Retail Regulatory Updates | November 2025

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.

Hazardous Waste/Universal Waste

Maryland Hazardous & Universal Waste Updates (COMAR 26.13):
Maryland’s revised hazardous waste regulations under the Code of Maryland Regulations (COMAR) 26.13 introduce significant updates designed to align state standards with federal environmental protections. Among the most notable changes is the prohibition the of bulk liquid hazardous waste disposal in landfills, reinforcing containment and transport requirements for facilities such as distribution centers that manage these materials. Facilities must ensure proper packaging, labeling, and secure transport in accordance with updated hazardous waste generator standards. The regulation also adds aerosol cans to the list of universal wastes, simplifying their management while maintaining environmental safeguards. Retailers are required to segregate aerosol cans from other waste streams and manage them under universal waste protocols, which specify requirements for storage, labeling, and disposal. These updates are part of Maryland’s broader effort to modernize its hazardous waste framework, which also includes revisions to the ignitability characteristic definition, conditional exclusions for solvent-contaminated wipes, and new standards for hazardous waste pharmaceuticals.
Enacted: 10/04/25
Compliance: 10/04/25

Fire Code

Ohio Fire Code Updates (OAC 1301:7-7-03):
The 2025 update to the Ohio Fire Code introduces significant revisions to general fire safety requirements under Rule 1301:7-7-03, aligning state standards with the latest International Fire Code provisions while maintaining Ohio-specific modifications. These changes emphasize stricter controls on open burning, ignition sources, and fire watch responsibilities during hazardous operations. Retail and distribution centers must review and update their fire prevention plans to ensure compliance, including obtaining proper permits for welding and other hot work activities, maintaining clear access to fire protection systems such as hydrants and extinguishers, and implementing documented fire watch duties during and after hot work. Facilities are required to keep fire safety inspection records and employee training documentation readily available for review by fire officials. The rule also reinforces requirements for maintaining unobstructed egress routes, proper storage of combustible materials, and adherence to updated standards for emergency planning and preparedness. These updates aim to reduce fire risks in commercial and industrial settings by improving accountability, documentation, and proactive hazard management.
Enacted: 10/07/25
Compliance: 10/07/25

Energy

California Energy Benchmarking (SB 500):
California Senate Bill 500 (SB 500) requires large commercial facilities—specifically retail stores and distribution centers exceeding 50,000 square feet—to report annual energy usage data to the California Energy Commission (CEC). The legislation is designed to enhance transparency and promote energy efficiency across the state’s building sector. Benchmarking must be completed using the US Environmental Protection Agency’s (EPA) ENERGY STAR® Portfolio Manager or another CEC-approved tool. Building owners may need to coordinate with multiple utilities to obtain aggregated consumption data. Utilities are required to provide this data within four weeks of receiving a request, ensuring privacy protections through aggregation and secure handling. Facilities must maintain accurate records and may be subject to public disclosure requirements as outlined in CEC guidelines. This legislation supports California’s broader climate strategy to reduce greenhouse gas emissions from buildings by at least 40% below 1990 levels by 2030. It promotes cost-effective energy efficiency measures and encourages operational improvements that reduce energy intensity. Compliance will likely require organizations to update internal reporting processes, train staff on benchmarking tools, and integrate energy performance tracking into existing sustainability programs.
Enacted: 10/13/25
Compliance: 01/01/26
California Wildlife Prevention & Clean Energy Transmission (SB 254):
California Senate Bill 254 (SB 254) introduces comprehensive measures to enhance wildfire resilience and accelerate the development of clean energy transmission infrastructure across the state. For retail facilities and distribution centers located in wildfire-prone areas, the legislation may lead to higher utility costs due to infrastructure surcharges and contributions to wildfire mitigation funds. The law also establishes stricter vegetation management requirements and mandates enhanced safety inspections near commercial properties to reduce ignition risks. To promote transparency, SB 254 prohibits utilities from profiting on wildfire mitigation investments and instead allows securitization of costs to help stabilize rates. Additionally, the legislation creates the California Transmission Accelerator to expedite permitting and construction of new transmission lines, an essential step toward achieving the state’s renewable energy goals. Businesses may need to coordinate with utilities and local authorities to comply with vegetation clearance standards and maintain defensible space around facilities. While these measures aim to protect communities and ensure reliable energy delivery, they also reflect a broader shift toward shared responsibility for wildfire prevention and infrastructure modernization—factors that will influence operational planning and long-term energy strategies for large commercial sites.
Enacted: 09/19/25
Compliance: Transmission planning and wildfire mitigation plan deadlines: Dec 31, 2026. Tax credits effective: Jan 1, 2026

