ARTICLE
30 April 2025

Compliance Deadline Set For California's Truth In Recycling Law, SB 343

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Perkins Coie LLP

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A significant development has occurred regarding California's SB 343, which imposes strict new requirements on recyclability claims for products and packaging sold in the state.
United States California Corporate/Commercial Law

Key Takeaways

  • The compliance deadline for California SB 343 is October 4, 2026.
  • SB 343 places restrictions on recyclability claims in California.
  • Enhanced recordkeeping is required to substantiate environmental marketing claims.
  • Companies should review and revise their product labeling and packaging, update recordkeeping practices, and monitor future developments to ensure compliance.

A significant development has occurred regarding California's SB 343, which imposes strict new requirements on recyclability claims for products and packaging sold in the state. The California Department of Resources Recycling and Recovery (CalRecycle) published the SB 343 Final Findings Report for the required characterization study of material types and forms that routinely become feedstock used in the production of new products and packaging on April 4, 2025. This publication triggers the compliance timeline for SB 343, meaning that all affected companies must ensure compliance by October 4, 2026.

Compliance Deadline Now Set

The release of the Final Findings Report is a pivotal event under SB 343. Companies now have 18 months from April 4, 2025, to bring their products, packaging, and marketing claims into compliance with the law's stringent requirements. The deadline for compliance is October 4, 2026. It is critical for businesses to begin their compliance efforts immediately to avoid enforcement actions and potential penalties.

Overview of SB 343 Requirements

SB 343 significantly restricts the use of recyclability claims in California. The law prohibits the use of the "chasing arrows" symbol and the placement of resin identification codes within that symbol unless the product or packaging meets strict statewide recyclability criteria. These criteria require that a product or packaging be:

  • Collected in curbside programs serving at least 60% of California's population
  • Sorted into defined streams by at least 60% of the state's recycling programs
  • Routinely used as feedstock in the production of new products or packaging

Any product or packaging that does not meet these criteria cannot display the chasing arrows symbol or make claims directing consumers to recycle the item. Companies must also be prepared to remove such symbols and claims from nonqualifying products.

Expanded Recordkeeping and CalRecycle's Role

SB 343 expands recordkeeping obligations for anyone making environmental marketing claims, including the use of the chasing arrows symbol or recycling statements. CalRecycle's material characterization study provides the public with information necessary to determine whether a product or packaging is considered recyclable under the law. The study will be updated in 2027 and every five years thereafter.

Action Steps for Companies

With the compliance deadline now set for October 4, 2026, we recommend that all companies selling products or packaging in California do the following:

  • Review all product lines and packaging for compliance with SB 343's recyclability criteria.
  • Remove or revise any noncompliant recyclability claims or symbols.
  • Update recordkeeping practices to substantiate environmental marketing claims.
  • Monitor future updates from CalRecycle.

Conclusion

The publication of the final material characterization study marks the start of the countdown to compliance with SB 343. Companies must act now to ensure their products and marketing materials meet California's new standards for recyclability claims. For further guidance or assistance, please contact our team.

For additional information on CalRecycle's study findings and SB 343, please see the following resources:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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