2025
Annual Report

September 1, 2024 – August 31, 2025

ACD engaged heavily on trade policy throughout the year, tracking tariffs and trade deals announced by the Trump Administration. To keep members informed, we hosted webinars, issued timely alerts, and maintained a continuously updated tariff webpage. We also met with officials from U.S. Customs and Border Protection (CBP), International Trade Administration (ITA), and U.S. Department of Homeland Security (DHS) to underscore the impact of inconsistent guidance on the industry. In addition, ACD pressed for reinstatement of the Generalized System of Preferences and Miscellaneous Tariff Bill programs and raised alarms over tariff circumvention, providing members with tools to report violations.

Following the new administration, U.S. Environmental Protection Agency (EPA) began reconsidering several regulations finalized under the Biden era. ACD engaged directly with officials to ensure member concerns were heard on two critical fronts:

• Risk Management Program (RMP): ACD opposed the burdensome 2024 changes requiring safer technology alternatives analyses, third-party audits, and extensive public data sharing. We urged the Trump Administration to remove EPA’s public data tool over security risks, a recommendation the agency adopted. The agency has since confirmed plans to limit data availability.
• Toxic Substances Control Act (TSCA): ACD raised concerns with EPA’s 2024 “whole chemical approach,” which assumed no use of protective equipment and overlooked specific conditions of use. We welcomed EPA’s decision to reconsider these provisions and continue pressing for risk evaluations grounded in sound science.

Make America Healthy Again (MAHA)
ACD continues to monitor the MAHA Commission’s developing proposals on food safety, chemical exposure, and pesticide use. The Commission’s draft recommendations call for expanded research into overall chemical exposure and greater reliance on precision technologies in agriculture. We recognize the public concern that fuels these conversations and share the goal of protecting health and safety. At the same time, ACD emphasizes that any resulting policies must be rooted in risk-based analysis and sound science—avoiding broad restrictions that overlook decades of regulatory oversight and proven safe uses.

Heat Illness Standard: At Occupational Safety and Health Administration's (OSHA) hearings on a proposed heat illness standard, ACD’s Warehouse Committee Chair testified, urging the agency to narrow its scope and adopt performance-based requirements. We followed up with written comments in September and continue pressing for a practical rule.

Hazard Communication Standard (HCS): Despite ACD’s warnings about complexity and cost, OSHA finalized most provisions in its 2024 HCS update. New requirements include hazard disclosures that can be “reasonably anticipated” and overlapping compliance deadlines across the supply chain. ACD met with OSHA officials to push for enforcement discretion and led a coalition letter to the Department of Labor, signed by 19 associations, urging relief for affected companies.

ACD remained active on ocean and rail shipping issues in 2025, ensuring member concerns were heard as supply chain disruptions mounted.

• Ocean Shipping: ACD sent multiple letters to the Federal Maritime Commission, raising concerns over surcharges and excessive detention and demurrage fees tied to East Coast labor disputes.
• Rail Service: Through our biannual rail survey, ACD gathered data to share with regulators and legislators, advocating for more reliable and competitive rail service. We met with Surface Transportation Board (STB) officials to press for action on service improvements.
• Rail Merger: Following the announced Union Pacific–Norfolk Southern merger, ACD coordinated with other associations to oppose the deal and spotlight its anti-competitive risks. ACD President and CEO Eric Byer also authored an op-ed on the issue, amplifying the industry’s concerns in the public arena.

As the two-year lapse of the Chemical Facility Anti-Terrorism Standards (CFATS) program continued, ACD led efforts to close this critical security gap. We pressed for reauthorization by securing CFATS amendments in must-pass bills, explored bipartisan alternatives, and kept the issue front and center through Capitol Hill events and extensive media outreach.

ACD’s leadership ensured policymakers and the public remained aware of the risks while keeping member companies’ security priorities at the forefront.