California SB 343 and What it Means for Your Business
The Truth about the "Truth in Labeling" Law
2 April 2026
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Table of Contents
- What is SB 343?
- Who is in scope?
- Criteria to determine recyclability
- Risks of non-compliance
- Conflicting laws in the U.S.
- How Anthesis can help
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With a flurry of regulatory activity in the packaging space this year amidst the revving up of Extended Producer Responsibility (EPR) regulations throughout the U.S., California’s Senate Bill 343 – the “Truth in Recycling” law – might be easy to overlook. However, the truth is that this law will have a serious impact on producers of both products and packaging doing business in California.
To meet compliance criteria, producers will need to consider the significance of changing labels, possible legal fees, and influencing consumer recycling habits. The regulation aims to address the conflict between on-packaging recycling labels and symbols with the realities of recycling infrastructure. Certain packaging types and materials may be widely considered as ‘recyclable’, but when the actual collection, processing, and end markets are evaluated, these assumptions may not ring true at the scale imagined.
What is SB 343?
Commonly known as the “Truth in Recycling” or “Truth in Labeling” law, California’s SB 343 prohibits companies from using the chasing arrows symbol or any other indicator of recyclability on products and packaging manufactured after October 4, 2026, unless certain criteria are met.
SB 343 directs CalRecycle, California’s department of waste and recycling, to publish data on what is collected, processed, and actually recycled in the state. This data provides key criteria producers must use to assess their products if they want to label them as recyclable. The first Material Characterization Study was published on April 4, 2025, with an update to the material types and forms being sorted by surveyed large-volume transfer/processing facilities and the counties served released on August 8, 2025. The law requires CalRecycle to publish this data again in 2027, and every 5 years subsequently.
Who is in scope?
CalRecycle, local jurisdictions, and producers all have key responsibilities under the regulation:
- CalRecycle must conduct and publish a material characterization study that provides information on what is being collected and processed by large volume transfer and processing facilities in the state. This information helps to guide producers and local jurisdictions on whether materials can be classified as recyclable.
- Local jurisdictions at the county level are responsible for enforcing the legislation and imposing penalties if charges of non-compliance are brought forth.
- Producers, those who manufacture the products or packaging, are responsible for evaluating their goods against the six criteria and reviewing the available information around material categorization. Producers must also provide documentation validating their recyclability or environmental claims to any requesting member of the public.
Criteria for determining which products may be labeled as recyclable
For a product or packaging to display the chasing arrow symbol or other recyclability labeling, it must meet the following six criteria:
- Material type is collected for recycling programs for jurisdictions that collectively encompass at least 60% of the population of the state.
- Alternatively, if a product or packaging has a demonstrated recycling rate of at least 75%, it may be labeled as recyclable, regardless of evaluation on the set of six criteria.
- If it is not collected through curbside recycling, alternative compliance is possible if:
- Before January 1, 2030, a product is collected through a program that recovers at least 60% of that packaging or product material
- After January 1, 2030, a product is collected through a program that recovers at least 75% of that packaging or product material
- The material type and form are sorted into defined streams for recycling processes by large-volume transfer or processing facilities
- For plastic packaging, the packaging is designed to not include any components, inks, adhesives, or labels that prevent the recyclability of the packaging according to the APR Design® Guide published by the Association of Plastic Recyclers.
- For plastic products and non-plastic products and packaging, the product or packaging is designed to ensure recyclability and does not include any components, inks, adhesives, or labels that prevent the recyclability of the product or packaging.
- The product or packaging does not contain an intentionally added chemical identified pursuant to the regulations implementing subparagraph (4) of subdivision (g) of Section 42370.2 of the legislation.
- The product or packaging is not made from plastic or fiber that contains perfluoroalkyl or polyfluoroalkyl substances or PFAS that meets either of the following criteria:
- PFAS that a manufacturer has intentionally added to a product or packaging and that have a functional or technical effect in the product or packaging, including the PFAS components of intentionally added chemicals and PFAS that are intentional breakdown products of an added chemical that also have a functional or technical effect in the product.
