Retail Regulatory Updates | March 2026

Dive into regulations reshaping the retail industry and discover how you can turn compliance into a competitive advantage.

This Week's Contributor

Tonya Read Project Manager, Permitting and Compliance APTIM | Environmental & Sustainability Solutions Email

Spotlighting Retail Regulatory Shifts

Ongoing regulatory changes continue to impact retail businesses. Staying informed is essential for ensuring compliance, risk mitigation, and maintaining a competitive edge in a dynamic marketplace. APTIM provides expert guidance to help businesses navigate evolving regulations and develop tailored compliance strategies to remain ahead of emerging requirements.

Navigating the latest regulations doesn’t have to be complicated. With the right support, you can stay compliant, reduce risk, and keep your business moving forward. Whether you need support understanding emerging legislation or developing a proactive compliance plan, APTIM is here to help.

Drinking Water

Illinois — Primary Drinking Water Standards (35 Illinois Administrative Code Part 611): Illinois updated its Primary Drinking Water Standards 35 Illinois Administrative Code, Part 611, enacted January 22, 2026, to align state requirements more closely with recent federal drinking water regulations. The amendments address monitoring, analytical testing methods, and reporting obligations associated with per- and polyfluoroalkyl (PFAS) substances, reflecting Illinois’ ongoing efforts to harmonize with US Environmental Protection Agency (EPA) drinking water rulemakings. The revisions incorporate updated monitoring and reporting expectations for public water systems (PWSs) and support implementation of emerging PFAS regulatory standards. Although certain “effective date” provisions previously included within Part 611 have been repealed, Illinois continues to adopt PFAS-related groundwater and drinking water standards through ongoing regulatory updates administered by the Illinois Perorational impacts for retail stores and distribution centers are generally indirect and arise primarily when facilities operate non-transient, non-community public water systems, such as private wells serving large campuses or distribution facilities. In those circumstances, facility operators may be subject to enhanced monitoring, sampling, reporting, and consumer notification requirements under the revised standards. Data centers typically experience limited direct impact unless they operate their own campus PWS. Facilities served by municipal water systems may experience indirect effects as public utilities implement PFAS monitoring and treatment requirements, which may influence water system communications, infrastructure upgrades, and associated service costs.
Enacted: 01/22/2026
Compliance: Monitoring and reporting by April 2027; maximum contaminant level (MCL) compliance by April 2029
Wisconsin — Drinking Water Standards (NR 809; PFAS & Technical Revisions) (Clearinghouse Rule CR 25‑068): Wisconsin updated its drinking water regulations under Wisconsin Administrative Code NR 809 through Clearinghouse Rule CR 25-068, approved by the Governor on February 26, 2026. The revisions incorporate new maximum contaminant levels for PFAS, update analytical testing methods, and make technical corrections to maintain consistency with federal Safe Drinking Water Act (SDWA) requirements. The amendments adopt federal MCLs for perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHxS), perfluorononanoic acid (PFNA), and hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX). The rule also establishes a Hazard Index–based MCL for certain PFAS mixtures, reflecting federal regulatory approaches designed to address cumulative PFAS exposure risks. According to the Wisconsin Department of Natural Resources (DNR), the rule is expected to become effective in spring or summer 2026 following completion of gubernatorial approval and legislative review procedures. For retail stores and distribution centers, the revised NR 809 rule does not generally create direct compliance obligations unless the facility operates its own public water system (PWS), most commonly a private well meeting regulatory PWS criteria. In those cases, facility operators should prepare for PFAS monitoring, sampling, reporting, and potential treatment actions if contaminant levels exceed established MCLs. Data centers face similar considerations. Facilities served by municipal water systems will experience minimal direct regulatory impact but may receive updated consumer confidence reports or supplier notifications as public water utilities implement PFAS monitoring and treatment requirements. Facilities operating private wells that qualify as PWSs must evaluate sampling obligations and potential treatment strategies to ensure compliance once the rule becomes effective.
Enacted: 02/26/2026
Compliance: Spring–Summer 2026 (Upon final rule effectiveness)

