Legal ESG

Enforcement & Greenwashing

California Tightens Recyclability Claims — October Deadline Carries Greenwashing Exposure

On June 29, ArentFox Schiff published a compliance alert flagging that California's SB 343 applies to all products manufactured after October 4, 2026: companies must either verify their products meet quantitative recyclability criteria (including 60% consumer access to recycling collection and 60% of California recycling systems sorting the material) or remove recyclability claims — including the

BY FRONTIER DESK · JUNE 30, 2026 · 1 MIN READ

On June 29, ArentFox Schiff published a compliance alert flagging that California's SB 343 applies to all products manufactured after October 4, 2026: companies must either verify their products meet quantitative recyclability criteria (including 60% consumer access to recycling collection and 60% of California recycling systems sorting the material) or remove recyclability claims — including the ubiquitous "chasing arrows" symbol. Companies must maintain written records supporting any remaining recycling claims and make those records available to the public on request; those records are explicitly usable in enforcement or greenwashing suits by the attorney general, other state officials, or private plaintiffs. With more than 400 greenwashing enforcement actions recorded globally in 2026 and the EU's Green Claims Directive moving toward effect, California's October deadline adds a concrete, near-term compliance trigger for consumer goods, packaging, and retail clients. Product counsel and advertising counsel should align on a joint SB 343 audit before October 4 — the public records requirement means noncompliance creates a ready-made evidence base for private plaintiffs.

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