California’s Textile EPR Law: Key 2026 Milestones and Upcoming Producer Deadlines

California continues to expand its extended producer responsibility (EPR) framework to new product categories, capturing an ever-greater number of “producers” responsible to comply across supply chains. In September 2024, Governor Gavin Newsom signed Senate Bill (SB) 707 — the Responsible Textile Recovery Act of 2024 — establishing the first statewide EPR program for apparel and other textile products in the United States. The program is now in the implementation phase, and 2026 marks the first major compliance milestones including the selection of a Producer Responsibility Organization (PRO) and initial producer registration. The law represents another step in California’s broader push toward producer-funded product stewardship programs.

Scope of the Law

SB 707 establishes an EPR program for textile producers administered by the Department of Resources Recycling and Recovery (CalRecycle). Under the program, qualifying producers must join a stewardship organization that coordinates producer compliance with the statute.

The statute requires producers of covered apparel and textile articles — such as clothing, footwear, bedding, and towels — sold in California to finance and organize the collection, repair, reuse, and recycling of those products at end of life, shifting responsibility for post-consumer textile waste from municipalities and taxpayers to producers.

SB 707 also establishes a tiered definition of “producer.” Compliance obligations generally fall first on the brand owner or manufacturer of the product sold in California, followed — if that entity is not present in the state — by the brand licensee, importer, or ultimately the distributor or retailer. Certain entities are exempt, including businesses with less than US$1 million in annual global turnover and sellers that deal exclusively in secondhand goods. This tiered framework is similar to the framework in other EPR programs (e.g., packaging, pharmaceuticals/sharps).

Recent Developments in Program Implementation

Selection of the Producer Responsibility Organization. A central component of the statute is the creation of a producer responsibility organization (PRO) that will administer the statewide stewardship program.

On March 1, 2026, CalRecycle selected Landbell USA as the PRO to implement the program, triggering the next phase of producer compliance obligations. The PRO must develop and implement a stewardship plan addressing the collection, transportation, repair, reuse, sorting, and recycling of covered textile products statewide, with the goal of establishing a “free and convenient” drop-off and collection system for post-consumer apparel and textile products.

Producer Registration Deadline. Producers of covered apparel and textile products sold into California must join the approved PRO and register their brands and covered products by July 1, 2026. Companies that manufacture, import, or sell apparel or textile products into California should consider beginning to prepare for the deadline by:

• Determining whether their products qualify as “covered products”;
• Identifying the entity that qualifies as the “producer” under the statute’s hierarchy;
• Evaluating internal systems for tracking California sales and product data; and
• Monitoring further guidance from CalRecycle and the selected PRO.

What’s Next?

Although the program formally launches in 2026, implementation will continue over several years. Upcoming milestones include:

• March 1, 2027: The PRO must complete a needs assessment and develop a statewide stewardship plan addressing collection infrastructure and recycling capacity.
• July 1, 2028: Deadline for CalRecycle to adopt implementing regulations.
• Within 12 months after regulations take effect: The PRO must submit a stewardship plan to CalRecycle.

Once the stewardship plan is approved — or by July 1, 2030, whichever occurs first — producers will be required to comply with the program and may face enforcement actions and significant penalties for noncompliance.

Given California’s leadership on EPR policy — and similar legislative proposals emerging in other states — companies should also monitor the potential expansion of textile stewardship programs across the United States in the coming years.

For additional upcoming EPR requirements in various states, see Sidley’s blog post here.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.