California's SB 343 labeling restrictions now apply to packaging manufactured after Oct. 4, 2026, per CalRecycle — but a July preliminary injunction largely blocks enforcement, leaving brands to plan compliance against an unsettled legal backdrop.

The 2021 law cracks down on recyclability symbols, especially the chasing arrows. To call a material recyclable in California, it must be collected in programs serving at least 60% of the state's population and sorted by facilities serving at least 60% of statewide recycling programs, among other parameters. Those material-specific determinations also feed into the extended producer responsibility program created by 2022's SB 54.

The enforcement picture stays muddy. The injunction doesn't eliminate private litigation risk for non-compliant businesses, and brands are already changing packaging decisions in response.

What does the injunction actually change?

Not much for the groups building compliance infrastructure. The Association of Plastic Recyclers built its APR Design Assessment Tool to evaluate whole plastic packages against SB 343 criteria. How2Recycle rolled out How2Recycle Pro labels designed specifically to comply with the law.

When the injunction landed, How2Recycle told members the court's action didn't shift its plans. That position holds, How2Recycle Director Emily Williams told Packaging Dive last week, despite members' significant confusion over what the ruling means and what happens next.

"Until there's additional clarity on the path for that law through that suit that's ongoing, then our position right now is continue to plan to be compliant," Williams said.

The takeaway: enforcement may be paused, but compliance planning isn't.

How are brands responding?

The numbers point in two directions. How2Recycle's inbound label requests are up 29% year over year — Williams attributes that partly to comfort in shared methodology. "I think there's some comfort in safety in numbers of everyone utilizing the same labeling system that has a known methodology," she said.

The organization has processed roughly 35,000 label requests this year as users transition to the How2Recycling Pro label. Some members' packaging has shifted from "widely recyclable" to "check locally" designations under SB 343 criteria.

At the same time, hesitation is visible:

• Some companies are delaying new labeling decisions until California clarifies the legal path.
• Member companies can print the label on some products and not others — a risk-management choice, in Williams' words: "That's how their organization has decided to manage their risk, and that is their choice."

Suppliers feel the freeze too. SB 343 introduced "a whole new level of burden of proof" for recyclability, said Sarah Paleg, director of sustainability in Amcor's flexibles business, during an SB 343 paper packaging panel at SPC Advance in California last week.

Paleg called the policy "paralyzing change" for certain formats like flexible paper. Prospective clients interested in switching formats for sustainability benefits get discouraged by uncertainty over how such packaging is classified in California and whether it can carry a recyclability claim.

The net effect: the law is pushing some labels forward while freezing others in place.

Does consumer behavior factor in?

The Sustainable Packaging Coalition, housed under nonprofit GreenBlue alongside How2Recycle, shared new research at SPC Advance. In a 1,000-person survey, 53% of U.S. respondents said they rely on ingrained habits to decide how to dispose of packaging, while 54% said clearer, more visible instructions would grab their attention.

That data keeps on-pack guidance central to the compliance calculus — exactly what SB 343 regulates.

What happens next in court and Congress?

The Flexible Packaging Association, the American Forest & Paper Association and other business groups filed the federal lawsuit in March, arguing SB 343 restricts free speech. After the July injunction, environmental nonprofits Californians Against Waste and the Earth Island Institute sought to intervene — the court denied that request last week.

A case management conference and early neutral evaluation are scheduled for Nov. 4.

In parallel, industry groups are pursuing a federal override. Ameripen backs the Pack Act in Congress, which would preempt state laws like SB 343 by amending the Federal Trade Commission Act to set requirements for recyclable, compostable and reusable claims — including third-party certification for packaging bearing a chasing arrows symbol. On Sept. 16, the Committee on Energy and Commerce voted to advance the bill to the full House.

The Nov. 4 court conference and the Pack Act's House trajectory will decide whether manufacturers face one national labeling standard or California's 60% thresholds.