California SB 343 Compliance: A Guide to Packaging & Truth in Labeling

For decades, the “chasing arrows” symbol has been the universal shorthand for recyclability. However, in the state of California, that symbol is no longer a suggestion—it is a strictly regulated claim.

Senate Bill 343 (SB 343), often called the “Truth in Labeling” law, fundamentally changes how manufacturers and brands can market the environmental attributes of their packaging. By shifting from “technically recyclable” to “actually recycled in practice,” California is setting a new global standard for transparency.

This guide provides a comprehensive breakdown of SB 343, its rigorous compliance standards, and the critical deadlines your business must meet to avoid hefty penalties.

What is California SB 343?

Signed into law in late 2021, SB 343 aims to eliminate “greenwashing” by prohibiting the use of the chasing arrows symbol (or any other recyclability claim) on products and packaging that do not meet strict, data-driven criteria.

The law mandates that for a package to be labeled as recyclable in California, it must be part of a material stream that is actually collected, sorted, and processed into new feedstock within the state’s existing infrastructure.

Key Distinction: Theory vs. Reality

• Before SB 343: If a plastic was technically capable of being melted down, it often bore the recycling symbol.
• After SB 343: A material is only “recyclable” if it meets the 60/60 Rule—proving it is handled at scale by California’s waste management facilities.

The 60/60 Rule: The Core Compliance Threshold

The cornerstone of SB 343 is a dual-threshold requirement. To legally use the chasing arrows symbol, packaging must satisfy two conditions simultaneously:

1. Collection Threshold (60%): The material type and form must be accepted for collection by recycling programs that serve at least 60% of California’s population.
2. Processing Threshold (60%): The material must be sorted into defined streams by large-volume transfer or processing facilities (LVTPs) that serve at least 60% of recycling programs statewide.

Additional Criteria

Beyond the 60/60 rule, the packaging must:

• Become Feedstock: Be reclaimed into a form that is used in the production of new products or packaging.
• Meet Design Standards: Not contain components (inks, adhesives, or labels) that prevent it from being recycled.
• Be PFAS-Free: Not contain “intentionally added” PFAS or have PFAS levels exceeding 100 parts per million (ppm).

Critical Deadlines and Timeline

Compliance is not a suggestion for the future—the clock is already ticking. The timeline is dictated by the publication of CalRecycle’s Material Characterization Study.

Important Note: The labeling restrictions apply to products and packaging manufactured after October 4, 2026. Items manufactured before this date can still be sold, but any new production runs must adhere to the new standards.

Impact on Plastic Resin Identification Codes (RIC)

One of the most visible changes involves the Resin Identification Code (the number 1–7 inside a triangle).

Under SB 343, the triangle itself is considered a recyclability claim if it resembles the chasing arrows.

• Non-Recyclable Plastics: Must still display the RIC for identification, but the number cannot be inside the chasing arrows symbol.
• Compliant Plastics: Only those meeting the 60/60 rule can keep the traditional chasing arrows around the resin number.

Penalties for Non-Compliance

California is taking enforcement seriously. Violating SB 343 falls under “deceptive or misleading” environmental marketing.

• Civil Penalties: Fines can reach up to $2,500 per violation. In the context of mass-produced packaging, “per violation” can refer to a single day of sales or even a single improperly labeled unit, potentially leading to millions in liability.
• Criminal Charges: Misleading claims can be prosecuted as a misdemeanor, punishable by up to six months in jail.
• Private Litigation: SB 343 provides a framework for class-action lawsuits under California’s Unfair Competition Law and False Advertising Law.

How to Prepare for SB 343 Compliance

To ensure your brand is ready by October 2026, follow these strategic steps:

Step 1: Audit Your Packaging Portfolio

Identify every piece of packaging that currently uses the chasing arrows symbol or the word “recyclable.” Cross-reference these materials with the CalRecycle Final Findings Report (2025) to see if they meet the 60/60 threshold.

Step 2: Redesign Non-Compliant Labels

If your material (such as certain plastic films or multi-layer pouches) is not on the “accepted” list, you must remove the recycling symbol and any unqualified recyclability claims from your artwork.

Step 3: Implement Substantiation Files

The law requires manufacturers to maintain written records supporting any environmental claims. This includes:

• Technical specifications of the material.
• Evidence of 60/60 threshold compliance (citing CalRecycle data).
• PFAS testing results.

Step 4: Explore Alternatives

Consider moving toward “Mono-materials” (e.g., all-paper or 100% PET) that have higher success rates in California’s recycling infrastructure.

SB 343 Compliance Checklist for Packaging Materials

To ensure your packaging remains compliant for the October 4, 2026 deadline, use the following checklist to evaluate every SKU in your inventory. Compliance is an “all-or-nothing” requirement; failing a single point below renders the use of the chasing arrows symbol illegal.

Phase 1: Material & Form Assessment

• Identify Material Type and Form: Does your packaging match a category identified in the CalRecycle Final Findings Report (2025)? (e.g., “PET Bottle” vs. “PET Thermoform”).
• Verify the 60/60 Rule: * Is the material collected by programs serving at least 60% of California’s population?
  • Is it sorted into defined streams by facilities serving at least 60% of recycling programs?
• Check Alternative Routes: If it fails the 60/60 rule, does it have a proven 75% recycling rate within the state, or is it part of a state-approved take-back program?

Phase 2: Design & Chemical Integrity

• APR Design® Guide Compliance: For plastic packaging, does the design (including caps, closures, and labels) meet the Association of Plastic Recyclers (APR) “Preferred” criteria?
• PFAS Screening: * Confirm there are no intentionally added PFAS in the material or fiber.
  • Verify through lab testing that total organic fluorine is below 100 ppm.
• Contaminant Audit: Are the inks, adhesives, and labels used free from chemicals that interfere with the recycling process (as defined by CalRecycle)?

Phase 3: Labeling & Artwork Review

• Resin Identification Code (RIC) Triangle: * If the material is not recyclable under SB 343, has the chasing arrows triangle been replaced with a solid or equilateral triangle (per ASTM standards)?
• Directional Claims: Have you removed or qualified phrases like “Please Recycle” or “Check Locally” if the material is not on the approved list?
• Multi-Material Components: If only part of the package is recyclable (e.g., a cardboard box with a plastic liner), is the claim clearly limited to the specific recyclable component?

Phase 4: Documentation & Recordkeeping

• Establish a Substantiation File: Do you have a centralized folder containing:
  • Technical data sheets.
  • PFAS test results.
  • A signed statement of compliance with the APR Design® Guide.
• Date of Manufacture Tracking: Do you have a system to prove which units were manufactured before vs. after the October 4, 2026 cutoff?

Conclusion

California’s SB 343 represents a paradigm shift in environmental accountability. It moves the burden of proof from the consumer to the manufacturer, requiring empirical evidence that “recyclable” isn’t just a marketing buzzword, but a functional reality.

With the October 4, 2026 deadline approaching, brands must act now to audit their supply chains, update their artwork, and ensure their claims are substantiated by CalRecycle’s data. Proactive compliance not only mitigates legal risk but also builds authentic trust with an increasingly eco-conscious consumer base.

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