March 18, 2026

Textile EPR Update: California Selects Landbell USA as PRO as U.S. and Global Requirements Expand

Deepti Gage, Lauren Lankenau, Valentina Sepulveda, Allyn Stern Beveridge & Diamond PC + Follow Contact LinkedIn Facebook X Send Embed

Textile extended producer responsibility (EPR) requirements continue to evolve in the U.S. and abroad, with California now taking a major step and other jurisdictions advancing similar frameworks. Most notably, on February 27, 2026, the California Department of Resources Recycling and Recovery (CalRecycle) selected Landbell USA as the Producer Responsibility Organization (PRO) for California’s textile EPR program under the Responsible Textile Recovery Act (SB 707), triggering key next steps for regulated producers. At the same time, New York continues to pursue textile EPR legislation, and Washington is likely to continue considering textile EPR bills, as the European Union and several European countries move forward with broader textile stewardship requirements.

California Textile EPR

The Responsible Textile Recovery Act requires CalRecycle to select a PRO to develop and operate the compliance, collection, and reporting framework that producers must follow. In line with this mandate, CalRecycle selected Landbell USA as California’s official Textile PRO on February 27, 2026.

Who is Landbell USA and What is Their Role?

Landbell USA’s role builds on its extensive global experience operating PROs across multiple jurisdictions. As of 2024, Landbell USA’s parent, Landbell Group, manages PROs in Austria, Brazil, Canada (Ontario), Denmark, Finland, Germany, India, Ireland, Italy, Israel, the Netherlands, Norway, Poland, Portugal, Slovakia, Spain, Sweden, and the United Kingdom. Across these programs, the scope varies by jurisdiction and covers packaging, batteries, electronics, and textiles.

Under California’s SB 707, Landbell USA is now responsible for operating the state’s EPR system for textiles. This includes producer registration, developing a statewide collection network, and managing the full process for handling textiles, from sorting to reuse, repair, recycling, and disposal of any remaining waste. A key requirement for the PRO is ensuring “free and convenient” collection options across the state. To meet this obligation, Landbell USA must also develop the logistics and infrastructure necessary to collect, sort, reuse, repair, and recycle textiles while minimizing disposal.

Financing the entire system is a core responsibility. Producers will be required to pay initial membership fees and ongoing “eco-modulated" fees, which will be charged based on sales volume and the environmental characteristics of products, including durability, repairability, and recyclability. Essentially, products that are harder to recycle will cost more. Additionally, Landbell USA must ensure transparency and accountability by maintaining registration records, tracking performance metrics, filing annual reports, and providing auditable data that allows CalRecycle to monitor compliance.

What’s Next for Producers in California

Producers must complete the registration process with Landbell USA by July **** 1, **** 2026.

• Who is the “producer”? The statute uses a hierarchy of responsibility:
  • First: the producer is the person who manufactures a covered product and owns or is the licensee of the brand or trademark under which the product is sold, offered for sale, or distributed in or into California. See Cal. Pub. Res. Code § 42984.3(s)(1).
  • If no person fits that definition: responsibility may shift, depending on which entity is present in the state, to:
  • the brand owner;
  • the exclusive licensee of the brand;
  • the importer into California; or
  • the first person to sell, offer for sale, or distribute the product in California.
• Scope of Covered Products: “Covered products” are broader than they may initially appear and include items such as: There are limited exclusions from the definition, including for certain personal protective equipment, reusable absorbent hygiene products, and single-use towel, paper, napkin, and wipe products.

The first step for the PRO is to conduct a needs assessment by March 1, 2027. This assessment will serve as a diagnosis of California’s textile management system. Its objective is to determine existing collection capacity, reuse and recycling infrastructure, geographic coverage, current market conditions, consumer behavior, and education needs. The results will be critical in shaping the program budget and the PRO’s plan, which together will influence the fees imposed on the PRO’s members. CalRecycle will hold a public informational workshop on April **** 7, **** 2026, to provide an overview of the needs assessment, and B&D will attend.

Other National and International Textile EPR Updates

New York is moving forward on textile EPR through Senate Bill S3217A, introduced in January 2025 and carried into the 2026 session. The bill proposes to establish a new EPR Textiles framework that would apply to apparel and textile articles sold in the state, covering both brand owners and certain importers. The proposal would require producers to finance and operate a statewide collection program. In addition, the bill seeks to authorize penalties for producers and representative organizations' non-compliance.

While New York and California EPR systems aim for similar structures, New York’s proposal would phase in a ban on textile disposal at solid waste facilities. In California, the PRO will design measures to minimize the disposal of covered products and a statewide education program to avoid improper disposal of such products.

In January 2025, Washington State lawmakers introduced HB 1420, proposing to create a statewide EPR program for textiles and apparel. As of mid-March 2026, the bill is still in committee and will not go to the Governor for signature. As this is the second time the Washington Legislature has considered a textile EPR bill, we expect lawmakers to revisit this legislation in the next session.

As discussed in our January 2026 alert on the EU Waste Framework Directive, the European Union is also moving decisively forward toward mandatory textile EPR across all Member States. Member States have until June 17, 2027, to apply the targeted revision into national laws and until April 17, 2028, to establish EPR schemes for textile and footwear products.

Some EU countries are already ahead: France has operated a national textile EPR system since 2008, and the Netherlands launched its program in 2023. Spain is also progressing, having published a draft decree for public comment in 2025 and now refining it internally.

By contrast, the United Kingdom has not yet introduced a textile EPR regime; however, ongoing policy efforts signal that textiles are a priority in the government’s forthcoming Circular Economy Growth Plan. Current discussions highlight the sector’s potential to generate skilled green jobs and drive sustainable product design. These opportunities are reflected in the Waste and Resources Action Programme’s (WRAP) analysis “Blueprint for a UK Textiles EPR scheme,” which outlines key recommendations for how a future UK system could support circularity.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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