New York Climate Corporate Data Accountability Act (Senate Bill S9072A, which replaced S3456; Assembly companion A4282A)

New York runs product-by-product EPR through NYSDEC, covering electronics, rechargeable batteries, paint, mercury thermostats, pharmaceuticals and carpet, with each statute setting manufacturer registration, collection and reporting duties. The Packaging Reduction and Recycling Infrastructure Act did not pass in 2026: the Senate amended the bill in April but did not vote on it, and the Assembly Speaker did not bring it to the floor.

Enforcement

Mandatory

Effective date

Electronic Equipment Recycling and Reuse Act effective 28 May 2010 with collection from 1 April 2011; Rechargeable Battery Recycling Act signed 10 December 2010; Postconsumer Paint Collection Act effective 9 May 2022; Drug Take Back Act effective 2019; carpet EPR: under DEC enforcement discretion (19 December 2025, clarified 22 January 2026) plans are due 31 December 2026 and programs and the retailer sales restriction start 1 July 2027, while the ban on PFAS in carpet applies from 31 December 2026

Covered entities

Manufacturers of covered electronic equipment, rechargeable batteries, architectural paint, mercury thermostats and prescription drugs sold in New York; carpet producers (including carpet cushion and artificial turf) under the carpet EPR law

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.