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 48702(b)(1)]

Architectural Paint that is sold, offered for sale, and distributed in California must be from manufacturers in compliance with the law. To offer Architectural Paint 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 Architectural Paint offered for sale:
    • On-site
    • Through e-commerce websites and
    • Any other means.
  • Information on ‘branded’ and privately labeled Architectural Paint products.
    • Including information regarding the specific manufacturer of the Architectural Paint.

Monitor CalRecycle Website

[PRC section 48702(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 Architectural Paint is 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 428703(b)(3)]

The Architectural Paint Stewardship Assessment may be shown as a separate line item on invoices, receipts, or equivalent billing documents for Architectural Paint that is sold in California.

  • If a visible fee is used, it must be consistent with the stewardship organization’s Architectural Paint 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 48703(a)]

Manufacturers that offer or sell Architectural Paint in or into California must, individually or through a stewardship organization, be a participant of an Architectural Paint Stewardship Plan that has been approved by CalRecycle.

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

Architectural Paint Stewardship Assessment

[PRC section 428703(b)(3)]

The Architectural Paint Stewardship Assessment may be shown as a separate line item on invoices, receipts, or equivalent billing documents for Architectural Paint that is sold in California.

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

Related Links

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