- 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
Packaging EPR Hits Full Swing: Key Milestones Across California, Maryland, and Beyond
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.
EPR Takes a Drag: Maine Enacts Vape-Specific Stewardship Program
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.
Oregon Calls Out Noncompliant Producers as Packaging EPR Enforcement Era Begins
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.
Court Enjoins Oregon’s Extended Producer Responsibility Law for Some Companies, but Others Face Continued Compliance Obligations
On February 6, 2026, an Oregon district court issued a decision barring the Oregon Department of Environmental Quality (DEQ) from enforcing the nation’s first extended producer responsibility (EPR) law for packaging, food serviceware, and paper products (referred to as “covered products” under Oregon’s law). The very brief order enjoins DEQ from enforcing the state’s Plastic Pollution and Recycling Modernization Act (RMA) against the National Association of Wholesaler-Distributors (NAW) and its members, who filed their suit in July 2025, challenging the law and claiming it violated the Oregon and U.S. Constitutions.
California Proposes Significant Changes to Product Packaging Regulations
What Happened
On Monday, October 14, 2024, the California Department of Resources Recycling and Recovery (CalRecycle) opened a public comment period on changes to the previously proposed regulations implementing the Plastic Pollution Prevention and Packaging Producer Responsibility Act (Act). The 15-day written comment period runs through Tuesday, October 29, 2024.
PFAS Designated as CERCLA Hazardous Substances
On April 19, the U.S. Environmental Protection Agency (EPA) released a pre-publication version of the long-awaited final rule designating two per- and polyfluoroalkyl substances (PFAS) as “hazardous substances” under the Comprehensive Environmental Response, Cleanup, and Liability Act (CERCLA). This final rule comes right on the heels of EPA’s April 8
U.S. EPA Issues FAQ Memo on Lithium-Ion Battery Management Under RCRA
As lithium-based batteries become more prevalent in everything from electric vehicles (EVs) to industrial-scale batteries, as well as e-scooters and personal electronics, more questions arise regarding how to properly manage and dispose or recycle them at the end of their lives. On May 24, the U.S. Environmental Protection Agency (EPA) issued a memorandum titled “Lithium Battery Recycling Regulatory Status and Frequently Asked Questions,” clarifying how the EPA’s current hazardous waste regulations, under the Resource Conservation and Recovery Act (RCRA), apply to lithium batteries, and describing the handling requirements imposed on companies generating the waste batteries and recycling facilities ultimately receiving the waste batteries.
Sanitizing Hand Sanitizer — Managing FDA-Recalled Hand Sanitizer
In 2020, even the hand sanitizer is potentially suspect. Retailers, distributors and corporate purchasers are now grappling with the added problem of clearing their shelves of it and stopping employees from using the Food and Drug Administration (FDA) recalled product.
Earlier this year, to combat the novel coronavirus, the FDA issued temporary guidance to streamline regulatory processes for manufacturing alcohol-based hand sanitizer (typically ethanol or isopropyl alcohol) to get product quickly to market. Many manufacturers (generally foreign manufacturers), however, then distributed toxic or defective product to U.S.-based distributors. As such, the FDA issued a recall for certain hand sanitizer products beginning in June 2020. Over the following months, it has expanded this recall, citing risks that some products pose a risk of poisoning users with methanol and wood alcohol or leaving customers exposed to COVID-19 as a result of either adulteration or ineffective ingredients.. The FDA has advised importers, consignees, distributors, retailers and others not to distribute or sell certain hand sanitizers, even if the manufacturer of the product has not recalled it, due to the dangers of methanol contamination, including death.
“Unauthorized Waste” Reporting Under EPA’s Hazardous Pharmaceutical Waste Rule
The new hazardous waste pharmaceutical management standards established by EPA’s Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine (“Rule”) are already effective in some states. Other states must adopt the rule by July 1, 2021 or, if a statutory amendment is required prior to the state’s adoption, by July 1, 2022. Based on this, all “healthcare facilities”[1] and “reverse distributors,”[2] as defined by the Rule, will ultimately be required to comply with the Rule (as adopted in each state).