您的产品准备好了吗？加州回收标签真相（SB 343）限制将在不到五个月内生效（2026年10月4日）。

California’sTruth in Recycling Labeling (SB 343) RestrictionsBecome Effective in LessThan Five Months (October 4, 2026) May 2026 After five years of leadup, SB 343’s “Truth in Recycling” labeling restrictions, which will havefar-reaching ramifications in the US consumer product market, finally becomes effective onOctober 4, 2026.SB 343restricts environmental marketing claims that the state deems to be It also reaches variants of that symbol that are likely to beinterpreted by a consumer as an implication of recyclability,including, but not limited to, one or more arrows arranged ina circular pattern or around a globe.” Cal. Bus & Prof. Code While there are alternative ways to meet the recyclabilitycriteria, products are generally considered recyclable if the •Accepted for collection by jurisdiction recycling programscollectively serving at least 60% of the California population •Sorted into defined streams by large volume transfer/ –Collectively serve at least 60% of statewide recycling –Send them to a reclaimer and reclaim them consistent •Satisfy specific composition and design limitations: –For plastic packaging, products or non-plastic products,the design does not include any components, inks, Therefore, it will be critical for all companies, but especiallyany foreign companies doing business in the US who mayhave UK-based or EU-based recycling symbols on packaging,to ensure compliance with SB 343 if its products make theirway to the California market. In addition, any recyclability –The product or packaging does not contain an intentionallyadded chemical identified in regulations from the USFood and Drug Administration (FDA) and the Office of –The product or packaging is not made from plastic or fiberthat contains intentionally added Per- and polyfluoroalkyl Resin Identification Codes (RICs) also present challenges underSB 343. While California now provides that RICs may only use asolid equilateral triangle, 29 other states have RIC requirements SB 343 places responsibility for recyclability labeling onthe producer of the product and packaging, who must alsosubstantiate that recyclability criteria are met. Cal. Bus &Prof. Code § 17580(a). This means companies must maintain These requirements directly impact the commonly used California’s SB 343 would likely deem these symbols“misleading” to consumers and in violation of Truth inRecycling. This leaves companies with no clear path for oneset of uniform packaging that complies with all state laws,and CalRecycle has offered no guidance to help address Compliance with SB 343 will be crucial for several reasons,but there is one aspect of SB 343 that sets it apart fromother laws. While SB 343 does not create a private right ofaction by itself, violations under SB 343 can be enforced byprivate citizens in consumer claims (e.g., California’s FalseAdvertising Law, the California Consumers Legal RemediesAct and California’s Unfair Competition Laws) in addition tothe enforcement by the attorney general. Moreover, a privatecitizen or member of the public is entitled to request (and a Contcts Peter GouldPartner, DenverE peter.gould@squirepb.comT +1 303 894 6176 Allen KacenjarPartner, ClevelandE allen.kacenjar@squirepb.comT +1 216 479 8296 Danelle GagliardiSenior Associate, ColumbusE danelle.gagliardi@squirepb.comT +1 614 365 2820 Companies should have already or should now be assessingproduct compliance with SB 343, as there are less than sixmonths left. Squire Patton Boggs is happy to assist with