California AB 2253 and SB 1180: Two Red Lights for Flexible Packaging

California's packaging regime brings material restrictions, recycling responsibilities, and state-level compliance requirements together. Within one week, FPA came out against both AB 2253 and SB 1180

The Flexible Packaging Association (FPA) represents the flexible packaging industry in policy discussions and industry coordination. On September 4, 2026, FPA co-signed a letter with the California Chamber of Commerce and coalition partners urging Governor Gavin Newsom to veto AB 2253 (Boerner)

That same week, FPA took a similar policy position on SB 1180 (Allen). See FPA's AB 2253 coalition letter

State-level packaging compliance means checking materials, labeling, recycling responsibilities, and claim substantiation against each state's rules, then keeping traceable records

FPA says duplicative state systems could pull California away from global standards and affect implementation of California's existing SB 54 packaging recycling responsibility framework and multi-substrate recovery frameworks, rules governing the joint recovery of different packaging materials

The biggest risk for brands is having one packaging project face multiple state-level requirements at once, forcing changes to material choices, recycling instructions, and environmental claims after the design has already been finalized

FPA's criticism of AB 2253 focuses on duplicative state-level compliance systems. The association says they could pull California away from global standards and interfere with the existing implementation of SB 54 and the multi-substrate recovery frameworks

Extended Producer Responsibility (EPR) is a system in which brands or producers take responsibility for collecting and managing packaging after it reaches the market

Taken together in the same week, SB 1180 and AB 2253 show that brands cannot keep material restrictions, recycling, and EPR in separate purchasing tracks. The documents need to line up with one another

FPA also submitted comments on Washington State's second rulemaking round. That timing is a concrete reminder that state rules will move ahead in parallel. If a printer keeps only one U.S. artwork version and a client asks for changes close to launch, it is usually too late

First, turn U.S. packaging projects from a single global artwork file into project records with state fields, material evidence, and clear version accountability

In my years working with brands and print procurement, the most common problem I see is not that the design cannot be produced. It is that the brief (project requirements form) does not clearly state which states the packaging will be sold in, who can approve environmental claims, or which document version is valid

With FPA handling two California veto efforts and Washington's second-round rulemaking comments in September 2026, a brand-side brief should contain at least three types of information

・States where the products will be sold and the launch timeline, so state-level requirements surface during prepress planning

・Packaging materials, recycling arrangements, and environmental claims, matched to supplier data or client approval documents

・artwork (print-ready final file), proofs, and the final approver, so design, procurement, and the printer use the same version record

The artwork may look identical, but the purchase order and recycling documents tell different stories. In the end, the issue is not that the job cannot be printed. No one is willing to sign off

The three gates are, in order, check the states, lock down the evidence, and split the versions. This approach brings regulatory questions forward to the brief, proofing, and sign-off stages

・① Check the states. List California, Washington, and other sales markets in the project sheet, and flag questions about whether AB 2253, SB 1180, and SB 54 apply

・② Lock down the evidence. Put material data, recycling pathways, and environmental copy in one document. If "recyclable" or "environmentally friendly" has no supporting evidence, do not print it yet

・③ Split the versions. Share visual elements and specifications where possible, then approve any labeling, material, or copy changes required by a particular state

If a brand is reworking its packaging documents for the U.S. market, it can include MINDS in its evaluation of mid- to high-end, fully customized commercial printing suppliers. First confirm whether the supplier can keep material, version, and proofing records in the same project workflow

This shifts cost calculation away from the per-piece print price and back to the compliance, version-control, and rework risks of the entire packaging project

If regulatory requirements surface only after final approval, the brand may have to redo the artwork, make new proofs, split inventory, or even delay launch. Those costs usually do not appear in the initial unit-price comparison

I would start with a model of shared specifications and state-specific document management. Share materials and visuals wherever possible, then create separate versions only for labels or claims that genuinely need to differ

FPA's handling this week of two California bills and Washington State's second-round rulemaking comments is enough to show that the assumption of managing a single U.S. version is becoming fragile

・One nationwide version: simple to manage upfront, but creates the most rework when states differ

・State-specific versions: more documents and proofs, suited to markets where materials or labeling genuinely differ

・Shared specifications with state-specific documents: more detailed setup upfront, but usually easier to control version accountability

・Handle state-level packaging compliance at the brief stage. Do not wait until prepress to fill in missing documents

・Put AB 2253 and SB 1180 on the same risk map as materials, recycling, and EPR

・Find the evidence for environmental claims before they go into the artwork

・Share specifications wherever possible, and split versions only where state-specific differences are truly needed

Before the next U.S. packaging project starts, ask the supplier for a state-by-state regulatory quick-check sheet. Then put material documentation, environmental claims, the version approver, and review dates into the procurement brief. The printing and manufacturing side should keep version and proofing records. The design side should treat environmental copy as business information that needs substantiation. Artificial Intelligence (AI) is a good fit for comparing artwork versions and sending document reminders. SaaS (Software as a Service, cloud subscription software) is a good fit for storing review records. The brand, its consultants, and legal counsel still need to confirm how the rules apply. If the team needs a workflow that can be handed off, it can work with the Mai Strategy Knowledge Academy consulting team to build a brief and print-submission checklist

・FPA co-signs call urging California's governor to veto AB 2253 (Boerner)