Wastewater

New Mexico Pollutant Discharge Elimination System Act (SB 21):
New Mexico Senate Bill (SB 21) establishes a state-administered permitting program for wastewater discharges into waters of the US, replacing federal oversight following recent changes to the Clean Water Act. Under this legislation, all entities—including retail and distribution centers with on-site wastewater systems or direct discharges—must obtain permits from the New Mexico Environment Department (NMED) rather than the EPA. The Water Quality Control Commission (WQCC) is responsible for adopting rules, setting permit conditions, and establishing a fee schedule to fund program administration through the Water Quality Management Fund. Facilities should expect stricter discharge monitoring, expanded reporting requirements, and potential civil or criminal penalties for violations, ranging from $5,000 to $25,000 per day.SB 21 also mandates public notice and hearings for permit applications, creates a private right of action, and ensures public access to permitting records while protecting confidential business information. No exemptions apply to commercial sites, and preliminary fee structures indicate substantial costs—application fees ranging from $2,500 to more than $100,000, with annual fees based on discharge volume. The legislation further introduces liability provisions for contamination, establishes appeal rights to the WQCC and courts, and allocates funds for remediation of neglected or contaminated sites. Collectively, these measures represent a major compliance shift for businesses operating in New Mexico.
Enacted: 05/08/25
Compliance: Dates to be set by the New Mexico Environment Department (NMED)
North Carolina Wastewater Discharge Permits (H 926):
North Carolina House Bill (H 926) introduces significant updates to the state’s wastewater permitting process aimed at reducing regulatory delays and streamlining approvals for small-scale systems. The legislation authorizes the Environmental Management Commission to implement “permitting by regulation” for certain low-risk discharges—specifically for those under 5,000 gallons per day and fractional vapor-compression distillation systems—provided they meet conditions such as preventing ponding, runoff, or violations of surface or groundwater standards. The bill also allows either local county health departments or Authorized On-Site Wastewater Evaluators to issue site denial letters for subsurface wastewater systems, simplifying the application process. Retailers and distribution centers operating small-scale wastewater systems may benefit from faster permitting and reduced administrative requirements. Additionally, H 926 directs state agencies to adopt permanent rules consistent with these provisions and includes broader regulatory relief measures related to land use, building inspections, and stormwater requirements for small developments. Collectively, these reforms aim to modernize permitting practices, support economic growth, and uphold environmental protections without unnecessary delays.
Enacted: 10/06/25
Compliance: 10/06/25

Transportation/Fleet

Texas Automated Motor Vehicles (43 TAC 220):
Texas Administrative Code, Chapter 220, adopted by the Texas Department of Motor Vehicles (TxDMV), establishes a comprehensive regulatory framework governing the operation of automated motor vehicles (AMVs) without a human driver. The regulation implements provisions from Senate Bill 2807, requiring entities operating fully autonomous vehicles—defined as those with level 4 or level 5 automation—to obtain formal authorization from the TxDMV. This requirement applies to distribution centers and logistics operators that utilize driverless trucks for commercial transport on public roads. Authorization applicants must submit detailed documentation regarding the vehicle’s automated driving system, safety protocols, and operational domain. Once authorized, operators are required to report material system changes and maintain compliance with state traffic laws and safety standards, including ensuring that vehicles can achieve a minimal risk condition in the event of system failure. The regulation also establishes administrative sanctions for noncompliance and preempts local jurisdictions from adopting conflicting rules, thereby ensuring a consistent statewide framework for autonomous vehicle oversight.
Enacted: 07/25/25 (Effective February 27, 2026)
Compliance: May 28, 2026
Utah Advanced Air Mobility (SB 96):
Utah Senate Bill (SB 96) establishes a foundational framework for the development and regulation of advanced air mobility (AAM) systems in the state, including the use of electric and vertical takeoff and landing (eVTOL) aircraft for transporting goods and passengers. The legislation directs the Utah Department of Transportation to lead a statewide community outreach and education campaign to inform the public about AAM technologies, potential applications such as drone deliveries and air taxis, and their associated economic and environmental benefits.SB 96 also requires the creation of a toolkit for local governments to support the development of ordinances and operational guidelines for unmanned aircraft systems (UAS), promoting consistency and safety across jurisdictions. Retailers and distribution centers may benefit from future drone delivery opportunities but will need to comply with local regulations, including aircraft regulations, aircraft registration, navigation protocols, and coordination with municipal authorities. The legislation emphasizes collaboration with industry leaders while avoiding vendor pre-selection, allowing for innovation and flexibility. SB 96 represents a multi-year effort to position Utah as a leader in emerging air mobility technologies, with a focus on privacy, public engagement, and economic development.
Enacted: 03/26/25
Compliance: 04/01/26

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Published November 2025

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