Key Takeaways

  • CARB held a public workshop on July 21, 2026, to preview SB 253 regulatory concepts for 2027 and beyond (with no changes to 2026 reporting obligations).
  • CARB’s December 2024 enforcement notice remains the operative guidance for 2026 reporting; companies must report only data already being collected as of the date of that notice, if any, with no assurance required.
  • CARB confirmed that November 10, 2026, is the reporting deadline for greenhouse gas emissions for the prior year; CARB will publish submission guidance by September 1, 2026.
  • For 2027, CARB will require mandatory reporting for the five most commonly reported Scope 3 categories; the remaining 10 will be voluntary.
  • Independent third-party limited assurance of Scope 1 and 2 emissions becomes mandatory beginning with 2027 reports.
  • Insurance companies will be subject to SB 253 starting in 2027; CARB proposes allowing insurers to submit existing CDI/NAIC data supplemented by any additional information needed to satisfy SB 253 requirements.
  • CARB expects to publish a proposed regulation this fall.
  • Six industry-specific virtual listening sessions begin August 5, 2026.
  • CARB did not provide any details on its plans to issue “clarifying” revisions to the initial regulations approved by the Board in February 2026.
  • The U.S. Fish and Wildlife Service and National Marine Fisheries Service issued a final rule rescinding the definition of “harm” from ESA regulations at 50 C.F.R. § 17.3 and 50 C.F.R. § 222.102, eliminating the long-standing regulatory interpretation that habitat modification resulting in death or injury of listed
…

Key Takeaways

  • California’s extended producer responsibility (EPR) law, Senate Bill (SB) 54, is facing a broad constitutional challenge brought by 17 states and the National Association of Wholesaler-Distributors (NAW).
  • The lawsuit targets core features of California’s EPR framework, including source-reduction mandates, recyclability and recycling-rate targets, producer fees, the $500 million annual environmental mitigation surcharge, and mandatory participation in the Circular Action Alliance (CAA).
  • The lawsuit does not change current compliance obligations. Unless and until a court issues injunctive relief, California can enforce SB 54 deadlines, reporting requirements, and producer responsibility organization (PRO) participation obligations.
  • Companies subject to California’s EPR program should continue building systems to report covered material, evaluate packaging reduction opportunities, and document assumptions underlying their producer-status determinations while the lawsuit proceeds.
  • First-of-its-kind program: California’s Responsible Textile Recovery Act of 2024 (SB 707) creates a statewide extended producer responsibility (EPR) framework for apparel and textile articles.
  • July 1, 2026 deadline: “Producers” of “covered products” must register with CalRecycle-approved producer responsible organization (PRO) Landbell USA.
  • August 13, 2026 workshop: CalRecycle will seek
…

California and Maryland ushered in a number of Extended Producer Responsibility (EPR) obligations last week. Although packaging EPR laws in Oregon and Colorado have been operational for some time, recent milestones in California and Maryland will bring their programs into full swing this summer. While not yet fully implemented, Minnesota and Washington’s programs also hit recent milestones.

On April 23, 2026, Maine became the first U.S. state to enact an extended producer responsibility (EPR) law that targets “electronic smoking devices” used to consume nicotine and cannabis. The Act to Create a Stewardship Program for Electronic Smoking Devices and Related Products (LD 1519) applies to every company that qualifies as a “producer” of “electronic smoking devices” sold in Maine. That will likely include all major manufacturers and brand-holders of electronic smoking devices, such as e-cigarettes, vape pens, and refill cartridges.

Last month, the U.S. Environmental Protection Agency (EPA) announced the draft Sixth Contaminant Candidate List (CCL 6) under the Safe Drinking Water Act (SDWA) and released it for public comment. CCL 6 identifies contaminants that are not yet regulated but are known or anticipated to occur in public water systems and may require future regulation. The draft list includes four contaminant groups — microplastics, pharmaceuticals, per‑ and polyfluoroalkyl substances (PFAS), and disinfection byproducts — along with 75 individual chemicals and nine microbes that may be found in drinking water. Although PFAS were included on prior lists, this is the first time the EPA has designated microplastics or pharmaceuticals as priority contaminant groups. Inclusion on the draft CCL 6 signals an emerging concern about these new contaminant groups and the potential for future regulatory action.

The Oregon Department of Environmental Quality (DEQ) issued a list of companies that are allegedly noncompliant “producers” under Oregon’s extended producer responsibility (EPR) law for packaging and paper products, known as the Recycling Modernization Act (RMA). The list appeared on the Circular Action Alliance’s (CAA) website on April 10, 2026. The CAA is the “Producer Responsibility Organization” that is charged with implementing EPR programs in Oregon, Colorado, and California.

A March 30, 2026, decision from the U.S. District Court for the Northern District of California, in Center for Biological Diversity v. U.S. Department of the Interior, vacated key provisions of the Endangered Species Act (ESA) regulations, including several regulations from 2019 that were revised and/or reissued in 2024. This ruling arrives amid a swirl of potential changes to implementation of the ESA, and signals that courts will be closely scrutinizing forthcoming regulations for consistency with a statute that has long been labeled the “pit bull” of environmental statutes.

At a public hearing held February 26, 2026, the California Air Resources Board (CARB) approved a resolution to adopt initial regulations implementing California’s landmark climate reporting and disclosure laws, the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261), which will require private and public companies whose revenues exceed certain thresholds to report greenhouse gas (GHG) emissions and disclose climate-related financial risks, respectively. In its resolution, CARB largely adopted the regulations proposed by staff in December 2025.