Retail Regulatory Updates | September 2025
Dive into regulations reshaping the retail industry and discover how you can turn compliance into a competitive advantage.
This Week's Contributor
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
- Illinois Amendments to the Consumer Electronics Recycling Act (ILHB3098): Illinois HB3098 expands the scope of the Consumer Electronics Recycling Act by broadening the definitions of covered electronic devices (CEDs) and allowing nonprofit organizations and private network recyclers to participate in collection site operations. Retailers are now permitted to operate retail or private network collection sites for CEDs, provided they have written agreements with manufacturers that are included in the manufacturers’ e-waste program plans. The law also introduces provisions for collaboration between retailers and nonprofits, eligibility for waivers in cases of collection shortfalls, and mandates retailer involvement in consumer education efforts such as signage and outreach. Retailers participating in these programs must follow best practices for packaging, contamination control, and reporting. Additionally, the law removes the automatic repeal clause, ensuring its continued applicability beyond the original sunset date.
Enacted: 08/15/25
Compliance: 01/01/26
Occupational Safety and Health
- Illinois Warehouse Tornado Preparedness (ILHB2987): Under Illinois House Bill 2987, warehouse operators are required to develop a tornado safety plan for each facility. Existing warehouses must complete their plans within 120 days of the law’s enactment, while new warehouses must do so within seven days of becoming operational. Each plan must include detailed floor layouts showing emergency exits and designated shelter areas, provide shelter space sufficient for 125% of the regular workforce, including temporary staff. Plans must also include essential emergency supplies such as first aid kits, water, and communication tools. These plans are to be reviewed annually and submitted to local emergency services and fire departments, ensuring preparedness and compliance.
Enacted: 08/15/25
Compliance: Existing warehouses must complete tornado safety plans by 09/17/25 (120 days after effective date), while new warehouses must complete plans within 7 days of becoming operational.
Solid Waste & Recycling
- Washington Carryout Bag Limitations (RCW70A.530.020): Increases plastic bag fee to $0.12 and paper bag fee remains at $0.08. Adds a $0.04 penalty for thicker plastic bags until 2028.
Enacted: 07/27/25
Compliance: 01/01/26
Air Quality
- Washington Prohibition on Bulky Hydrofluorocarbons (RCW70A.60.100): Beginning January 1, 2030, retailers and warehouses will be prohibited from selling or distributing newly produced bulk hydrofluorocarbons (HFCs) with a global warming potential (GWP) over 1,500, and starting January 1, 2033, the limit drops to GWP over 750. This means businesses involved in the sale or use of refrigerants, such as those managing cold storage, HVAC systems, or refrigeration units, must transition to lower-GWP alternatives or reclaimed refrigerants. Retailers that sell refrigerants must ensure compliance with these thresholds and may need to adjust inventory, sourcing, and labeling practices. Warehouses using refrigeration systems must plan for equipment upgrades or retrofits to accommodate compliant refrigerants. The Department of Ecology is authorized to adopt rules that could accelerate these deadlines or lower the GWP thresholds, depending on the availability of reclaimed refrigerants. Exemptions exist for:
- Reclaimed HFCs
- Emergency repairs (with strict limits)
- Aircraft-related uses
- Transshipments
Violations are subject to penalties under chapter 70A.15 RCW, and the department may also prohibit fees for destroying recovered refrigerants to incentivize reclamation. Businesses should monitor rulemaking updates and prepare for compliance through infrastructure upgrades, staff training, and supplier coordination.
Enacted: 07/27/25
Compliance: 01/01/30 - Washington Transition to Low-GWP Refrigerants (RCW70A.60.120): As part of Washington’s transition to low-GWP refrigerants, retailers and warehouse operators must comply with new equipment restrictions starting January 1, 2024, requiring all newly installed refrigeration and air conditioning systems to use refrigerants with a global warming potential (GWP) of 150 or less. Equipment manufactured before this date may still be sold or installed until January 1, 2026. Facilities with systems containing 50 pounds or more of refrigerant must register in the RAMP platform and begin adhering to leak detection, repair, reporting, and recordkeeping requirements in 2025. Additionally, businesses must maintain five years of records detailing refrigerant types, equipment sectors, and transactions, and ensure proper labeling of equipment. Retailers face challenges such as high retrofit costs, limited low-GWP refrigerant options, building code limitations, supply chain delays, and potential operational downtime. However, early planning, alignment with federal EPA rules, and the opportunity to contribute to Washington’s net-zero emissions goal by 2050 present strategic advantages.
Enacted: 07/27/25
Compliance: Prohibition on certain high-GWP refrigerants in new stationary refrigeration equipment began on 01/01/24, while equipment manufactured before 01/01/24 may still be sold, leased, or installed until 01/01/26. Facilities with systems containing ≥50 pounds of refrigerant with GWP ≥ 150 must register and comply with leak detection, repair, and reporting requirements started in 2025.
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 September 2025
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