Energy & Sustainability

New Jersey — End‑of‑Life Recycling for Solar & Photovoltaic (PV) Facilities (S.3399): New Jersey enacted Senate Bill (S.) 3399 on January 12, 2026, establishing mandatory end-of-life removal, recycling, and management requirements for solar and photovoltaic (PV) energy generation facilities and associated equipment. The law requires owners of solar or PV installations to decommission, remove, and properly recycle system components and related infrastructure once the equipment reaches the end of its useful life. The statute also requires secure storage of hazardous or toxic components that cannot yet be safely recycled until approved recycling methods become available. Implementation of the law will occur through regulations adopted by the New Jersey Department of Environmental Protection (DEP), which must establish minimum standards for removal, recycling, and storage of PV system components. Retail stores and distribution centers operating rooftop or canopy PV systems may experience new planning and financial considerations associated with long-term system lifecycle management. Facilities may need to develop decommissioning plans, establish contracts with qualified recycling vendors, and maintain documentation supporting chain-of-custody procedures for removed PV equipment. Data centers, many of which operate on-site solar generation systems in combination with battery storage, may need to incorporate these requirements into asset management inventories, long-term financial reserve planning, and vendor service agreements. Facilities should also evaluate take-back arrangements and ensure appropriate handling and storage procedures for PV components that contain hazardous materials until approved recycling pathways are available.
Enacted: 01/12/2026
Compliance: 07/11/2026

Fire Code

Rhode Island — Life Safety Code (Part 8; NFPA 101, 2021 Edition): Rhode Island updated its Life Safety Code (Part 8) to adopt the National Fire Protection Association (NFPA) 101, Life Safety Code, 2021 edition, effective March 1, 2026. The revision is part of broader state fire code updates that also incorporate NFPA 1 (2021 edition) and NFPA 72 (2022 edition). Part 8 establishes core life safety requirements applicable to new and existing buildings, including provisions addressing means of egress, fire detection and alarm systems, building services and fire protection equipment, special structures, and mixed-use occupancies. The 2021 edition introduces clarified egress requirements, expanded performance-based design options, updated occupancy classifications, and revisions across mercantile, business, industrial, and storage occupancy chapters. Retail stores may experience operational impacts related to updated requirements for egress pathways, fire detection and alarm system specifications, and mixed-use occupancy provisions, particularly during renovations, tenant improvements, or building reconfigurations that must comply with the adopted code edition. Retail distribution centers and data centers should review applicable provisions within the business, industrial, and storage occupancy chapters, including updated expectations related to elevator safety, fire alarm system performance, impairment procedures, and fire protection features for battery storage areas. Certain provisions reference NFPA 855, Standard for the Installation of Stationary Energy Storage Systems, which may affect facilities operating battery energy storage systems. These updates may necessitate reassessment of facility layouts, fire protection system capabilities, and emergency response procedures to maintain compliance with the updated Life Safety Code.
Enacted: 03/01/2026
Compliance: 03/01/2026

Fuel Stations & Underground Storage Tanks

California — Underground Storage Tanks (USTs) Full Chapter Rewrite (23 CCR, Division 3, Chapter 16): California implemented a comprehensive revision to Title 23, California Code of Regulations (CCR), Division 3, Chapter 16, governing underground storage tank (UST) systems, effective January 1, 2026. The State Water Resources Control Board adopted this chapter-wide rewrite to modernize regulatory requirements addressing UST system design, construction, monitoring, testing, inspections, release reporting, closure, and corrective action. The revisions align regulatory provisions with current technologies, eliminate obsolete requirements, including references to single-wall UST systems, and reorganize the chapter into clearer, topic-based articles. The update also revises definitions, updates violation classifications, and introduces enhanced inspection and recordkeeping expectations. In addition, the amendments update associated testing, reporting, and operator training forms contained within the regulatory appendices. Where feasible, prescriptive provisions have been replaced with performance-based standards to provide greater flexibility while maintaining environmental protection objectives. Retail facilities operating fueling stations and distribution centers with on-site fueling infrastructure must review UST monitoring systems, leak detection technologies, operator certification requirements, and updated testing and reporting forms. Facilities should ensure that operational procedures, inspection programs, employee training, and recordkeeping practices align with the reorganized regulatory structure and revised compliance expectations. Data centers operating diesel USTs supporting emergency generator systems should evaluate updated inspection, testing, closure, and release reporting requirements. The revised regulations establish more detailed expectations for release detection equipment, containment testing, and documentation practices. Although many data centers rely on aboveground fuel storage systems, facilities operating USTs must ensure that internal procedures align with the updated inspection, reporting, and corrective action requirements contained in the revised chapter.
Enacted: 01/01/2026
Compliance: 01/01/2026

