California's SB 343 is changing what it means to call a product or package “recyclable.”
Rather than relying primarily on whether a material is technically capable of being recycled, California's framework looks at whether materials are actually collected and processed for recycling in the state. To support that determination, the California Department of Resources Recycling and Recovery (CalRecycle) conducted a statewide Material Characterization Study examining what moves through California's recycling system.
For companies selling packaged products in California, the resulting requirements were scheduled to reach an important milestone on October 4, 2026. Products and packaging manufactured after that date are subject to SB 343's restrictions on the chasing-arrows symbol and other indicators of recyclability.
There is, however, an important complication: enforcement of SB 343 is currently blocked by a federal preliminary injunction. That makes the immediate legal landscape uncertain, but it does not eliminate the underlying packaging-data challenge created by the law.
What Is California SB 343?
SB 343, sometimes referred to as California's “Truth in Recycling” or “Truth in Labeling” law, was enacted in 2021 to establish more objective standards around recyclability representations.
The law restricts the use of the chasing-arrows symbol and other indicators that a product or package is recyclable unless applicable criteria are satisfied. CalRecycle's role includes studying what materials are actually collected and processed through California's recycling infrastructure and publishing that information for manufacturers and other interested parties to use in evaluating recyclability claims.
This represents an important shift for packaging teams.
A material being theoretically recyclable is not necessarily enough. Companies making recyclability claims need to understand how that type of material performs within California's actual recycling system—and how the characteristics of their particular product or package affect the analysis.
Why Does October 4, 2026 Matter?
CalRecycle published its first SB 343 Material Characterization Study Final Findings on April 4, 2025. Under SB 343, manufacturers receive 18 months following publication of a study to adjust their use of recyclability representations based on the updated information.
That 18-month period ends on October 4, 2026.
Importantly, the date is tied to manufacture, not sale.
According to CalRecycle, products and packaging manufactured after October 4, 2026 are subject to the labeling restrictions. Products and packaging manufactured before that date are not subject to those restrictions simply because they continue to be sold afterward.
This means October 4 was intended to mark a meaningful transition point for companies using recyclability claims on products and packaging sold in California.
Current Status: SB 343 Enforcement Is Under Injunction
The October 4 date currently comes with a significant caveat.
On July 14, 2026, a federal court issued a preliminary injunction in California League of Food Producers v. Bonta, blocking enforcement of SB 343. CalRecycle now states that the ongoing litigation may affect the October 4, 2026 compliance deadline.
The injunction does not eliminate SB 343 or stop CalRecycle's material-characterization work. CalRecycle is still required to update its study in 2027 and every five years thereafter.
Companies should therefore monitor the litigation while continuing to understand which packaging and recyclability claims could be affected.
How Does CalRecycle Determine What Gets Recycled?
One of the most important pieces of SB 343 is CalRecycle's Material Characterization Study.
CalRecycle conducted a statewide analysis at material recovery facilities during 2023 and 2024 to identify materials commonly collected, sorted, sold, or transferred for recycling in California. The resulting Final Findings were published in April 2025.
To organize that information, CalRecycle classifies materials into Material Types and Forms (MT&Fs).
These classifications are considerably more specific than simply identifying a package as “plastic,” “paper” or even “PET.”
For example, CalRecycle distinguishes among categories such as clear PET bottles, pigmented PET bottles, PET thermoformed clamshells and containers, and other PET rigid formats.
The distinction matters because different forms of the same underlying material can behave very differently in real-world collection, sorting and recycling systems.
Once the appropriate MT&F is identified, CalRecycle's findings provide information about how that type and form of material is handled in California's recycling system.
Does Assigning an MT&F Mean a Package Is Recyclable?
No. This is an important distinction.
CalRecycle expressly states that SB 343 does not direct the agency to determine the recyclability of individual products or packaging. Instead, manufacturers and other parties use CalRecycle's published information as part of their assessment of whether a particular product can be considered recyclable for labeling purposes.
CalRecycle also notes that parties may need information beyond what the agency publishes.
