The clock is running. October 4, 2026, is the compliance deadline for California's SB 343 labeling law — and it applies to every brand selling packaged goods in California, regardless of company size, where you are headquartered, or whether you sell in a physical store or online.
If your packaging currently displays the chasing arrows recycling symbol, any statement directing consumers to recycle, or any representation that your packaging is recyclable, you need to verify that your packaging actually meets California's new legal definition of "recyclable in the state" — or update your artwork before that date.
This is not a future-state problem. The SB 343 labeling deadline of 2026 is less than four months away. Brands that have not started their packaging audit are already behind. Here is what SB 343 requires, what is at stake, and a practical checklist to work through before time runs out.
Senate Bill 343 — commonly known as California's truth-in-labeling law or Truth in Recycling law — prohibits the use of the chasing arrows recycling symbol, resin identification codes inside a chasing arrows triangle, and any recyclability claim on products or packaging unless the material is actually being recycled through infrastructure serving most Californians.
The law was signed in 2021. The compliance clock started April 4, 2025, when CalRecycle published its Material Characterization Study Final Findings — the statewide analysis of which materials are actually collected, sorted, and processed for recycling across California's materials recovery facilities. The SB 343 October 2026 deadline is exactly 18 months from that publication date.
California's recyclability claims: California law is no longer evaluated based on theoretical material recyclability or national industry standards. They are evaluated based on whether the material actually moves through California's recycling infrastructure — a substantially more demanding bar.
To be labeled recyclable under SB 343, packaging must meet four independent criteria simultaneously:
•Collection: The material must be accepted by curbside recycling programs serving at least 60 percent of California's population.
•Sorting: The material must be sorted into defined recycling streams by facilities serving at least 60 percent of the state's recycling programs.
•Design: The packaging must not contain components — inks, adhesives, labels, coatings — that prevent it from being recycled.
•PFAS-Free: The packaging must not contain intentionally added PFAS or have PFAS levels exceeding 100 parts per million.
All four criteria must be satisfied. Meeting three out of four does not qualify packaging for a recyclability claim.
CalRecycle's Material Characterization Study makes clear which materials have real recycling infrastructure behind them and which do not. Materials that scored zero percent for effective sorting at processing facilities include polystyrene foam, PVC containers, compostable plastic bags, most plastic films, and complex composite food service packaging. Packaging made from these materials cannot carry a recycling symbol or recyclability claim after October 4, 2026.
Most uncoated paper-based materials, by contrast, are strong candidates for compliant recyclability claims under SB 343's framework.
The numbered resin identification codes (1 through 7) that have appeared on plastic packaging for decades create a separate compliance issue under SB 343. The resin code number cannot be placed inside a chasing arrows symbol unless the specific plastic meets California's statewide recyclability criteria.
Manufacturers who need to display a resin code without making a recyclability claim must use a solid equilateral triangle — not the chasing arrows — as the surrounding symbol. This creates a real operational challenge for national brands. At least 29 other states require the chasing arrows symbol around resin codes, meaning California-specific packaging artwork may be necessary.
This point is critical and frequently misunderstood. SB 343's restrictions apply based on the date of manufacture, not the date of sale. Products and packaging manufactured before October 4, 2026, are not subject to the restrictions, regardless of when they are subsequently sold or distributed in California.
This means brands have a window to sell through existing inventory of packaging manufactured before the deadline. However, any packaging produced after October 4, 2026, must comply fully with SB 343's labeling requirements. Brands need to establish a manufacturing-date tracking protocol to document which units were produced before versus after the compliance cutoff.
SB 343 is enforced by the California Attorney General and local jurisdictions. Violations of the recyclability labeling restrictions can result in civil penalties of up to $2,000 per violation. A violation may be measured per day of non-compliance, per episode of improper labeling, or per individual item improperly labeled — meaning a company that produces 50,000 non-compliant items could face tens of millions of dollars in civil liability.
Private litigation is already active. More than 30 private lawsuits have been filed citing SB 343, asserting claims under California's Unfair Competition Law, False Advertising Law, and Consumers' Legal Remedies Act. Private plaintiffs' counsel are treating SB 343's definitions as predicate standards for claims that are actionable today — before the October 2026 deadline. Brands with unsubstantiated recyclability claims on current packaging face litigation exposure now, not just in October.
In March 2026, a coalition of 18 trade associations filed suit in the U.S. District Court for the Southern District of California seeking to block enforcement of SB 343, arguing that the labeling restrictions violate First Amendment commercial speech rights. A preliminary injunction motion was filed in April 2026.
The lawsuit does not change what brands must do between now and October 4, 2026. The compliance deadline remains in effect. Companies that are not members of a plaintiff trade association cannot rely on the litigation to protect them from enforcement. Brands should plan for full compliance by the deadline while monitoring the case.
