Retail Regulatory Updates | October 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

Alaska Hazardous Waste Updates (18 AAC 62):
Alaska has adopted new hazardous waste regulations under Title 18, Chapter 62 of the Alaska Administrative Code (18 AAC 62), aligning with the federal Resource Conservation and Recovery Act (RCRA) Subtitle C. These regulations establish standards for hazardous waste identification, handling, storage, transport, treatment, and disposal. The adoption marks a step toward Alaska obtaining authorization from the Environmental Protection Agency (EPA) to manage hazardous waste independently. Until authorization is granted, federal regulations remain in effect. The new rules also include provisions for electronic devices classified as universal waste and clarify criteria for hazardous waste characteristics.
Enacted: 06/01/25
Compliance: 06/01/26
Maryland Hazardous Waste Updates (COMAR 26.13):
Recent updates to Maryland’s hazardous waste regulations under the Code of Maryland Regulations (COMAR) Title 26, Subtitle 13, align state standards more closely with EPA rules and aim to streamline hazardous waste management across sectors. Changes include the adoption of management standards for hazardous waste pharmaceuticals at healthcare facilities, revised definitions for the ignitability characteristics, and the classification of aerosol cans as universal waste. Additionally, the regulations now include conditional exclusions for solvent-contaminated wipes and establish standards for managing automotive airbag inflator waste. These revisions enhance environmental protection while simplifying compliance for generators and handlers of hazardous waste.
Enacted: 10/01/25
Compliance: 10/01/25

Toxic Substances

40 CFR Part 751 Subpart D (TCE):
The EPA’s final rule under the Toxic Substances Control Act (TSCA) restricts the manufacture, processing, distribution, use, and disposal of trichloroethylene (TCE) due to its health risks. The rule prohibits TCE in consumer products including cleaning supplies, furniture care items, arts and crafts sprays, and automotive products. Retailers must remove TCE-containing products from shelves by September 15, 2025, and update Safety Data Sheets (SDS) and provide downstream notifications within 90 days of the rule’s publication. Industrial uses face phased prohibitions through 2034, with specific deadlines for degreasing, battery manufacturing, and aerospace applications. Disposal of TCE to wastewater systems is prohibited unless explicitly exempted.
Enacted: 09/15/25
Compliance: 09/15/25

Solid Waste & Recycling

California E-Waste Recycling Fees for Battery-Embedded Devices (PRC 42464):
California consumers must pay a recycling fee at the point of sale for battery-embedded electronic devices, as mandated by Public Resources Code (PRC) Section 42464. The California Department of Resources Recycling and Recovery (CalRecycle) is responsible for setting the fee annually by October 1, based on the cost of administering the recycling program. The fee applies to products with non-removable batteries and excludes certain medical devices and energy storage systems. Retailers must collect the fee and may retain up to 3% for administrative costs. The fee is capped at 1.5% of the retail price or a maximum of $15 per item.
Enacted: 09/29/25
Compliance: 01/01/25
Colorado Battery Stewardship Act (CRS 25-17 Part 10 [SB25-163]):
Colorado’s Battery Stewardship Act (House Bill 23-1215) requires producers of small- and medium-format rechargeable and single-use batteries to join a Battery Stewardship Organization (BSO) and submit a battery recycling plan by July 1, 2027. Retailers may not sell batteries unless the producer participates in an approved plan by July 1, 2029. Retailers are prohibited from charging any point-of-sale fees to cover program costs. The BSO must establish convenient and accessible free collection sites statewide, conduct public education and outreach campaigns, and submit annual performance reports to the Colorado Department of Public Health and Environment (CDPHE). Starting January 1, 2030, disposal of covered batteries in landfills is prohibited. Violations may result in fines up to $7,000 per day per violation.
Enacted: 09/29/25
Compliance: 01/01/29 and 01/01/30
Washington Pass-Through Fees for Compliant Carryout Bags (70A.530.020):
Washington state law (Revised Code of Washington [RCW] 70A.530) requires retailers to charge 12 cents for reusable plastic carryout bags and 8 cents for compliant paper bags. Additionally, a 4-cent fee applies to plastic bags with a thickness of 4 mils or greater, and this amount must be remitted to the state’s Waste Reduction, Recycling, and Litter Control Account. Retailers must clearly itemize these charges on customer receipts and may retain the revenue excluding the remitted fee. The law also prohibits the distribution of single-use plastic carryout bags and establishes minimum recycled content and labeling requirements for compliant bags.
Enacted: 09/08/25
Compliance: 01/01/25 and 12/31/27

