California’s SB 343 recycling labelling law establishes criteria for recycling symbols and recyclability claims on products and packaging. For cosmetic brands, compliance involves more than selecting a potentially recyclable material: closures, pumps, labels, adhesives and other components can also affect the assessment.
Often called the “Truth in Recycling” or “Truth in Labelling” law, SB 343 links recyclability claims to collection, sorting, design and composition criteria. A technically recyclable plastic does not automatically qualify for a recyclable label.
What Is California SB 343?
SB 343 aims to prevent misleading recyclability claims. Its scope extends beyond the familiar chasing arrows symbol to other statements and symbols indicating that a product or package is recyclable.
Brands should therefore review written claims and recycling instructions as well as logos. The assessment should establish exactly which product or packaging component each claim describes. California Public Resources Code §42355.51
SB 343 Compliance Date and Preliminary Injunction
CalRecycle identifies products and packaging manufactured after 4 October 2026 as subject to the labelling restrictions. This is a manufacturing-based threshold, rather than a universal deadline for selling existing stock.
On 14 July 2026, a federal court issued a preliminary injunction blocking enforcement of SB 343. The injunction does not permanently repeal the law. CalRecycle notes that litigation may affect the compliance deadline, while its study update obligations continue. SB 343: Accurate Recycling Labels – CalRecycle Home Page
How Is Recyclability Assessed Under SB 343?
Collection and Sorting Criteria
The standard assessment pathway includes two distinct coverage thresholds:
- Collection programmes must collectively serve at least 60% of California’s population.
- Relevant sorting facilities must collectively serve at least 60% of the state’s recycling programmes.
These figures do not mean that 60% of a particular package is actually recycled. The law also provides alternative assessment pathways under specified conditions.
Packaging Design and Component Compatibility
For plastic packaging, the assessment considers whether components, inks, adhesives or labels prevent recycling under the APR Design® Guide.
A PET bottle should therefore not be labelled recyclable solely because its main body is PET. Equally, the presence of another material does not automatically establish non-compliance: the actual design and relevant recycling stream need to be assessed. APR: PET packaging design guidance
Chemical Composition Requirements
Relevant composition conditions include PFAS provisions for plastic and fibre-based materials, alongside other chemical restrictions referenced in the legislation. Material specifications should therefore be included in the packaging assessment.
Which Packaging Materials Need Closer Review?
CalRecycle’s sorting table, updated on 24 June 2026, shows different outcomes for specific PET, HDPE and PP formats compared with many flexible plastic formats. PVC, PS and several film categories show limited or no sorting coverage.
However, inclusion in a favourable sorting category is not product-specific approval to use a recycling label. Collection data, material format and applicable design conditions must also be considered. CalRecycle: Updated Table 2
Why Does SB 343 Matter for Cosmetic Packaging?
Cosmetic packaging frequently combines materials to protect formulations, improve dispensing or create a particular appearance. These features can complicate recyclability assessments.
| Packaging format | Key assessment points |
| Sample sachets and refill pouches | Collection and sorting coverage; flexible and multilayer construction |
| Multilayer tubes | Barrier materials, layer proportions and recycling compatibility |
| Airless containers and pumps | Metal springs, mixed plastics and component separability |
| Jars and multi-component containers | Compatibility of the body, closure, seal and applicator |
| Labelled plastic bottles | Label material, coverage, inks and adhesives |
How Should Cosmetic Brands Prepare for SB 343?
While litigation continues, brands can take practical steps to improve the evidence supporting their packaging claims:
- Create a packaging inventory: Include bodies, closures, pumps, seals, labels and barrier layers.
- Review recycling claims: Identify which component each symbol or statement refers to.
- Collect supplier documentation: Request material specifications, design evidence and composition information.
- Identify the correct material format: Do not rely solely on resin names such as PET, PP or HDPE.
- Document labelling decisions: Retain the technical basis for each recyclability claim.
- Monitor legal and CalRecycle updates: Align artwork and production decisions with the current enforcement position.
Contact Obelis to discuss the labelling and regulatory compliance needs of your cosmetic packaging.
Frequently Asked Questions
Does SB 343 ban all recycling symbols?
No. It makes recycling symbols and recyclability claims conditional on specific criteria. Enforcement is also affected by the preliminary injunction.
Is PET packaging automatically eligible for a recyclable label?
No. The material format, packaging components and applicable assessment criteria must also be considered.
Can refill packaging be labelled recyclable?
Refill functionality does not establish recyclability. The pouch or container requires a separate assessment of its construction and compatibility with relevant recycling systems.