testimony to the Rhode Island House Environment and Natural Resources Committee on An Act Relating to Health and Safety (HB 6207). ԹϺ recommended that the definition of ‘exempt materials’ in the bill be amended to clarify that packaging for products subject to the state's PaintCare program are not covered materials under HB 6207.

Read More…

ԹϺ Written Testimony on Rhode Island House Bill 6205

ԹϺ submitted written testimony to the Rhode Island House Environment and Natural Resources Committee on An Act Relating to Health and Safety – Extended Producer Responsibility for Packaging and Paper Act (HB 6205). ԹϺ recommended that the definition of ‘packaging’ in the bill be amended to clarify that packaging for products subject to the state's PaintCare program are not covered materials under HB 6205.

Read More…

ԹϺ Provides Feedback to OMB on Deregulation

ԹϺ responded to the White House Office of Management and Budget's solicitation for comments on potential deregulation for industry. ԹϺ highlights elements of regulatory frameworks that have particularly onerous requirements and present unnecessary challenges for industry. These include certain regulatory provisions under the Toxic Substances Control Act, Emergency Planning and Community Right to Know Act, and Federal Fungicide Insecticide and Rodenticide Act; EPA’s National Volatile Organic Compound Emission Standards for Aerosol Coatings Amendments; EPA’s Universal Waste Rules; Build America, Buy America Act; and EPA's recent amendments to the Risk Management Program.

Read More…

ԹϺ Comments on New Jersey Assembly Bill 5009

ԹϺ 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. ԹϺ urged the legislature to amend the bill to include additional exemptions commonly found in other states’ packaging extended producer responsibility laws. ԹϺ maintains that doing so would promote ease of compliance by industry.

Read More…