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US-CA-EPRIn force; SB 54 permanent regulations effective 1 May 2026; PRO program plan under review; federal and state court challenges pending

SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act (2022); paint stewardship AB 1343; mattress stewardship AB 2308; carpet stewardship AB 2398; battery stewardship AB 2440; sharps; textiles SB 707 (2024)

United States (California) · California Department of Resources Recycling and Recovery (CalRecycle), which oversees the packaging, textile, battery, mattress, carpet, paint, and pharmaceutical and sharps stewardship programs

California runs the most extensive set of state EPR laws in the US, anchored by SB 54, which makes producers of single-use packaging and plastic food service ware fund collection, recycling and source reduction through Circular Action Alliance as the state's PRO. CAA filed its program plan in June 2026 and CalRecycle must act on it by 1 January 2027. Separate laws cover paint, mattresses, carpet, batteries, pharmaceuticals and sharps, and textiles (SB 707, with Landbell USA approved as the PRO in March 2026).

Category
Extended Producer Responsibility
Enforcement
Mandatory
Effective date
SB 54 signed 30 June 2022; permanent regulations effective 1 May 2026; Circular Action Alliance submitted the program plan 15 June 2026, with CalRecycle approval and program start due on or before 1 January 2027; first Plastic Pollution Mitigation Fund payment due 1 March 2027; full recyclability and 65% recycling rate by 1 January 2032; textiles (SB 707): producers had to join the PRO by 1 July 2026, PRO needs assessment due March 2027, approved plan required by July 2030 and full implementation in 2031
Covered entities
Producers of single-use packaging and plastic food service ware sold in California; paint, mattress, carpet, battery and battery-embedded product, pharmaceutical and sharps, and textile producers under each product-specific stewardship law
Notes
OAL approved the permanent regulations on 1 May 2026. SB 54 requires the PRO to pay USD 500 million per year to the California Plastic Pollution Mitigation Fund from 2027 to 2037; CAA lists 1 March 2027 for the first payment. Litigation: Oceana, NRDC and Californians Against Waste Foundation filed a petition in San Francisco Superior Court on 2 June 2026 arguing the regulations are too lenient; a 17-state coalition led by Nebraska, joined by the National Association of Wholesaler-Distributors, sued CalRecycle's director and CAA in the US District Court for the Eastern District of California on 22 June 2026 (State of Nebraska v. Heller, No. 2:26-cv-02214) on Commerce Clause, First Amendment and delegation grounds; a preliminary injunction hearing is reported for 15 January 2027. On 20 September 2026 Governor Newsom vetoed SB 1180 (spending rules for the Plastic Pollution Mitigation Fund) and signed SB 501 (Chapter 414, amending the Responsible Battery Recycling Act).

Sources

Related regulations

US-CA-SB253

California SB 253 – Climate Corporate Data Accountability Act

United States (California) · California Air Resources Board (CARB)
Enacted; CARB initial regulation adopted 26 February 2026, withdrawn from OAL review in June 2026 for limited changes, OAL approval pending as of 23 September 2026; not enjoined

California law requiring US-based companies with more than $1 billion in annual revenue that do business in the state to report Scope 1 and 2 emissions each year from 2026 and Scope 3 from 2027, with third-party assurance phased in. CARB adopted an initial regulation covering applicability, fees and the first deadline in February 2026 and is drafting a second rule for 2027 reporting onward. For 2026 only, CARB guidance issued 1 September 2026 lets companies submit existing Scope 1 and 2 data or a statement that data were not collected, and CARB will use enforcement discretion for good-faith first-year filings.

Enforcement
Mandatory
Effective date
First Scope 1 and 2 reports due 10 November 2026 (CARB's proposed deferral from 10 August 2026, pending OAL approval); Scope 3 reporting from 2027; CARB proposes limited assurance of Scope 1 and 2 starting with 2027 reports
Covered entities
US-based business entities with total annual revenue above $1 billion that do business in California. CARB's proposed 15-day changes assess coverage entity by entity and let a parent file consolidated reports and pay fees for covered subsidiaries.
Primary source ↗Verified 2026-09-23
US-CA-SB261

California SB 261 – Climate-Related Financial Risk Act

United States (California) · California Air Resources Board (CARB)
Enacted; enforcement enjoined pending appeal (Ninth Circuit order of 18 November 2025); CARB not enforcing

California law requiring US-based companies with more than $500 million in annual revenue that do business in the state to publish a climate-related financial risk report every two years, following the TCFD framework or an equivalent. The Ninth Circuit enjoined enforcement while the Chamber of Commerce appeal is pending, so CARB has not enforced the 1 January 2026 deadline. Companies may post reports voluntarily to a CARB docket opened 1 December 2025.

Enforcement
Mandatory by statute; enforcement suspended by court injunction
Effective date
Statutory first report due 1 January 2026 and every two years after; CARB is not enforcing that date and will announce an alternate reporting date after the appeal is resolved
Covered entities
US companies doing business in California with revenue >$500m
Primary source ↗Verified 2026-09-23
In force; PPWR has applied since 12 August 2026 and replaced Directive 94/62/EC; ELV Regulation (EU) 2026/1738 in force since 13 August 2026 and applies from 1 September 2028

The EU runs product-specific EPR regimes for packaging, electrical and electronic equipment, batteries, vehicles and single-use plastics, putting collection, recycling and recycled-content obligations on producers placing goods on the single market. The Packaging Regulation has applied directly in all Member States since 12 August 2026, with recyclability, reuse and recycled-content rules phasing in. The new End-of-Life Vehicles Regulation sets vehicle design, recycled-content and EPR rules from 1 September 2028.

