Extended Producer Responsibility Deadlines Are Here: What Companies Complying With Packaging and Textile EPR Need to Do Now
Companies preparing to comply with packaging extended producer responsibility (EPR) requirements across the United States, as well as textile producers and those in their supply chains, should update their strategies based on recent and upcoming developments across states with new programs.
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.
Oregon Federal Court Enjoins EPR Law Enforcement
On February 6, 2026, Sidley prevailed on behalf of the National Association of Wholesaler-Distributors (NAW) in securing a preliminary injunction against Oregon’s first-of-its-kind plastic packaging extended producer responsibility (EPR) law. Judge Michael H. Simon of the U.S. District Court for the District of Oregon granted a preliminary injunction prohibiting the Oregon Department of Environmental Quality (DEQ) from enforcing the Plastic Pollution and Recycling Modernization Act (often referred to as Oregon’s “Recycling Modernization Act” or “RMA”) against NAW and its members, while the case proceeds to trial. The injunction represents a significant milestone, with the federal court acknowledging that producers would likely be injured by the Act’s violations of due process and impacts caused on interstate commerce.
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.
SB 54 Regulations Public Comment Period Open Until June 3, 2025
CalRecycle has released amendments to the proposed regulations implementing California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) and published its Report to the Legislature describing the program’s broader implementation. CalRecycle is accepting public comments on the proposed changes to the regulations through tomorrow, June 3, 2025.
