Q3 2026: Where Your Interests Showed Up in the States

Three months, 12 weeks of state legislative and regulatory review, seven comment letters filed, one federal court ruling that changed a compliance picture members were already planning around, and one new California deadline that lands before the end of the year. Here is what the Auto Care Association worked on and where it landed.

California: a registration deadline hits Dec. 19, and the state has not built the

portal

California Governor Gavin Newsom signed SB 615 on Sept. 20. If you supply, distribute, or sell replacement vehicle traction batteries into California, you are covered.

Earlier drafts put end-of-life duties and material recovery targets on suppliers and remanufacturers. Those came out before passage. What stayed still reaches the aftermarket.

Battery suppliers and remanufacturers must register with the State Air Resources Board within 90 days of enactment. That puts the deadline at Friday, Dec. 19, 2026, with annual updates each July 1 after. The board is directed to build an electronic submission process, but has published no guidance on how to register before that process exists. The Auto Care Association is asking the board how companies are expected to meet a deadline with no portal, and will pass along what we hear.

After that: permanent labels on new traction batteries sold in California beginning July 1, 2028, carrying only specified information. Remanufacturers must rebrand, relabel, and mark the original label obsolete. Supplier fees start July 1, 2029 on a tiered schedule set through public comment. Board implementing regulations are due no later than July 1, 2031.

Eighty-one days is not much runway. If traction batteries move through your business in California, start now.

A recycled-content bill that would have touched nearly every product line was vetoed

AB 2253 would have extended recycled-content claim substantiation from plastic food containers to all products starting Jan.1, 2030. Any member making a voluntary recycled-content claim on a label or an online listing would have needed written documentation, ISO chain-of-custody accounting, and the ability to produce records to the Attorney General on request. The Governor vetoed it September 27. It can return next session, and we expect it will.

New Mexico's PFAS labeling mandate is blocked, for now

The Auto Care Association filed comments on Sept. 16 asking the Environment Department to put guidance in writing on exemption scope, including whether the exemptions reach motor vehicle air conditioning refrigerant, and to hold off on enforcement until it does.

The same day, a federal judge preliminarily blocked the Act's product labeling requirement on First Amendment grounds in a case brought by manufacturing groups. The Association is not a party.

Before anyone relaxes: the relief is preliminary, the state has said publicly it will challenge it, and the court rejected several of the plaintiffs' arguments, including the claim that New Mexico's PFAS definition is too broad to convey factual information. Reporting and the other obligations under the Act are unaffected by the order. We are still pressing the department for written answers on exemption scope.

Massachusetts: the exposure moved, and the new one arrives in 2028

H 4870 was redrafted as H5598 and reported to House Ways and Means on July 22. The redraft dropped language the Auto Care Association had flagged to the sponsor in July, which had stripped the motor vehicle exemption for refrigerant and vehicle textiles. The current text exempts motor vehicles and motor vehicle equipment regulated under a federal motor vehicle safety standard.

That exemption is narrower than it reads. Most aftermarket parts are not regulated under a specific federal standard, which leaves them treated as consumer products under the bill. Two consequences follow: Aftermarket floor mats, seat covers, carpet, and fabric treatment products would be restricted beginning Jan. 1, 2029. And beginning June 1, 2028, any manufacturer of a consumer product containing intentionally added PFAS would have to register that product by universal product code, identifying every PFAS compound by chemical registry number. That reporting obligation reaches well past the restricted list and arrives first.

The bill also directs the state to study other consumer products and recommend further restrictions, with new categories taking effect three years after designation.

Formal sessions have ended, but the reporting deadline runs to Dec. 31, 2026. The Auto Care Association is reassessing its position against the new text.

New Jersey has a fix moving in your favor

S 4057 would exclude rugs and fabric made for vehicles from the state's PFAS carpet restriction. It cleared the Senate and sits in Assembly Consumer Affairs. New Jersey carries bills into 2027, so the calendar has not run out. The Association supports it and uses its language as a template when arguing for vehicle carve-outs elsewhere.

Seven comment letters

When an agency proposes a rule, there is a window to put industry facts on the record before the language hardens. We used it seven times this quarter: Los Angeles County household hazardous waste EPR on July 16; the Minnesota Packaging Waste and Cost Reduction Act rulemaking; the California Bureau of Automotive Repair airbag safety rule on July 21; the draft California program plan under SB 54 on Aug. 13; the Environmental Protection Agency selective catalytic reduction proposal on Aug. 28; Washington's EPR draft regulations on Sept. 2; and New Mexico on Sept. 16.

The Minnesota filing pressed the automotive lubricant packaging exemption and warned the state against building a fee structure producers have no real way to appeal. The California airbag filing flagged a sourcing gap that would push shops toward original equipment parts without a defined verification standard.

Two results that went against us

New York's Department of Environmental Conservation declined the request we made with our coalition partner for enforcement discretion and a later effective date on the Part 494 restriction covering do-it-yourself refrigerant cans. The Jan. 1, 2027 date stands. We have a call with the department Oct. 1 and are working the remaining paths.

On Aug. 27, a federal court upheld Oregon's packaging EPR law against the industry's constitutional challenge, including the argument that the producer responsibility organization holds too much unchecked authority over fee-setting. That reasoning now sits against similar claims in other states, Colorado included. The practical read: these fights get won in rulemaking and in legislatures, not in court.

Wins you may not have caught

Washington's Insurance Commissioner finalized a claims rule on Sept. 2, effective Oct. 18. It bars insurers from denying or refusing payment based solely on a database or estimating software, requires a response to supplemental estimates and final invoices within five business days, and requires a written explanation when an insurer pays less than a claimant's estimate. A direct gain for independent shops in Washington.

Oregon's temporary glass rule, published September 14, narrows producer responsibility organization collection duties for glass bottles and jars to ten low-population counties. The Department of Environmental Quality expects producer base fees for glass packaging to fall at least 40% against 2026 levels.

Ohio extended emissions waiver repair technician certification from two years to three, effective Aug. 21.

Open now

Oregon's Department of Environmental Quality has proposed a third round of Recycling Modernization Act rule changes, published Oct. 1. The proposal clarifies exclusions for hazardous automotive fluid containers, adds steel and aluminum aerosol cans to collection lists effective Jan. 1, 2028, and moves pressurized cylinders to Jan.1, 2030. Hearings run Oct. 20 and 21. Comments close Oct. 30 at 4 p.m. ET. The Auto Care Association will file.

What's coming

Rhode Island amended its Consumer PFAS Ban Act in June to reach products sold or distributed for commercial or industrial use, with civil penalties beginning Jan. 1, 2027. If you move product through commercial or industrial channels in Rhode Island, that date is close.

New Hampshire has filed placeholder requests for the 2027-2028 session covering packaging stewardship, PFAS facility liability, and consumer right to repair. No text yet. Prefiling in most states starts within weeks.

Two PFAS restriction bills stay live into next year: Ohio HB 743 and Michigan HB 5890. Neither has a hearing scheduled.