Hazardous Waste, Universal Waste & E-Waste

Colorado — Hazardous Waste Generators: Exception Reporting & e‑Manifest (6 CCR 1007-3, Part 262): Colorado updated hazardous waste generator requirements under 6 Code of Colorado Regulations (CCR) 1007-3, Part 262, effective January 14, 2026, addressing exception reporting procedures when a hazardous waste manifest is not returned by the receiving facility. Under 6 CCR 1007-3 § 262.42, Large Quantity Generators (LQGs) must contact the transporter and/or receiving facility if a returned manifest is not received within 35 days and must submit an Exception Report if the manifest remains outstanding after 45 days. Small Quantity Generators (SQGs) must submit an Exception Report if the manifest is not returned within 60 days. In parallel, federal e-Manifest program requirements administered by the EPA establish that, beginning December 1, 2025, EPA will no longer accept mailed paper exception reports from SQGs or LQGs. All Exception Reports must instead be submitted electronically through the EPA e-Manifest system within RCRA Info. This change requires generators to update internal procedures, staff responsibilities, and system permissions associated with e-Manifest reporting. Retail stores and distribution centers that generate hazardous waste from materials such as aerosols, paints, corrosives, and other regulated products must ensure that Exception Reports are submitted electronically when manifests remain unconfirmed after applicable regulatory deadlines (60 days for SQGs and 45 days for LQGs). Facilities should review internal waste shipment tracking procedures, employee training programs, and compliance monitoring practices to confirm alignment with Colorado’s Part 262 requirements and federal e-Manifest reporting procedures. Data centers typically generate hazardous waste less frequently; however, projects involving battery replacements, uninterruptible power supply (UPS) system upgrades, electronic equipment disposal, or chemical-based cooling or refrigeration maintenance may temporarily result in SQG or LQG status. Facilities should confirm that RCRA Info and e-Manifest accounts are properly configured and accessible, enabling timely electronic submission of Exception Reports if a hazardous waste manifest is not returned within required timeframes.
Enacted: 01/14/2026
Compliance: 01/14/2026