Work through these steps before October 4, 2026:
•Inventory every SKU sold or distributed in California.
•Identify every piece of packaging that displays the chasing arrows symbol, a resin identification code inside the chasing arrows, the word "recyclable," or any statement directing consumers to recycle.
•Include packaging inserts, outer shipping materials, product sleeves, labels, and tissue.
•Include website copy and marketing materials that make recyclability claims about packaging.
•Download CalRecycle's Material Characterization Study Final Findings (published April 4, 2025) and the December 2025 update.
•For each packaging material, verify whether it meets the 60/60 threshold — collected by programs serving 60 percent of California's population and sorted by facilities serving 60 percent of the state.
•Paper-based materials without problematic coatings, inks, or adhesives are generally strong candidates for compliant claims. Most plastic films, composite pouches, and foam materials are not.
•Remove the chasing arrows symbol from any packaging material that does not meet the 60/60 threshold.
•Replace chasing arrows, triangles around resin codes with solid equilateral triangles for materials that do not meet recyclability criteria.
•Remove or qualify phrases like "Please Recycle" or "Check Locally" if the material is not on CalRecycle's approved list.
•For multi-component packaging, ensure any recyclability claim is limited to the specific component that qualifies — not the entire package.
•Document technical specifications for every material with a remaining recyclability claim.
•Record PFAS test results confirming packaging is PFAS-free.
•Gather evidence of 60/60 threshold compliance citing CalRecycle data.
•Maintain signed statements of compliance with the APR Design Guide where applicable.
•California's Business and Professions Code requires written records to support all environmental marketing claims.
•Create a system to document which production runs occurred before October 4, 2026, and which occurred after.
•Coordinate with packaging suppliers and co-manufacturers to ensure manufacturing dates are documented on all incoming materials.
•Plan production schedules to exhaust non-compliant inventory before cutting new packaging runs.
•Evaluate whether existing packaging supplier contracts address SB 343 compliance obligations.
•Clarify indemnification provisions for non-compliant artwork or materials from third-party suppliers.
•Require suppliers to provide documentation confirming compliance for any packaging produced after October 4, 2026.
Paper tube packaging made from FSC-certified, uncoated kraft or white paper is precisely the kind of packaging SB 343 was designed to encourage. Most uncoated paper-based materials have strong recycling infrastructure behind them in California and are strong candidates for compliant recyclability claims — provided the packaging design does not incorporate adhesives, coatings, or plastic components that disrupt recyclability.
Paper Tube Co.'s packaging uses vegetable-based inks, FSC certified papers, and compostable materials — design choices that reduce compliance exposure under SB 343 and simplify the audit and substantiation process. Brands that have switched to paper tube packaging often find their SB 343 checklist considerably shorter.
Explore Paper Tube Co.'s sustainable packaging options atpapertube.co/pages/sustainability.
The SB 343 labeling deadline is October 4, 2026. All products and packaging manufactured on or after that date must comply with SB 343's restrictions on recyclability claims and symbols, including the chasing arrows recycling symbol.
Yes. SB 343 applies to every brand that sells, distributes, or imports products or packaging in California, regardless of where the company is headquartered. If your product is sold to California consumers — including through e-commerce — SB 343 applies.
The 60/60 threshold requires that a material be collected by recycling programs serving at least 60 percent of California's population and sorted into defined recycling streams by facilities serving at least 60 percent of the state's materials recovery facilities. Both thresholds must be met simultaneously.
Only if your packaging material meets California's statewide recyclability criteria under SB 343, if the material does not meet the 60/60 threshold, the chasing arrows symbol may not appear on packaging manufactured after October 4, 2026. Resin identification codes must be placed inside a solid triangle, not chasing arrows, for non-qualifying plastics.
Violations of SB 343's recyclability labeling restrictions can result in civil penalties of up to $2,000 per violation. Violations may be measured per day, per episode, or per individual improperly labeled item, creating potential exposure of tens of millions of dollars for large production runs. Private lawsuits under California's Unfair Competition Law are also available.
No. The federal lawsuit filed in March 2026 seeks to block SB 343, but the October 4, 2026, compliance deadline remains in effect. Companies not party to the litigation cannot rely on it for protection. Brands should plan for full compliance by the deadline.
Paper tube packaging made from uncoated, FSC-certified paper using vegetable-based inks is generally well-positioned under SB 343's criteria. Most uncoated paper-based materials have a strong recycling infrastructure in California. Specific compliance requires verifying that all components — inks, adhesives, labels — do not disrupt recyclability and that the packaging meets the 60/60 threshold based on CalRecycle's data.
California's Business and Professions Code requires brands to maintain written records supporting any environmental marketing claim, including recyclability symbols. Records should include material technical specifications, PFAS test results, evidence of 60/60 threshold compliance citing CalRecycle data, and documentation of manufacture dates establishing which units fall under the October 4, 2026, cutoff.
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