Understanding those issues requires distinguishing proposed changes from existing obligations, and industry concerns from documented business impacts.

Trade, Raw Materials and Export Markets

Although much of the industry’s production takes place domestically, its supply chains and customers extend beyond U.S. borders. According to ACA’s manufacturing and supply-chain priorities, many critical raw materials must be sourced internationally, while Canada and Mexico account for approximately 70% of U.S. coatings exports. The association is seeking continued access to those markets, more flexible rules of origin and tariff exemptions for essential inputs. 

The United States-Mexico-Canada Agreement (USMCA) remains a central part of that discussion. At the July 1 joint review, the United States declined to renew the agreement in its current form. The Office of the U.S. Trade Representative (USTR) said the agreement remained in force while negotiations continued, and that it was seeking to address shortcomings in the agreement and trade deficits with Canada and Mexico. USTR subsequently opened public consultation for the 2027 review, with comments due Jan. 12, 2027. 

Company disclosures provide an important distinction between exposure to trade uncertainty and measurable financial effects. In its third-quarter filing, PPG said tariffs had not caused significant reductions in customer demand, increases in raw-material costs or other significant adverse impacts during the first nine months of 2026. The company separately reported rising raw-material, energy, logistics and packaging costs.

Chemical Reviews and New Technology

For companies developing new chemical substances, the Toxic Substances Control Act (TSCA) review process is a significant policy issue. ACA argues that lengthy and unpredictable reviews delay commercialization and disadvantage U.S. manufacturers. It is seeking more consistent evaluations that reflect substances’ conditions of use. 

EPA describes the program’s purpose as evaluating potential risks before new chemicals enter the U.S. market and establishing safeguards when needed. The agency’s Oct. 1 program statistics listed 427 active cases involving premanufacture notices, significant new use notices and microbial commercial activity notices. Of those, 276 were with EPA and 151 were with submitters. These are programwide figures, not coatings-specific totals, and include cases awaiting information or other action from companies.

The legislative debate involves both review efficiency and the adequacy of safety protections. House Energy and Commerce Committee leaders announced a hearing on proposed TSCA changes in January, saying targeted reforms could improve accountability, support manufacturing and safeguard public health. The Environmental Defense Fund opposed the discussion draft, arguing that it would limit EPA’s ability to assess new chemicals and protect workers and communities from substances already in use. 

PFAS Reporting Across Jurisdictions

Per- and polyfluoroalkyl substances (PFAS) present a separate set of federal and state requirements. At the federal level, EPA is reconsidering portions of its TSCA reporting rule. The agency’s proposed revisions include exemptions for certain low-concentration mixtures, imported articles, research and development chemicals, and other categories. Those proposed exemptions are distinct from the reporting schedule changes already finalized. 

An April 2026 final rule changed the submission period’s start to Jan. 31, 2027, or 60 days after the effective date of a forthcoming substantive revision, whichever comes earlier. The rule retains a six-month submission period for most reporters, with additional time for qualifying small manufacturers reporting exclusively as article importers. These are reporting requirements, not a blanket prohibition on PFAS-containing coatings.

State obligations operate separately. Under Minnesota’s PFAS reporting program, initial reports on intentionally added PFAS in covered products were due Sept. 15, 2026. Manufacturers granted extensions have until Dec. 14. The requirements cover products sold, offered for sale or distributed in Minnesota, including online sales, subject to the program’s exemptions.

Solvent Restrictions and Reformulation

Regional air-quality rules provide another example of policy decisions reaching directly into formulation work. South Coast Air Quality Management District has been amending rules to phase out para-chlorobenzotrifluoride (pCBtF) and tert-butyl acetate (t-BAc) in several applications. Its published regulatory summary lists amended rules covering automotive refinishing, metal parts and products, aerospace, wood coatings, adhesives and sealants, and solvent cleaning.

The district attributes the changes to health-risk assessments by California’s Office of Environmental Health Hazard Assessment. The compounds’ treatment under VOC rules does not eliminate those concerns: a solvent may receive a VOC exemption under a particular rule while still facing restrictions for health reasons. 

Another decision is scheduled shortly after Election Day. The district’s Nov. 6 governing board agenda includes proposed amendments to Rule 1106 for marine and pleasure craft coatings. The proposal includes future prohibitions on pCBtF and t-BAc, lower VOC limits for certain coating categories, and sell-through and use-through provisions. As of Nov. 3, those amendments remain proposals awaiting consideration. 

Research and Manufacturing Investment

Some policy provisions relevant to laboratory and plant investment are already law. The 2025 tax law allows current deductions for qualifying domestic research or experimental expenditures under Section 174A. IRS guidance explains that the provision generally applies to expenditures paid or incurred in tax years beginning after Dec. 31, 2024. 

The law also established permanent 100% additional first-year depreciation for eligible property acquired after Jan. 19, 2025. The Treasury Department and IRS issued guidance in January 2026 addressing eligibility and application of the provision. 

These provisions affect the tax treatment of qualifying research and capital expenditures. They should be distinguished from campaign proposals or prospective legislation. Their availability also does not, by itself, establish how much additional research or manufacturing investment companies will undertake.

Housing and Infrastructure Demand

Policy decisions also affect the markets that purchase coatings. The bipartisan 21st Century ROAD to Housing Act became law July 11, 2026. According to the House Financial Services Committee, the package includes measures aimed at reducing barriers to home construction, modernizing Department of Housing and Urban Development programs and expanding community-bank lending. The next stage is implementation rather than initial passage. 

Recent company reporting helps illustrate this. In its Oct. 27 earnings release, Sherwin-Williams described a challenging demand environment and muted underlying market volumes, even as it reported sales growth across its three segments.

Infrastructure presents a more immediate congressional deadline. Federal surface transportation programs are operating under an extension running from Oct. 1 through Dec. 11, 2026, according to the Federal Highway Administration’s implementation notice. That places transportation authorization and funding on the post-election agenda. 

ACA is seeking long-term transportation funding, changes to permitting processes and consistent domestic-content treatment for coatings under Build America, Buy America requirements. The association argues that differences in how those requirements apply across federal programs create uncertainty for manufacturers supplying infrastructure projects. 

Energy Costs and Operating Conditions

In its October outlook, the U.S. Energy Information Administration forecast average wholesale electricity prices of $52 per megawatt-hour in 2026, up 11% from 2025. The agency attributed much of the increase to weather-related changes in a few regions, while noting substantial regional differences. It also projected commercial and industrial electricity demand growth of close to 3% in 2027. 

Those wholesale figures provide context for a cost category that coatings companies are already identifying in their financial reporting. PPG’s third-quarter filing, for example, cited energy alongside raw materials, logistics and packaging among the costs rising across the coatings value chain. 

The Decisions Ahead

The immediate calendar includes South Coast AQMD’s Nov. 6 consideration of marine coatings amendments, the Dec. 11 surface transportation deadline, Minnesota’s Dec. 14 PFAS reporting deadline for manufacturers with extensions and the Jan. 12, 2027, deadline for USMCA review comments. Each involves a different authority and a different path to implementation. 

The election will influence who sets federal priorities. For coatings companies, the operational effects will depend on the legislation, regulations, funding decisions and implementation that follow, alongside requirements already in force.

Policy status reflects information available Nov. 3, 2026.

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