- The presence of PFAS in a product or product component or packaging or packaging component at or above 100 parts per million, as measured in total organic fluorine.
Alternatively, if a packaging or product is handled through a state or federal law established program (such as a bottle bill), on or after January 2022, which governs its disposal and is determined to not contaminate curbside recycling or mislead consumers on its recyclability, it can be considered recyclable in the state.
Risks of non-compliance
Manufacturers and producers will be held accountable for evaluating their products and packaging.
Any manufacturer or distributor of a product that includes green claims in advertising or labeling indicating that the product does not negatively impact the environment or is providing some environmental benefit through language – such as ‘eco-friendly’, ‘green product’, or using the chasing arrows – will need to provide written evidence supporting the validity of these claims.
This evidence must contain:
- The reasons the manufacturer/distributor believes the representation to be true.
- Any significant adverse environmental impacts directly associated with the production, distribution, use, and disposal of the consumer good.
- Any measures that are taken by the manufacturer/distributor to reduce the environmental impacts directly associated with the production, distribution, and disposal of the consumer good.
- Violations of any federal, state, or local permits directly associated with the production or distribution of the consumer good.
- Whether, if applicable, the consumer good conforms with the uniform standards contained in the Federal Trade Commission Guidelines for Environmental Marketing Claims for the use of the terms “recycled,” “recyclable,” “biodegradable,” “photodegradable,” or “ozone friendly.”
- If the manufacturer/distributor uses the term “recyclable,” uses a chasing arrows symbol, or otherwise directs a consumer to recycle the consumer good, whether the consumer good meets all of the criteria for statewide recyclability pursuant to subdivision (d) of Section 42355.51 of the Public Resources Code.
Conflicting laws across the U.S.
Although SB 343 prohibits the use of chasing arrows without credible evidence, other states have conflicting laws that can pose a challenge for producers.
There are 29 states that mandate the use of chasing arrows with resin identification codes and others that will allow either chasing arrows or the unilateral triangle with the resin codes. If products do not align with the recyclability criteria, producers can utilize the solid unilateral triangle to identify the rigid plastic resin codes.
It is recommended to be aware of these discrepancies, considering explicit guidance for how to manage them has not been published.
How Anthesis can help
With likely costs, supply chain constraints, consumer reactions, and the concern over adjusting labeling or choosing to abandon the chasing arrows altogether for fear of litigation, SB 343 is posing significant potential impacts on producers.
Evaluating your readiness and the potential risk exposure of your products and packaging is a strong first step to addressing these challenges. Anthesis supports clients in baselining products and assessing compliance readiness for local, national, and international regulations. We develop custom action plans and implementation strategies to mitigate risk and leverage client-specific opportunities.
We also help clients understand legislation and compliance requirements in context. For example, complimentary bills such as SB 54, California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, include ambitious recycling rate goals that could be impacted if producers choose to abandon recycling labels on packaging to avoid potential misrepresentations. By 2032, SB 54 requires:
- 100% of single-use packaging and plastic food service ware are recyclable or compostable, with the recyclability definition coming from SB 343
- A 65% recycling rate of single-use plastic packaging and food service ware
There is connectivity between these regulations that will support the bolstering of recycling infrastructure and the circularity of packaging. Anthesis is well-equipped to assess your business’ relationship with these regulations, analyze your data, outline your potential risks, and establish a strategy for compliance.
Growing Extended Producer Responsibility (EPR) regulations are also interrelated with the data analysis needs of SB 343. Companies gearing up for EPR reporting should keep in mind how conducting the SB 343 analysis provides mutual benefits to their EPR reporting work as deadlines approach.
Preparing for 2026 EPR Compliance
Key deadlines and practical action steps as EPR programs continue their expansion across the U.S.
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