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California: sustainable packaging labelling
California combines mandatory resin, beverage-deposit and non-flushable-wipe markings with detailed compostability and recyclability controls, environmental-claim substantiation duties and packaging producer responsibility. Each regime has its own scope, responsible actors, dates and enforcement route; SB 343 remains enacted but Attorney General enforcement is preliminarily enjoined.
Executive summary
California cannot be reduced to a single “recycling label” rule. It maintains several distinct package-marking and environmental-claim regimes. Public Resources Code section 18015 requires resin identification on covered rigid plastic bottles and containers. The Beverage Container Recycling and Litter Reduction Act requires prescribed California redemption wording on covered beverage containers. Sections 42355 to 42358.5 regulate recyclability, compostability and degradation-related presentation. Sections 49650 to 49654 prescribe a “Do Not Flush” symbol for specified wipes. Business and Professions Code section 17580 requires records supporting environmental marketing claims. SB 54 adds producer-responsibility obligations but not one universal package logo.
The legal status of Senate Bill 343 requires particular care. Its recyclability criteria remain enacted, and CalRecycle states that they apply to products and packaging manufactured after 4 October 2026. On 14 July 2026, however, the United States District Court for the Southern District of California entered a preliminary injunction restraining enforcement by the California Attorney General and persons acting in concert or privity with that office while litigation proceeds. The order is temporary and does not repeal the statute. A report should therefore state both propositions rather than calling the law either fully enforceable without qualification or invalid.
Legal status at a glance
| Requirement | Status | Operational meaning |
|---|---|---|
| Rigid plastic resin code | mandatory | Covered rigid plastic bottles and containers must display the resin code in a solid equilateral triangle; chasing arrows are restricted unless recyclability criteria are met. |
| Beverage deposit statement | mandatory | Covered containers must carry one of five prescribed California redemption statements by an approved durable method. |
| Compostable plastic presentation | mandatory / restricted | Claims require qualifying standards and third-party certification; product presentation, colour and symbols are controlled, and degradation terms are restricted. |
| Recyclability representation under SB 343 | in force; enforcement enjoined in part | The statutory criteria apply to products and packaging manufactured after 4 October 2026. A federal preliminary injunction currently restrains Attorney General enforcement and certain aligned actors. |
| Non-flushable wipes | mandatory | Covered wipes require the “Do Not Flush” symbol and prescribed placement, size, contrast and package-format treatment. |
| Packaging EPR under SB 54 | mandatory programme | Producer membership, reporting, fees and performance duties apply; the law does not prescribe one general consumer-facing EPR mark. |
| AB 2253 | proposed | The pending 2025-26 bill would tighten recycled-content claim accounting. It is not enacted law. |
Resin identification and the symbol transition
Section 18015 requires each rigid plastic bottle or rigid plastic container manufactured for use in California to be labelled with a code indicating the resin. California now uses a solid equilateral triangle consistent with ASTM D7611 rather than treating the chasing-arrows form as a neutral resin identifier. The numbers and abbreviations identify PETE, HDPE, V, LDPE, PP, PS and OTHER categories.
The design matters because SB 343 treats the chasing-arrows symbol and other statements indicating recyclability as environmental representations. A business should therefore separate the mandatory composition code from any optional recycling message. Molded tooling, material specifications and the SB 343 assessment should be version-controlled together. A legacy chasing-arrows mold should not be carried forward automatically.
Beverage container redemption marking
Public Resources Code section 14561 requires a beverage manufacturer to place one of five statements on each covered beverage container: “CA Redemption Value,” “California Redemption Value,” “CA Cash Refund,” “California Cash Refund” or “CA CRV.” The statute prescribes the wording, not a printed cash amount. The statement may be etched, embossed or printed on the container, or placed through a securely affixed stamp, label or other device, and must be clear and prominent.
The duty applies only after the product is classified as a covered beverage and the container is within the program. Product registration and container marking are related but separate controls. Refillable containers have a statutory exemption. The initial transition for wine and distilled-spirit containers added to the program has ended; current stock should be assessed under the operative rules rather than the former sell-through period.
Compostable, degradable and biodegradable presentation
California generally prohibits plastic products from being labelled “biodegradable,” “degradable,” “decomposable” or with similar implications. A compostable representation requires satisfaction of the applicable ASTM D6400 or D6868 criteria, or the authorized home-compostability route, together with third-party certification and other statutory conditions. Fluorine limits and association with desirable organic inputs also matter.
Presentation rules are product-specific. Compostable plastic bags require the certification logo and conspicuous identification through colour, bands or lettering as provided by law. Compostable products must be readily distinguishable and may not use the chasing-arrows recycling symbol. The regulated “product” can include an article rather than only conventional packaging, so packaging teams should identify whether the item, its package or both carry the claim.
