American Coatings Association submitted formal comments to the California Air Resources Board regarding proposed regulations implementing California’s Climate Corporate Data Accountability Act (SB 253) and Climate-Related Financial Risk Act (SB 261).

In its submission, the association outlined a series of recommendations intended to address potential compliance impacts for paint and coatings manufacturers. Among the requests, ACA urged CARB to exempt paint and coatings businesses from the proposed reporting requirements, citing existing air quality and toxics reporting obligations at the state and local levels.

ACA also called for clarification of key regulatory definitions, including what constitutes “doing business in California,” how parent and subsidiary relationships are determined and whether revenue thresholds should be based on global or California-specific income. The association stated that unclear definitions could create uncertainty for companies with complex corporate structures.

Additional recommendations included excluding Scope 3 greenhouse gas emissions from reporting requirements, revising the proposed fee assessment methodology and extending the initial reporting deadline under SB 253 to December 31, 2026. ACA also requested flexibility allowing companies to use either calendar year or fiscal year data when preparing climate-related financial risk disclosures under SB 261.

A public hearing on the proposed regulations is scheduled for February 26, 2026, with final rules expected later this year following review by the Office of Administrative Law.