Energy

Illinois Stretch Energy Code for Building Efficiencies (HB3510):
Illinois House Bill 3510 (HB3510) establishes the Illinois Stretch Energy Code, a voluntary yet more stringent alternative to the Illinois Energy Conservation Code. This code allows municipalities to adopt higher energy efficiency standards for both residential and commercial buildings. It sets progressive targets for site energy index values relative to the 2006 International Energy Conservation Code (IECC). For commercial buildings, the index must be no greater than 0.50 by December 31, 2026; 0.44 by December 31, 2029; and 0.39 by December 31, 2032. These standards apply to projects authorized or funded by the Capital Development Board and are designed to align with the goals of the Climate and Equitable Jobs Act (CEJA; Illinois General Assembly, 2023).
Enacted: 08/15/25
Compliance: 12/31/26

Hazardous Materials

California Sale of Certain Lighters (SB 793):
California Senate Bill (SB 793) prohibits the sale, distribution, or offering of lighters, lighting rods, or gas matches that do not meet ASTM International safety standards. Specifically, cigarette and pipe lighters must comply with ASTM Standard F400, while utility lighters for grills and fireplaces must meet ASTM Standard F2201. The law also bans counterfeit lighters that infringe on intellectual property rights. Exceptions are made for interstate transportation and the warehouse storage of items not open to the public. Retailers must ensure compliance to avoid fines and protect consumers from unsafe products.
Enacted: 10/01/25
Compliance: 10/01/25
Ohio EPCRA Update (OAC 3745-100-08):
Ohio’s update to the Emergency Planning and Community Right-to-Know Act (EPCRA) regulations revises exemptions and reporting thresholds for toxic chemical releases under the Toxics Release Inventory (TRI). The changes include updates to definitions, recordkeeping, and reporting schedules to align with federal standards in Title 40 of the Code of Federal Regulations (CFR) Part 372. Notably, the rule clarifies exemptions for laboratory research chemicals and adjusts thresholds for substances such as sulfuric acid and generator fuel oil. Facilities must evaluate their chemical usage and storage to determine reporting obligations, and the de minimis exemption for per- and polyfluoroalkyl substances (PFAS) has been revoked, requiring more detailed reporting.
Enacted: 08/08/25
Compliance: 08/08/25
Oregon PFAS Rulemaking (OAR 340-122-0115):
Oregon’s Environmental Quality Commission (EQC) updated the state’s hazardous substances list to include four additional PFAS compounds: perfluorohexane sulfonic acid (PFHxS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA; GenX), and perfluorobutanesulfonic acid (PFBS). These are now regulated alongside perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) under Oregon Administrative Rule (OAR) 340-122-0115. The rule grants the Oregon Department of Environmental Quality (DEQ) authority to require investigation, removal, and remediation of PFAS contamination. It aligns Oregon’s standards with US Environmental Protection Agency (EPA) guidance and expands liability under the state’s Cleanup Act to include current and former property owners and operators responsible for PFAS releases.
Enacted: 09/12/25
Compliance: 09/12/25

Need Help with Compliance?

Contact RegulatoryReview@APTIM.com to learn how our team of experts can guide your business through existing requirements and prepare you for what’s next.

Published October 2025

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