Solid Waste & Recycling

Connecticut — Out‑of‑State Beverage Container Redemption Controls (SB 299): Connecticut enacted Senate Bill (SB) 299 on March 3, 2026, revising the state’s beverage container redemption program to strengthen fraud prevention, regulatory oversight, and financial accountability. The law replaces the previous registration system with a mandatory licensing program for redemption centers, requiring submission of detailed applications and payment of a $2,500 licensing fee beginning July 1, 2026.The statute also establishes enhanced operational controls, including expanded recordkeeping requirements, quarterly reporting obligations, limits on high-volume daily container returns, and prohibitions on acceptance of out-of-state or previously redeemed beverage containers. The amendments also modify handling fee structures and financial remittance timelines applicable to deposit initiators. Collectively, these measures are intended to reduce fraudulent redemption activity, improve transparency within the container deposit system, and strengthen enforcement authority. Retail stores that operate beverage container redemption services may experience operational impacts due to the revised licensing, intake control, and documentation requirements. Facilities may need to implement updated procedures to verify container eligibility, manage daily return volumes, and maintain compliant records. Retailers may also need to coordinate more closely with distributors and deposit initiators to support accurate reconciliation of redeemed containers. Distribution centers are generally unaffected unless they directly operate beverage container redemption functions. Data centers are not expected to experience operational impacts because the requirements apply exclusively to beverage container redemption operations.
Enacted: 03/03/2026
Compliance: 07/01/2026
New York — Rechargeable Battery Recycling (S.8832, Chapter 87): New York enacted Senate Bill (S.) 8832 (Chapter 87 of the Laws of 2026) on February 13, 2026, updating provisions of the state’s Environmental Conservation Law governing rechargeable battery recycling. The amendments refine statutory definitions, expand manufacturer responsibilities, strengthen fire safety and battery handling standards, and require additional studies addressing collection and recycling of batteries used in electric mobility devices. The New York State Department of Environmental Conservation (DEC) has updated program guidance to reflect these changes. Under the revised framework, retailers selling rechargeable batteries or battery-containing products must accept used rechargeable batteries of similar shape, size, function, and weight for recycling. Acceptance of batteries used in electric bicycles (e-bikes) and electric scooters (e-scooters) remains voluntary. The revisions are intended to expand consumer access to battery recycling programs, improve safe battery handling practices, and increase producer accountability within the state’s battery stewardship system. Retail stores must comply with mandatory take-back requirements for covered rechargeable batteries and battery-containing products, except where acceptance of e-bike or e-scooter batteries is voluntary. Retailers must also adhere to strengthened fire-safe storage, handling, and consumer education requirements associated with battery collection programs. Retail distribution centers and data centers are generally not classified as retailers and therefore do not have direct take-back obligations under the law. However, facilities managing internal battery inventories should review and update standard operating procedures (SOPs) governing the safe handling, consolidation, storage, and transportation of rechargeable batteries, particularly lithium-ion devices, to maintain safe and compliant battery management practices.
Enacted: 02/13/2026
Compliance: 02/13/2026

Transportation & Fleet

Virginia — Hazardous Materials Transport Through Bridge‑Tunnel Facilities (24VAC30‑61): Virginia revised 24 Virginia Administrative Code (VAC) 30-61, governing the transportation of hazardous materials through the state’s bridge–tunnel facilities, effective February 25, 2026. The amendments reorganize and clarify requirements applicable to hazardous materials transport through six major bridge–tunnel corridors. The rule distinguishes rural tunnel facilities, including the Interstate 77 Big Walker Mountain Tunnel and East River Mountain Tunnel, from urban or water-adjacent tunnels serving the Hampton Roads region, including the Hampton Roads Bridge–Tunnel, Monitor–Merrimac Memorial Bridge–Tunnel, and the Elizabeth River Downtown and Midtown Tunnels. The revisions remove outdated regulatory language and align state routing requirements with current federal hazardous materials transportation standards. Under the updated framework, rural tunnel facilities generally follow standard federal and Virginia hazardous materials transport regulations without additional state-specific restrictions. In contrast, urban or water-adjacent tunnels may continue to impose restrictions on certain hazardous material shipments, including routing limitations, escort requirements, or time-of-day operational controls. Retail distribution centers shipping hazardous materials, including aerosols, flammable liquids, or corrosive materials, should confirm whether freight routes pass through Hampton Roads–area tunnels and verify that carriers comply with applicable routing requirements and restrictions. Logistics planners should ensure that carriers understand any prohibited material classifications or scheduling limitations that may apply within restricted tunnel corridors. Retail stores and data centers are expected to experience minimal direct operational impact because the regulation primarily applies to hazardous materials transporters rather than facility operators. However, organizations that arrange or coordinate freight shipments containing regulated hazardous materials should verify that contracted carriers follow compliant routing practices and remain aware of potential emergency restrictions or temporary operational controls issued by the Virginia Department of Transportation (VDOT).
Enacted: 02/25/2026
Compliance: 02/25/2026

Need Help with Compliance?

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Published March 2026

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