Litigation | CA
On June 2, 2026 Oceana, the Natural Resources Defense Council, and the Californians Against Waste Foundation filed suit against CalRecycle in San Francisco Superior Court, captioned Natural Resources Defense Council, Inc. v. Department of Resources Recycling and Recovery, challenging the SB 54 final regulations that took effect May 1, 2026. The petition is verified, which means CalRecycle must answer allegation by allegation rather than by general denial; the case number is not publicly confirmed. The petitioners allege the regulations create unauthorized carveouts that exclude large categories of plastic packaging, allow producers to claim indefinite exemptions, and let permitted technologies that generate hazardous waste count as recycling, undermining the law's source-reduction and recycling mandates. This is a challenge from the environmental side, distinct from the June 22, 2026 challenge brought by 17 state attorneys general and NAW; SB 54 now faces challenges from both directions. Source: Resource Recycling (June 5, 2026); Oceana; NRDC; National Law Review (June 2026).
Enforcement | OR
On April 9, 2026 Oregon DEQ released its inaugural quarterly producer status list under the Recycling Modernization Act, flagging roughly 250 companies for failing to register, report, and/or pay required fees. Each producer was first contacted by the Circular Action Alliance and given 90 days to respond; nonresponders then received a formal DEQ notice and an additional 30-day cure window before being listed. Penalties can reach $25,000 per day, and the Oregon Department of Justice may seek to bar the sale of noncompliant products in the state. The February 6, 2026 NAW preliminary injunction shields only NAW members as of that date; all other producers remain fully subject to enforcement. Source: Resource Recycling (April 21, 2026); Troutman Pepper Locke (April 2026); Oregon DEQ.