Page 14 - Kattison Avenue Newsletter - Spring 2026 - Issue 16

California's Trash Talk

The registration deadline for apparel and textile producers under the state’s new
Extended Producer Responsibility (EPR) law is July 1, 2026.

By Cynthia Martens

Under the Responsible Textile Recovery Act of 2024, which “producer.” Specifically, the law defines as “producer” any
aims to make textile and apparel producers responsible for “person who manufactures a covered product and who owns
the cost of consumer textile and apparel waste, all producers or is the licensee of the brand or trademark under which that
of covered products in California must register with the state- covered product is sold, offered for sale, or distributed for sale
selected Producer Responsibility Organization (PRO) by July 1. in or into the state.” If there is no such person in California,
The PRO is responsible for overseeing textile waste collection, then the producer “is the owner of a brand or trademark or, if
implementing appropriate waste management and processing the owner is not in the state, the exclusive licensee of a brand
infrastructure, and representing members before regulatory or trademark under which the covered product is sold, imported
authorities, among other activities. for sale, offered for sale, or distributed for sale in or into the
state, regardless of whether the trademark is registered.” In the
The law contains sweeping definitions of apparel and textiles;
absence of a brand owner or exclusive licensee in California, the
the sale of a covered product is deemed to occur in California if
producer “is the person that imports the covered product into
the product is delivered to the consumer in the state.
the state for sale or distribution,” and, failing that, the producer
For many fashion businesses, compliance with the new law is the “distributor, retailer, or wholesaler who sells the product in
requires a careful analysis of the cascading definition of or into the state.”

14 Kattison Avenue | Spring 2026