California SB 54: Regulations submitted to OAL — reporting deadline imminent

This is the most time-sensitive development of the month for any producer selling covered packaging in California.

On March 19, 2026, CalRecycle submitted the revised SB 54 regulations to the Office of Administrative Law (OAL) for review. OAL has until May 1, 2026 to approve or disapprove. CalRecycle has requested an early effective date, meaning the regulations could take effect the same day they are approved. Once that happens, producers will have 30 days to submit their 2023 baseline supply data to CAA, putting the likely reporting deadline around May 31 to June 1, 2026.

Separately, CAA confirmed it remains on track to submit its California Program Plan to the SB 54 Advisory Board by June 15, 2026, followed by a 60-day public comment period. CAA has also signaled that early fee invoices may be issued as soon as August 2026, with 2025 data informing both early and full program fees starting 2027.

If you missed it: CalRecycle published nine technical needs assessment reports covering Source Reduction, Collection Processing and End Markets, and Consumer Education. These reports are designed to inform CAA's program plan and budget — and producers with input should share feedback through the Advisory Board process before the May 21, 2026 review deadline.

What to do now: Confirm your 2023 baseline data is ready for submission (if you haven't submitted to CAA yet). Review CalRecycle's Covered Material Categories list to verify which of your SKUs are in scope. The reporting window will open quickly once regulations are approved.

California SB 343: "Truth in Recycling" faces lawsuit

On March 17, 2026, a coalition of 18 industry trade associations filed a federal lawsuit challenging the constitutionality of California's SB 343, the so-called "Truth in Recycling" law. Plaintiffs, representing food producers, packaging manufacturers, restaurants, and grocers, argue the law violates both First and Fourteenth Amendment rights by restricting truthful recyclability claims and applying vague, difficult-to-interpret criteria that expose businesses to civil and criminal penalties.

At the heart of the case is SB 343's ban on the familiar "chasing arrows" recycling symbol unless a product meets California's strict 60/60 threshold, meaning the packaging must be collected by programs serving at least 60% of the state's population and sorted by at least 60% of recycling facilities statewide. Plaintiffs argue many materials that are genuinely recyclable fail to meet these thresholds due to infrastructure gaps, not because they cannot be recycled.

The law's compliance deadline of October 4, 2026 has not moved. The lawsuit does not suspend enforcement, and companies outside the plaintiff coalition cannot rely on any injunction obtained by those groups. All producers selling into California should continue preparing for compliance, including auditing recyclability claims, reviewing on-pack symbols, and evaluating supplier agreements.

What to watch: The court is likely to make a decision soon given the October deadline. A preliminary injunction ruling, if granted, would be the next major signal, but compliance planning should continue in parallel.

Colorado: EPR faces legal challenges

While California dominated the headlines, another legal challenge emerged in Colorado. On March 12, 2026, the Independent Lubricant Manufacturers Association (ILMA) filed a lawsuit in Colorado state court challenging the structural implementation of the state's packaging EPR law (HB 22-1355). The core arguments: the state has improperly delegated regulatory authority to private organizations (CAA and LPMA), fees are not transparently tied to actual recycling costs, and mandatory PRO participation creates an unlawful barrier to market entry, particularly for smaller producers operating on thin margins.

It is worth noting that legal challenges at this stage of EPR implementation are not entirely surprising. As programs move from planning into active enforcement, friction from specific industry segments tends to surface. This lawsuit is primarily focused on lubricant manufacturers, and a similar challenge in Oregon, while resulting in a limited preliminary injunction for certain producers, has not fundamentally disrupted that state's program.

Whether this litigation produces meaningful structural changes remains to be seen. For most consumer brands, the more immediate risk is simply the uncertainty it introduces into an already complex multi-state compliance landscape.

What this means for producers: Compliance obligations in Colorado have not changed, and producers should continue meeting registration, data reporting, and fee deadlines. Monitor developments, but treat this as a signal to stay informed rather than a reason to revisit your compliance posture.

Washington: Formal rulemaking begins for Recycling Reform Act

Washington's Department of Ecology launched formal rulemaking for the Recycling Reform Act (SB 5284) on March 19, 2026, beginning development of Chapter 173-950 WAC. The rulemaking will clarify PRO reimbursement structures, program plan submission timelines, and enforcement mechanisms. Stakeholder meetings are expected to run through late 2027 before a formal rule proposal is issued.

CAA was officially registered as Washington's PRO earlier in the month, on March 4, 2026. For producers, this signals the start of the implementation phase: companies with covered packaging sold in Washington should prepare for PRO registration and future fee obligations. Reporting deadlines for Washington are expected to align with CAA's May 31, 2026 multi-state harmonized deadline.

Also worth noting…

• Oregon SB 582: Public comment on CAA's second draft proposal closed March 27. Separately, Oregon DEQ issued a conditional approval of CAA's 2023–2024 startup financial report, directing CAA to provide more detailed cost breakdowns and disclose its methodology for allocating national expenses to Oregon, signaling increased scrutiny of PRO financial transparency going forward.

• Maine LD 1541: Maine DEP is preparing to issue an RFP for its Stewardship Organization. Producer registration has not yet opened, but detailed guidance on packaging classification, registration, and reporting methods is expected in summer 2026.

• Colorado HB 22-1355 (CPI adjustment): Colorado is proposing a rule to adjust the revenue-based exemption threshold using a Consumer Price Index update. Producers near the exemption boundary should monitor this closely. A CPI adjustment could pull previously exempt companies into scope. A virtual stakeholder meeting on the proposed rule is scheduled for April 6, 2026.

• Tennessee SB 269/HB 600 (Waste to Jobs Act): The bill faced a significant setback in March, with trade press reporting it was effectively sidelined in committee. Senator Campbell has signaled the coalition will return with a stronger push next session.

Staying ahead

March alone brought regulatory submissions, lawsuits, new rulemaking launches, and fast-approaching reporting deadlines across multiple states. For teams managing multi-state packaging portfolios, keeping pace manually is increasingly difficult.

At Neta AI, we track changes like these in real time, across state statutes, agency rulemaking portals, PRO announcements, and local ordinances. We surface the ones that are directly relevant to your packaging footprint and SKU portfolio. Instead of piecing together updates from disparate sources, your team receives targeted alerts with clear context on what changed, what it means for your products, and what actions to take.

If you want to see how Neta AI can streamline your compliance monitoring, reach out. We'd love to walk you through it.