This program will provide a practical overview of the rapidly evolving extended producer responsibility (“EPR”) landscape, with a primary focus on California’s SB 54 and its producer definitions, reporting obligations, fee...more
3/10/2026
/ California ,
Continuing Legal Education ,
Deadlines ,
Extended Producer Responsibility (EPR) ,
Fees ,
Plastics ,
Pollution Control ,
Producers ,
Product Packaging ,
Recycling ,
Reporting Requirements ,
Waste Management ,
Webinars
On February 20, the California Court of Appeal issued a decision with significant implications for Proposition 65 litigation: Environmental Health Advocates, Inc. v. Pancho Villa’s, Inc., et al. In short, a private...more
On February 26, 2026, CARB approved regulations to implement California Senate Bills 253 (the Climate Corporate Data Accountability Act) and 261 (the Climate-Related Financial Risk Act) following a public hearing. The...more
On February 19, 2026, we attended the Circular Action Alliance (“CAA”) California EPR Update Webinar. CAA is the Producer Responsibility Organization (“PRO”) implementing California’s packaging EPR law, Senate Bill (“SB”) 54....more
On February 18, 2026, CalRecycle published several components of the SB 54 statewide needs assessment, including five technical reports and a Synthesis Report summarizing the overall findings. The statewide needs assessment...more
On January 23, 2026, we attended the SB 54 Packaging Producer Responsibility Advisory Board’s first meeting of the year. The Board received updates from both CalRecycle and Circular Action Alliance (CAA), California’s...more
If California’s SB 54 rulemaking process feels familiar, that’s because it is. CalRecycle has withdrawn proposed implementing regulations—signaling continued recalibration of one of the most complex packaging Extended...more
On December 8, the California Office of Environmental Health Hazard Assessment (OEHHA), the state agency in charge of implementing Proposition 65 (Prop. 65), issued a guidance letter providing clarity about Prop. 65 warnings...more
12/17/2025
/ California ,
Enforcement Actions ,
Environmental Policies ,
Hazardous Substances ,
New Guidance ,
OEHHA ,
Product Labels ,
Proposition 65 ,
Public Health ,
Retailers ,
Toxic Chemicals ,
Warning Labels
On December 2, 2025, the California Attorney General (AG) issued an enforcement advisory reminding producers of expanded polystyrene foam food service ware of their obligations under Senate Bill (SB) 54, the Plastic Pollution...more
On December 3, 2025, we attended Circular Action Alliance’s (CAA) Quarterly Update webinar. CAA is the Producer Responsibility Organization (PRO) that has been selected by states with active plastic and packaging Extended...more
We continue to closely follow the litigation brought by the U.S. and California Chambers of Commerce, the American Farm Bureau Federation, the Los Angeles County Business Federation, the Central Valley Business Federation,...more
On September 22, 2025, we attended Circular Action Alliance’s (CAA) Quarterly Update webinar. CAA is the Producer Responsibility Organization that has been selected by states with active plastic and packaging Extended...more
We’ve been closely following the litigation brought by the U.S. and California Chambers of Commerce, the American Farm Bureau Federation, the Los Angeles County Business Federation, the Central Valley Business Federation, and...more
On September 11, 2025, a California federal court denied business groups’ request to enjoin two California climate disclosure laws pending their appeal to the Ninth Circuit from the court’s earlier denial of their request for...more
On August 11, 2025, the U.S. District Court for the Eastern District of California issued a significant ruling in Personal Care Products Council v. Bonta, striking down California’s Proposition 65 (“Prop 65”) cancer warning...more
9/4/2025
/ California ,
Compelled Speech ,
Cosmetics ,
Federal Court Litigation ,
First Amendment ,
Injunctions ,
Permanent Injunctions ,
Personal Care Products ,
Proposition 65 ,
Toxic Chemicals ,
Warning Labels
California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, also known as Senate Bill (SB) 54, continues to move forward toward full implementation with the issuance of new guidance documents....more
9/4/2025
/ California ,
Environmental Policies ,
Extended Producer Responsibility (EPR) ,
Guidance Documents ,
New Guidance ,
Plastics ,
Product Packaging ,
Recycling ,
Regulatory Requirements ,
Reporting Requirements ,
Sustainability ,
Waste Management
California’s Proposition 65 (“Prop. 65”) requires businesses to provide warnings for any products that contain certain levels of chemicals determined by the State of California to cause cancer or reproductive harm. Prop. 65...more
In the three months since our previous post about major California businesses being targeted with a Proposition 65 (“Prop. 65”) Notice of Violation (“NOV”) for allegedly exposing California customers to Bisphenol S (BPS) in...more
On June 30, California Governor Gavin Newsom signed two budget bills that contained the most significant reforms to the California Environmental Quality Act (CEQA) in decades, effective immediately. These changes create an...more
On July 1, the California Department of Resources, Recycling, and Recovery (CalRecycle), a California agency tasked with implementing the state’s sustainability laws, released its latest draft of regulations for California...more
On March 4, 2025, the Supreme Court issued its opinion in City and County of San Francisco v. Environmental Protection Agency, holding that EPA does not have the authority to issue “end-result” requirements in National...more
Maryland and Washington have joined the growing list of states enacting extended producer responsibility (EPR) laws for packaging and paper products. These laws shift the cost of recycling these materials from the consumer...more
Effective May 13, 2025, the United States Environmental Protection Agency (EPA) issued an interim rule extending the data submission period for the Toxic Substances Control Act (TSCA) section 8(a)(7) perfluoroalkyl and...more
On May 2, 2025, the U.S. District Court for the Eastern District of California issued a landmark ruling in California Chamber of Commerce v. Bonta, Case No. 2:19-cv-02019, holding that Proposition 65 (“Prop. 65”) warning...more
Acrylamide, a Proposition 65-listed substance that naturally forms in the cooking and heating of many plant-based foods, has been the focus of court action over the past six years. However, companies will no longer be...more