That means mapping a package to an MT&F is an important step, but it is not necessarily the end of the analysis.
Consider a clear PET bottle. The package may include:
a PET bottle
a PP closure
a full-body shrink sleeve
printing inks
adhesives
other coatings, treatments or components.
Understanding the base container's material type and form provides part of the picture. Characteristics of the actual packaging configuration can also be relevant to evaluating a recyclability claim.
For companies with large SKU portfolios, this turns SB 343 into a packaging-data problem as much as a regulatory one.
How Does SB 343 Relate to California SB 54?
Packaging teams working on California compliance will likely encounter another classification system: the Covered Material Categories (CMCs) established under SB 54, California's Plastic Pollution Prevention and Packaging Producer Responsibility Act.
The two systems overlap substantially, but they are not currently identical.
SB 54's CMCs classify covered materials according to combinations of material type and form. CalRecycle uses those categories for its packaging EPR program and publishes recyclability, compostability and recycling-rate information for the categories. The January 2026 CMC list applies the categories to detachable components of covered material individually.
SB 343's MT&Fs also classify materials based on material and physical form, but the taxonomy was developed for the Material Characterization Study supporting California's recyclability-labeling framework.
CalRecycle acknowledges the lack of complete alignment. Its SB 343 FAQ states that the agency intends to align SB 343 MT&Fs and SB 54 CMCs to the greatest degree possible in future updates, and CalRecycle says future SB 343 studies will be designed to better align with the SB 54 categories.
An SB 54 Classification Does Not Replace an SB 343 Assessment
This distinction is particularly important for companies already preparing their packaging data for SB 54.
A company should not assume that assigning a package an SB 54 CMC—or seeing that CalRecycle has deemed that CMC recyclable for SB 54 purposes—automatically establishes that a particular package may carry a recyclability representation under SB 343.
The SB 54 CMC determination is made at the category level for purposes of that Act. SB 343 can require consideration of the particular product or packaging and information beyond the category-level characterization.
The good news is that much of the underlying packaging data can support both programs.
Rather than maintaining an “SB 54 spreadsheet” and a separate “SB 343 spreadsheet,” companies can maintain a structured packaging dataset describing what their packaging actually is and then map that information to the appropriate regulatory classifications.
For example:
Clear PET + rigid + bottle + non-CRV + component configuration
can support both:
SB 343 → appropriate MT&F
and
SB 54 → appropriate CMC
even when the two regulatory categories do not perfectly align.
Packaging Compliance Starts With Packaging Data
SB 343 illustrates a broader trend in packaging regulation.
EPR programs, recycled-content mandates, chemical restrictions, recyclability claims and other packaging requirements increasingly depend on detailed information about what a company's packaging actually consists of.
The regulatory questions may differ, but much of the underlying data is the same.
A structured packaging record can support California SB 343 and SB 54 while also providing the foundation for EPR reporting, recycled-content requirements, chemical restrictions and other state packaging obligations.
For companies with large packaging portfolios, the challenge is therefore not simply interpreting each new regulation. It is maintaining the packaging data and supplier evidence necessary to respond to those regulations consistently.
How Cedarline Can Help
Cedarline helps consumer brands build and maintain the component-level packaging data, supplier documentation and regulatory mappings needed to support packaging compliance.
For SB 343, that means helping companies characterize their packaging, organize the underlying information, map relevant packaging to CalRecycle's classifications and identify evidence gaps—giving internal compliance teams and legal counsel a structured foundation from which to evaluate recyclability claims.
Related Articles:
California SB 54: What the Source Reduction Requirements Actually Mean for CPG Companies
What Is Extended Producer Responsibility (EPR), and Why Is It Changing Packaging Compliance?
Who Is the “Producer”? Why One Word Can Determine Your Packaging Compliance Obligations
Supplier Documentation: The Foundation of Modern Packaging Compliance
Disclaimer: This article is intended for informational purposes and does not constitute legal advice. Companies should consult appropriate legal or compliance professionals regarding the application of SB 343 to specific products, packaging or claims.