SB 707 Implementation Briefing #2: Pro Updates and Informal Rulemaking Process Underway.
Part of the American Circular Textiles Implementation Briefing Series
PRO Updates.
Landbell USA Board of Directors
As a key part of implementing California’s Responsible Textile Recovery Act of 2024 (SB 707), CalRecycle selected Landbell USA in February 2026 to act as the sole Producer Responsibility Organization (PRO) for used textiles. An updated Board of Directors includes representatives of large national brands, California retailers, and other related stakeholders. For a complete updated list of Board members, click here.
Producer Registration
The deadline for producer registration was July 1, 2026. Producers that have not yet registered are encouraged to do so as soon as possible. The July 1, 2026 deadline established under SB 707 has passed, and registration with the approved PRO, Landbell USA, is required under the law. The flat fee for registration for July 1, 2026 through June 30, 2027 is $1,000. Landbell has said that these funds will help offset the costs of the required Needs Assessment.
Any covered producers not registered after this date risk penalties for noncompliance, with fines of up to $10,000 for each day of noncompliance. Registration is ongoing - obligated producers can still register at any time here.
If you are uncertain as to whether or not you are required to register as a producer, Landbell USA has a page dedicated to Producer Support and FAQs that can be found here.
Needs assessment contractor selection
SB 707 requires that the selected PRO undertake a Needs assessment to inform the Program Plan. The final needs assessment is due to CalRecycle by March 1, 2027.
According to the Landbell USA website,
The Department of Resources Recycling and Recovery (CalRecycle) held a needs assessment informational public workshop on April 7, 2026.
CalRecycle and Landbell USA provided key updates and engagement pathways for interested stakeholders to be involved in the PRO needs assessment operation and took questions from a large audience in the workshop. Landbell USA also announced that they are outsourcing the needs assessment operation to a third-party contractor and are conducting a public request for proposal (RFP) process.
Landbell USA has had robust engagement with various stakeholders, parties of interest and needs assessment RFP contractors. Our engagement with these interested parties is ongoing and has been remarkably insightful and resourceful.
As of October 14, 2026, the third-party contractor has not yet been announced. We will update the SB 707 Implementation Tracker when an announcement and further details have been released. Those interested in supporting the needs assessment process are encouraged to contact Landbell USA at landbellusa.support@landbellgroup.com.
CalRecycle Rulemaking Activity.
Rulemaking Process
CalRecycle is responsible for adopting regulations to create the rules for California’s EPR implementation. Through spring 2027, CalRecycle will hold a series of public workshops to get feedback on possible regulatory language. Once this exercise is complete, the agency will draft the proposed regulation and submit it to the Office of Administrative Law for review and publication in the California Regulatory Notice Register (the Z Register), which officially opens the public comment period. Once regulations are published in mid-2027, the process will become more formalized as CalRecycle reviews public comments and makes necessary changes to the proposed regulations. CalRecycle is required to respond to each official comment submitted through this formal process. After a thorough review, the regulations can go into effect no earlier than July of 2028.
Informal Rulemaking Process and Workshops
Through spring of 2027, CalRecycle is planning a series of informal regulatory workshops to gather feedback on proposed regulatory concepts related to the requirements outlined in SB 707.
Previous workshops with covered topics
The first was held on August 13, 2026 and focused on definitions, online marketplaces, and PRO Submittals. CalRecycle allowed public comments during the workshop, and requested that all written comments be submitted by August 27, 2026.
On September 29, 2026, the second workshop was held, and focused on Responsible End Markets, Reuse, and Repair, as well as Convenient Collection System and Producer Identification and Exemptions. The discussion document for the workshop can be found here. CalRecycle has requested that all written comments be submitted by October 13, 2026.
Upcoming Workshops with covered topics
All Textile Stewardship Informal Regulatory Concepts Workshops are hybrid meetings, with options to participate including in-person attendance, Zoom attendance, or viewing a live stream of the workshop. Public comments will be taken from those in-person as well as those attending via Zoom. Detailed information about how to participate can be found in the Agenda/public Notice for each workshop found below.
November 12, 2026 from 10:00 AM to 5:00 PM PT
Topics to include:
Producer Responsibility Plan
Contingency Plan
Plan Termination
Plan Revocation and Cessation of PRO Status
Annual Report
Legal Challenges.
Lawsuit challenging Landbell USA’s selection as California’s PRO
Initial Filing
On March 27, 2026, the American Apparel and Footwear Association (AAFA) filed suit against CalRecycle challenging the selection of Landbell USA as the SB 707 PRO. Landbell USA is named as a Real Party in Interest, not as a named defendant. AAFA was part of a coalition, along with California Retailers Association (CRA) and the National Retail Federation (NRF), that created a competing PRO application to serve as the SB 707 PRO. Neither CRA or NRF chose to participate in the legal challenge.
In its initial filing and subsequent revisions, AAFA claims that:
“CalRecycle was without authority to approve—and abused its discretion in approving—Landbell USA as the PRO. The statute requires the approved PRO be formed by producers of covered products. Landbell USA was not formed by producers and does not represent producer interests. Instead, it was formed by a foreign EPR service provider and management company, Landbell Group.”
Motion for Preliminary Injunction
On April 10, AAFA filed for a preliminary injunction, which is a temporary court order made early in a lawsuit that stops a party from doing a disputed action to keep things as they are until the case is resolved. AAFA cited the "irreparable harm” that would be done to AAFA and its membership if the court allowed SB 707 implementation to continue while the court case is being adjudicated. After the hearing was scheduled for August 7, 2026, AAFA filed an application to advance the hearing to an earlier date. On April 24, 2026, the request to move the date of the hearing forward was denied by the court.
On August 7, 2026, the court held a hearing on the matter of the preliminary injunction. On September 17, the court rejected the request for preliminary injunction. In its decision, it agreed that AAFA has standing to file, but ruled that AAFA would not suffer irreparable harm without the preliminary injunction. Rather, the court said that it found that irreparable harm would occur to the public if the SB 707 implementation were halted at this time. Finally, the court found that “for purposes of the present motion, that Petitioner has failed to establish a likelihood of success on the merits”.
Next Steps
A hearing on the original legal challenge has been scheduled for March 12, 2027. On September 28, 2026, AAFA filed a “Letter Requesting Continuance of Hearing Date,” asking the court to assist in moving the hearing to an earlier date. In its letter, AAFA characterized the respondents’ position as a lack of cooperation; CalRecycle responded on October 1, disputing this assertion. On October 12, the Court confirmed the hearing date of March 12, 2027.
SB 707 Implementation Tracker.
American Circular Textiles maintains a public SB 707 Implementation Tracker compiling key milestones, emerging implementation questions, and recent clarifications related to the program.
The tracker is updated periodically and is intended to provide a neutral reference point for companies, policymakers, and other stakeholders following SB 707 implementation.
About American Circular Textiles.
American Circular Textiles is an independent U.S. policy intelligence and engagement platform focused on the regulatory, market, and infrastructure developments shaping textile circularity.
The organization convenes brands, resale platforms, recyclers, technology providers, and other stakeholders to support informed engagement with evolving policy frameworks affecting the textile and apparel sector.
Contact.
Organizations following SB 707 implementation or interested in engaging with American Circular Textiles on textile EPR policy developments may contact: policy@americancirculartextiles.com
Media inquiries: press@americancirculartextiles.com
