September 2026 in the States: A California Battery Deadline, a Blocked PFAS Label, and Two Filings

In September, the Auto Care Association filed comments in Washington and New Mexico, pressed New York on do-it-yourself refrigerant cans, and confirmed a new California registration deadline that reaches the aftermarket. Here's what moved:

What we did on your behalf in September:

• Filed comments with Washington's Department of Ecology on Sept. 2, asking that alternative collection programs coordinate with producer responsibility organizations before fees are assigned, that the hazardous and flammable product packaging exemption get objective criteria, and that reporting methods be standardized.
• Filed comments with the New Mexico Environment Department on Sept. 16, asking for written guidance on exemption scope, including motor vehicle air conditioning refrigerant, and a hold on enforcement until that guidance exists.
• Pressed New York's Department of Environmental Conservation, with a coalition partner, for relief from the Jan. 1, 2027 restriction on do-it-yourself refrigerant cans. When the department declined, we set an Oct. 1 meeting on sell-through.
• Confirmed that California's new traction battery registration requirement reaches aftermarket distributors and retailers, and set the deadline at Dec. 19.
• Convened the PFAS Working Group on Sept. 24 to brief members on the New Mexico ruling and to collect compliance questions for the Environment Department.
• Shared a supplier-manufacturer PFAS reporting workbook and a compliance FAQ with the Working Group on Sept. 9 for review.

California: register traction batteries by Dec. 19

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

Suppliers and remanufacturers must register with the State Air Resources Board within 90 days of enactment. That's Saturday, Dec. 19, 2026, so plan on Friday, Dec. 18. The board has not yet published guidance on how to register before its electronic submission process is in place.

Permanent labels on new traction batteries follow beginning July 1, 2028, and supplier fees beginning July 1, 2029.

New Mexico: the labeling rule is blocked; reporting is not

On Sept. 16, the Auto Care Association filed comments with the New Mexico Environment Department on the PFAS Protection Act. We asked the department to put guidance in writing on exemption scope, including whether the exemptions cover motor vehicle air conditioning refrigerant, and to hold enforcement until it does.

The same day, a federal court preliminarily blocked the act's product labeling requirement in a case brought by manufacturing groups. The Auto Care Association is not a party. The ruling is preliminary, so treat labeling as paused, not gone. Reporting, due Jan. 1, 2027, and the act's other obligations are unaffected.

Washington: comments on the packaging EPR rules

On Sept. 2, the Auto Care Association filed comments on Washington's draft extended producer responsibility (EPR) rules. We asked the Department of Ecology to require alternative collection programs to coordinate with producer responsibility organizations before fees are assigned or invoiced, to set objective criteria and documentation standards for the hazardous and flammable product packaging exemption, and to standardize reporting methods across producers.

New York: the refrigerant can date holds

New York's Department of Environmental Conservation declined the Auto Care Association's request made with a coalition partner for enforcement discretion and a later effective date on the Part 494 restriction on do-it-yourself refrigerant cans. Jan. 1, 2027 stands. The Auto Care Association will meet with the department on Oct. 1 on the sell-through question it left unanswered.