Enforcement
Mandatory
Effective date
PPWR entered into force 11 February 2025 and has applied since 12 August 2026 (Article 67(5) from 12 February 2029; other obligations phase in later). Battery Regulation entered into force 17 August 2023 with phased obligations through 2027. ELV Regulation (EU) 2026/1738 entered into force 13 August 2026 and applies from 1 September 2028, when Directive 2000/53/EC is repealed (some Directive provisions continue until 2032). WEEE Directive in force since 2012; SUP Directive transposition deadline 3 July 2021.
Covered entities
Producers, importers and distributors placing packaging, EEE, batteries, vehicles or single-use plastic products on the EU market, regardless of material or origin
Primary source ↗Verified 2026-09-23
In force; year 1 (2025-26) fees invoiced from October 2025; confirmed year 2 (2026-27) fees and notices of liability due later in 2026

The UK runs separate producer responsibility regimes for packaging, electrical equipment, batteries and end-of-life vehicles. Under the 2024 pEPR rules, large packaging producers pay PackUK disposal fees that cover the cost of managing household packaging waste, and from year 2 (2026-27) those fees vary with recyclability. Producers still meet recycling obligations by obtaining packaging recycling notes (PRNs and PERNs).

Enforcement
Mandatory
Effective date
pEPR Regulations made 11 December 2024, in force 1 January 2025; first assessment year 2025-26 (first notices of liability October 2025, based on 2024 packaging data); confirmed year 2 (2026-27) fees due later in 2026; WEEE Regs since 1 January 2014; Battery Regs since 5 May 2009
Covered entities
Packaging producers established in the UK with annual turnover of GBP 1 million or more that supplied or imported more than 25 tonnes of packaging in the previous year. Large producers (turnover above GBP 2 million and more than 50 tonnes) pay household packaging disposal fees and must meet recycling obligations with PRNs or PERNs; small producers have fewer duties. WEEE producers placing EEE on the UK market; battery and ELV producers.
Primary source ↗Verified 2026-09-23
In force; VREG amended 2022 to extend scope to all EEE. VVEA amendments in force 1 August 2026. New Packaging Ordinance (VerpV) adopted 24 June 2026, in force 1 January 2027 with phased duties to 2032.

Switzerland operates advance disposal fee (vRG) schemes for electrical and electronic equipment, batteries, glass bottles and PET, run by industry organizations (SENS, SWICO, Inobat, PET-Recycling Schweiz) under federal ordinances. The Packaging Ordinance adopted in June 2026 replaces the beverage container rules: packaging must be minimized, suitable for recycling and use recycled content where feasible (from 2030); sellers of beverage cartons and single-use plastic packaging above the thresholds must take them back unless they finance an industry scheme (from 2031); and recycling rates of at least 70% for beverage cartons and 55% for single-use plastic packaging apply from 2032, with possible mandatory deposits if missed. Until then, collection of plastic packaging remains largely industry-led and voluntary.

Enforcement
Mandatory
Effective date
VREG in force since 1 July 1998, revised scope effective 1 January 2022; VVEA effective 1 January 2016, amended 1 August 2026; VerpV in force 1 January 2027, with advance disposal fee for glass packaging (Art. 8) from 1 January 2028, general packaging requirements (Art. 3) from 1 January 2030, subsidiary take-back duty for beverage cartons and single-use plastic packaging (Art. 4) from 1 January 2031, and minimum recycling rates (Art. 7) from 1 January 2032; battery and glass advance disposal fees in place since the 1990s
Covered entities
Manufacturers, importers and retailers of electrical and electronic equipment, batteries, glass and PET beverage containers placing products on the Swiss market. Under the VerpV: manufacturers and importers of glass packaging (extended beyond beverage containers from 2028); retailers and manufacturers placing filled beverage cartons or single-use plastic packaging on the market that exceed CHF 1 million turnover and 500 kg of packaging in two consecutive years (take-back duty from 2031 unless met through an industry organization); all retailers and manufacturers supplying filled packaging (design requirements from 2030).
Primary source ↗Verified 2026-09-23
In force; revised packaging EPR rules applied from 1 July 2025; EPR for certain single-use plastic products (Chapter 7A) added in November 2025 and for plastic-containing fishing and aquaculture gear (Chapter 7B) from 1 January 2026. A new packaging regulation implementing the EU PPWR has been proposed to the ministry but is not yet out for consultation.

Norway implements EU-style EPR through Avfallsforskriften, requiring producers of packaging, EEE, batteries and vehicles to join a producer responsibility organization approved by the Environment Agency. Since July 2025 the previous 1,000 kg-per-material exemption for packaging has been abolished, so every importer or producer must register and report. Chapter 7A requires producers of certain single-use plastic products to join an approved scheme and cover municipal cleanup and collection costs from 2027, and Chapter 7B sets EPR for plastic-containing fishing and aquaculture gear.

Enforcement
Mandatory
Effective date
Avfallsforskriften in force since 2004 (latest amendment FOR-2025-12-18-2839, in force 1 January 2026); Chapter 7 packaging EPR revised effective 1 July 2025 (lower registration limit removed); Chapter 7A in force on adoption (FOR-2025-11-12-2278), with the duty to cover municipal costs applying to costs from 1 January 2027 and first payment due 1 October 2028; Chapter 7B in force 1 January 2026, with §§ 7B-4 to 7B-7 applying from 1 March 2027; WEEE provisions since 1999
Covered entities
Any company that professionally imports or manufactures packaging, packaged products, EEE, batteries or vehicles for the Norwegian market; from July 2025 all packaging producers regardless of volume. Also producers that first place certain single-use plastic products on the Norwegian market (food and beverage containers, cups, flexible food packaging, light carrier bags, wet wipes, tobacco filters, balloons) and producers of fishing, recreational fishing and aquaculture gear containing plastic.
Primary source ↗Verified 2026-09-23