SB 253 Update: CARB Still Wrestling With Draft Regulations in March 2026
Companies preparing to comply with California’s SB 253 and submit their first required disclosures in August 2026 received additional guidance this week from the California Air Resources Board (CARB). At a public workshop on March 23, CARB outlined proposed approaches under its developing rulemaking, including options for phasing in compliance over time, and solicited public feedback on those concepts. The following article summarizes the key developments from that workshop.
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.
Walk Like a CSHO: Cal/OSHA Proposes Its Own “Walkaround Rule”
On February 13, 2026, Cal/OSHA published a notice of proposed rulemaking (NPRM) to clarify who can join its onsite inspections. To be codified as Title 8 § 331.8 if implemented, Cal/OSHA’s stated goal is to match federal OSHA’s 2024 updates to 29 C.F.R. § 1903.8 and expand upon California Labor Code section 6314, which already states that “a representative authorized by . . . employees” can accompany Cal/OSHA inspectors during their “tour” of the worksite. In its new proposal, Cal/OSHA explicitly expands the definition of “representative(s) authorized by employees” to include an “employee of the employer, a third party, or the collective bargaining representative.”
California Environmental Law Update: Key Legislative and Regulatory Updates To Track in 2026
California enacted a wide-ranging slate of environmental and climate legislation in 2025 and in prior years, with many of the resulting requirements taking effect in 2026 that will impact companies operating in or doing business with the state. These developments span climate disclosure and financial reporting, greenhouse gas regulation, energy and fuel markets, California Environmental Quality Act (CEQA) reform, and public health and safety standards. The below roundup highlights a collection of key new statutes and regulatory changes that the industry should be tracking now to assess compliance obligations and strategic planning considerations heading into 2026 and future years.
New Year, New Packaging Requirements: Extended Producer Responsibility Update
State extended producer responsibility (EPR) programs for packaging materials are no longer on the horizon — as we enter 2026, requirements in some states have already taken effect and more will be implemented this year. Last year, packaging “producers,” including brand owners, manufacturers, distributors, and others saw programs move into operational phases, primarily through a single Producer Responsibility Organization (PRO), the Circular Action Alliance (CAA). Implementation continues across programs in Oregon, Colorado, and California, as well as other states planning to set new requirements. As we begin 2026, covered producers should review these changes and assess the appropriate compliance methodology within their supply chains.
The State of Play in California for Autonomous Vehicles
More autonomous vehicles are operating in California than anywhere else in America. And yet California has some of the most extensive autonomous regulations in the country. While some other states have taken a relatively laissez-faire approach to autonomous vehicles, California’s rules are lengthy and elaborate. Even as various operators have been able to work through the requirements to operate in the state, they have been a major lift. And autonomous heavy trucking has been entirely prohibited. (more…)
CARB Proposes to Repeal Advanced Clean Fleets Regulation
The California Air Resources Board (CARB) has proposed to repeal the High-Priority and Drayage components of the Advanced Clean Fleets (ACF) regulations. The proposal also includes changes to the Low Carbon Fuel Standard (LCFS) regulations and implements AB 1594 (flexibility for public utilities).
U.S. EPA Eliminates Key Scope 3 Role, Leaving Gap Ahead of SB 253 Compliance
On July 28, 2025, the U.S. Environmental Protection Agency (EPA) eliminated the positions and unit responsible for maintaining the Extended Input-Output (EEIO) model, a key federal tool used to calculate Scope 3 greenhouse gas (GHG) emissions. The move signals a likely end to federal support for EEIO emissions factors, presenting challenges for companies preparing to comply with California’s landmark climate disclosure law, SB 253 (as amended by SB 219). As federal involvement recedes, the private sector and California regulators may fill the gap, introducing uncertainty about how Scope 3 emissions will be quantified going forward.
California’s CEQA Reforms Offer Narrow Exemptions — With One Powerful Exception
The California legislature recently passed SB 131 and AB 130, two bills designed to streamline environmental review under the California Environmental Quality Act (CEQA). While publicly touted as significant CEQA reform, the legal impact is more constrained, offering little relief for most industrial, commercial, or logistics-related development. SB 131 does, however, significantly expand the Governor’s discretionary power to designate certain large-scale private projects for streamlined CEQA treatment, offering potential opportunity for selected developers.
California Proposes Adding Microplastics to Candidate Chemicals List – Comment Period Open Through August 4, 2025
The California Department of Toxic Substances Control (DTSC) has proposed to amend its Safer Consumer Products (SCP) regulations by adding microplastics to the Candidate Chemicals List (Cal. Code Regs., tit. 22, § 69502.2). While this proposed action does not impose immediate compliance obligations, it has substantial implications because once microplastics are listed as Candidate Chemicals, DTSC may identify consumer products containing microplastics as Priority Products. The identification of a Priority Product triggers requirements under California law for manufacturers and entities throughout the supply chain, who must assess alternative product formulations and are subject to response measures prescribed by DTSC.
