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California EPR – Responsible Textile Recovery Act (SB 707)

Key Highlights
Purpose & Scope
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Establishes an Extended Producer Responsibility (EPR) framework for textiles sold in California.
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Shifts responsibility for textile waste management to producers/importers/brand owners.
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Aims to increase reuse, recycling, circularity, and reduce landfill/incineration of textiles.
Who Is a “Producer”?
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Brand owner or trademark holder selling textiles in California.
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Importers or distributors if the brand owner is not based in the U.S.
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Retailers selling private-label or exclusive brands.
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E-commerce sellers included if they sell into California.
Covered Products
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Apparel (all categories).
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Home textiles: sheets, towels, bedding, curtains, rugs.
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Accessories: bags, backpacks, soft luggage.
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Footwear, uniforms, and textile-based gear.
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Exceptions: carpets, mattresses, and certain industrial textiles already covered by other EPR laws.
Producer Requirements
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Join or create a Producer Responsibility Organization (PRO).
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Pay annual EPR fees based on volume and type of textiles sold.
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Develop and implement a statewide textile recovery plan including:
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Textile collection and drop-off network.
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Sorting and reuse systems.
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Recycling infrastructure (mechanical, chemical, T2T).
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Reporting, auditing, and performance metrics.
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Mandatory Goals & Performance Metrics
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Increase textile reuse, repair, and recycling rates.
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Reduce disposal to landfill or incineration.
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Establish equitable access to collection points.
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Support domestic recycling market development.
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Annual reporting to CalRecycle on progress, tonnage, recovery outcomes.
Implementation Timeline
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2025–2026: PRO formation, program design, registration.
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2027: Program launch; collection network operational.
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2027–2030: Increasing recovery, recycling, market-development requirements.
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Full implementation by 2030, including annual audits and compliance reviews.
Compliance Obligations for Brands
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Submit SKU-level product data to PRO.
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Pay EPR fees tied to product type, material content, and volume.
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Labeling or consumer education as defined by PRO.
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Maintain full documentation for audits.
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Prohibited from selling textiles in CA if not in compliance.
Penalties
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Fines for non-compliance, inaccurate reporting, or failing to join a PRO.
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Potential restrictions on product sales in California for repeat violations.
Impact for Retailers, Manufacturers & Supply Chains
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Increased demand for recycled inputs, especially T2T rPET, MMCF, and mechanically recycled cotton.
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Need for SKU-level traceability and material transparency.
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Strong push toward design for recyclability and mono-material constructs.
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Supplier capability audits and alignment for EPR readiness.
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Opportunity for long-term offtake agreements, circular design partnerships, and local recycling investment.
Strategic Opportunities
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Early movers gain advantage in:
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Material certification and recycled content strategy.
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Closed-loop partnerships (collect–sort–recycle).
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Data/PLM integration for EPR reporting.
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Consumer-facing circular programs (repair, resale, recommerce).
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Potential for reduced fees through eco-modulated fee structures (design choices that improve recyclability).
LoopLab Support Capabilities
Circular products and material design enablement.
• Recyclability engineering and mono‑material optimization.
• ESPR, DPP, and California EPR compliance readiness frameworks.
• Supplier capability assessments and governance systems.
• Data model alignment for PLM, EPR reporting, and DPP integration.
• EPR fee modeling, eco‑modulation optimization, and risk mitigation.
• Roadmap creation, cross-functional training, and implementation support.