Paint EPR Enforcement

CalRecycle provides enforcement oversight of the Paint Stewardship Law. Compliance is evaluated through various means including, but not limited to, site inspections and records review.

During an inspection, CalRecycle may ask a site to provide information and records that demonstrate compliance with the following:

Retailers, Wholesalers and Distributors

Offer Compliant Architectural Paint

[PRC section 48706(b)(1)]

Paint products sold, offered for sale, and distributed in California must be from manufacturers in compliance with the law. To offer paint products for sale from manufacturers that do not appear on CalRecycle’s list of compliant paint manufacturers and brands can lead to penalties. 

The following may be requested by CalRecycle:

  • A complete listing of manufacturers of paint products, including architectural coatings, offered for sale:
    • On-site
    • Through e-commerce websites and
    • Any other means.
  • Information on ‘branded’ and privately labeled paint products.
    • Including information regarding the specific manufacturer of the paint product.

Monitor CalRecycle Website

[PRC section 48706(d)]

CalRecycle maintains a list of compliant paint manufacturers and brands on its website.

Retailers, wholesalers, and distributors that sell or distribute Architectural Paint in California are required to monitor CalRecycle’s website to determine if the sale of a manufacturer’s paint products are in compliance with the law. 

Retailers, wholesalers, and distributors need to be able to:

  • Provide information regarding who at the business monitors CalRecycle’s website.
  • Identify the website monitored to verify accuracy.

Architectural Paint Stewardship Assessment

[PRC section 48704.1(b)]

The Stewardship Assessment may be shown as a separate line item on invoices, receipts, or equivalent billing documents for paint products, including architectural coatings, that are sold in California.

  • If a visible fee is used, it must be consistent with the stewardship organization’s Stewardship Plan’s developed assessments for the specific product and size sold.
  • The assessment must be included as a taxable item.

Manufacturers

Architectural Paint Stewardship Plan Requirement

[PRC section 48702(a)]

Manufacturers that offer or sell paint products, including architectural coatings, in or into California must, individually or through a stewardship organization, be a participant of a Stewardship program that has been approved by CalRecycle.

CalRecycle may request information and documentation supporting compliance with this requirement.

Architectural Paint Stewardship Assessment

[PRC section 48704.1(b)]

The Stewardship Assessment may be shown as a separate line item on invoices, receipts, or equivalent billing documents for paint products, including architectural coatings, that are sold in California.

  • If a visible fee is used, it must be consistent with the stewardship organization’s Stewardship Plan’s developed assessments for the specific product and size sold.
  • The assessment must be included as a taxable item.

For enforcement related information, contact (916) 341-6079 or paintenforcement@calrecycle.ca.gov.