SB 343 recyclability criteria and current injunction
Section 42355.51 restricts use of the chasing-arrows symbol, the word “recyclable” and other representations that a product or packaging is recyclable unless the statutory criteria are met. CalRecycle’s statewide characterization study and material-category findings support the assessment. The principal route combines collection access for at least 60 percent of the state population with sortation and reprocessing criteria, including consistency with the relevant design guide and absence of features that prevent recycling. A separate route addresses material recovered through a program with a demonstrated high recovery rate.
CalRecycle identifies 4 October 2026 as the manufacturing application date. The July 2026 preliminary injunction prevents the Attorney General and persons acting in concert or privity with that office from enforcing the challenged provisions while the order remains in effect. It does not erase the statutory text, decide the case finally or necessarily determine every public or private enforcement theory. Businesses should monitor the docket and obtain current advice before relying on the injunction for artwork released after the manufacturing date.
Environmental-claim records and recycled-content proposals
Business and Professions Code section 17580 requires a person making specified environmental marketing claims to maintain written records and make information available as prescribed. The record should identify the factual basis, tests, standards, calculations and market assumptions supporting the claim. Compliance is not achieved by keeping a supplier declaration that does not address the consumer-facing proposition.
Assembly Bill 2253 remains proposed legislation in the 2025-26 session. In its current legislative form it would require recycled-content claims to reflect actual physical recycled content and would restrict mass-balance or credit-based attribution. It had advanced in the Senate as of the verification date but was not enacted. It belongs in legal tracking, not in a current mandatory-artwork specification.
Non-flushable wipes and packaging producer responsibility
AB 818 created the non-flushable-wipe labelling regime in sections 49650 to 49654. Covered wipes manufactured on or after 1 July 2022 must display the “Do Not Flush” symbol. The statute addresses location, contrast, size and treatment for different package formats, including cylindrical packs, flexible film and packages with a principal display panel. This is a disposal instruction for wipes, not a general packaging-recycling label.
SB 54, codified beginning at section 42040, establishes producer responsibility for covered single-use packaging and plastic food-service ware. Permanent regulations were approved by the Office of Administrative Law on 1 May 2026. Producers face organization membership, reporting, fee, source-reduction and recyclability performance obligations. The program does not itself create one universal consumer EPR mark, and payment into the system does not substantiate a claim that a particular package will be recycled.
Who bears which obligation
The responsible party changes by regime. A rigid-plastic manufacturer controls the resin mark. A beverage manufacturer bears the redemption-statement duty. Producers and persons selling compostable products face presentation restrictions. A person making an environmental claim must hold supporting records. Wipe manufacturers must apply the flushability warning. SB 54 uses its own producer definition, including rules for brands, licensees, importers and sellers.
A California compliance matrix should therefore have one row per legal instrument rather than one generic “brand owner” field. It should name the regulated actor, product definition, manufacturing or sales date, package component, required artwork, evidence owner and enforcement body. Common artwork can be approved only after these separate analyses are reconciled.
Practical artwork checklist
Classify the product first: rigid plastic, covered beverage, compostable plastic product, non-flushable wipe and SB 54 covered material are separate tests. Confirm the resin and use the current solid-triangle code. For beverages, select an authorized redemption statement and approved application method. For compostability, verify certification, standard, fluorine and presentation conditions. For recyclability, document the current CalRecycle category and the effect of the injunction. For wipes, measure the symbol against the correct package-format rule.
Retain dated source copies, laboratory and certification records, statewide access and design evidence, final production proofs, registrations and legal-status notes. California rules change on manufacturing dates and through litigation as well as legislation. “Last verified” is therefore substantive information, not page decoration.
Primary sources and verification
California Legislature. Public Resources Code section 14561, beverage-container redemption statement. Official code
California Legislature. SB 343 enrolled text, including amendments to sections 18015 and 42355.51. Official bill text
California Legislature. Public Resources Code section 42355.51. Official code
CalRecycle. SB 343 recyclability-labelling implementation and statewide findings. Official guidance
United States District Court, Southern District of California. Preliminary-injunction order filed 14 July 2026. Court order
CalRecycle. Plastic product labelling, compostability standards and presentation. Official guidance
California Legislature. Business and Professions Code section 17580, environmental marketing records. Official code
California Legislature. AB 818, non-flushable wipes. Official enacted bill
CalRecycle. SB 54 packaging producer-responsibility program. Official program page
California Legislature. AB 2253 (2025-26), current bill status. Official legislative status
Federal Trade Commission. Green Guides, 16 CFR Part 260. Official guidance and regulatory text
Federal Trade Commission. Environmental Claims: Summary of the Green Guides. Business guidance
California’s statutes, regulations, agency findings and current court orders should all be checked before release. Last verified: 21 August 2026.