New York's 2024 Extended Producer Responsibility for Carpet Law

New York's 2024 Extended Producer responsibility LAW for Carpet, CUSHION & TurF

Note: Statutory language in New York law defines "carpet" to expressly include carpet, carpet cushion, and artificial turf. For continuity, this page uses the terms as the statute does.

Overview

New York's Extended Producer Responsibility (EPR) for Carpet Law took effect December 28, 2024, requiring producers to fund and operate a statewide take-back and recycling system.

The law does not ban the sale of synthetic turf or any category of carpet in New York. Instead, it shifts the cost and operational responsibility for end-of-life management onto producers, sets escalating recycled-content and recycling-rate targets over a 15-year period, and phases out PFAS in covered products.

What the law does: This law mandates that carpet producers fund a no-cost collection program for New York consumers and meet escalating environmental targets. More specifically, the law:

Requires producers (or a representative organization acting on their behalf) to submit a carpet collection program plan to the Department of Environmental Conservation (DEC) for approval.
Requires producers (or a representative organization acting on their behalf) to submit a carpet collection program plan to the Department of Environmental Conservation (DEC) for approval.
Sets minimum 30% recycling rate (10% closed-loop) within 5 years, 50% (20% closed-loop) within 10 years, and 75% (40% closed-loop) within 15 years of program approval. Carpets must contain at least 10% post-consumer recycled content one year after program approval, increasing to 20% in 5 years and 30% in 10 years.
Bans the sale of carpet, including turf, that contains or is treated with PFAS substances for any purpose, effective December 31, 2026.
Requires producers to fund consumer outreach and education, and to submit annual compliance reports.
Requires retailers to only sell carpet, including turf, by producers participating in an approved carpet collection program. A retailer may also participate, on a voluntary basis, as a designated collection site.

Why This matters

This is the first EPR program to include synthetic turf (sports fields, landscape, and shock pad underlayments).
The law shifts the financial and logistical burden of carpet disposal from consumers and municipalities to producers.
Non-compliance carries penalties for unmet recycling targets, impacting profitability.
This is an opportunity to lead in sustainable practices but requires proactive planning to meet stringent requirements.

What's Next: How STC is Taking the Lead

Industry Collaboration: STC continues to facilitate meetings with its members and contract lobbyists to shape effective compliance strategies.
Industry Partnerships: STC is engaged with the Carpet and Rug Institute (CRI) and Carpet Cushion Council (CCC) in the research, decision-making, planning and implementation of the New York Surface Recovery Alliance (NYSRA) as a producer responsibility organization (PRO) formed by carpet producers. Participants will be invited to join NYSRA after the organization is fully operational.
Regulatory Engagement: STC continues to work closely with the DEC, providing feedback and expertise during the reporting and rulemaking processes.
Rulemaking Process: Implementing regulations are still forthcoming and expected sometime in fall 2026. We encourage members to reach out to STC with any questions.

Key Dates

December 31, 2026 – Deadline for producers/representative organizations to submit carpet collection program plans to DEC for approval (plans are accepted or rejected within 90 days). Any new producers entering after this date must submit a plan before selling carpet in NY.
December 31, 2026 – No carpet sold or offered for sale in NY may contain or be treated with PFAS for any purpose.
July 1, 2027 – Carpet collection programs must be implemented. After this date, producers can't sell carpet in NY unless participating in an approved program, and retailers can't sell carpet unless the producer is participating.
July 1, 2028 – First annual program reports due to DEC.

Longer-Term Compliance Milestones (measured from when a producer's program plan is approved)

+1 year: All carpet sold must contain ≥10% post-consumer recycled content.
+5 years: ≥20% post-consumer recycled content; 30% recycling rate (10% closed-loop).
+10 years: ≥30% post-consumer recycled content; 50% recycling rate (20% closed-loop).
+15 years: 75% recycling rate (40% closed-loop).

Key Definitions (as written in the law)

Carpet: A manufactured article that is (a) used by a consumer, (b) affixed or placed on the floor or building walking surface as a decorative or functional building interior or exterior feature, and (c) primarily constructed of a top surface of synthetic or natural face fibers, yarns, or tufts attached to a backing system made of synthetic or natural materials. Includes, but is not limited to, commercial or residential broadloom carpet, modular carpet tiles, artificial turf, and pads or underlayment used with carpet. Does not include handmade rugs, area rugs, or mats.

Producer: person who manufactures carpet that is sold, offered for sale, or distributed in the state under the manufacturer's own name or brand. "Producer" includes:

(a) the owner of a trademark or brand under which carpet is sold, offered for sale, or distributed in this state, whether or not such trademark or brand is registered in the state; and
(b) any person who imports a carpet into the United States that is sold or offered for sale in the state and that is manufactured by a person who does not have a presence in the United States.

Representative Organization: A not-for-profit organization established by a producer or group of producers to implement the carpet collection program.

Carpet Collection Program: A program financed and implemented by producers, either individually, or through a representative organization, that provides for, but is not limited to, the collection, transportation, reuse, recycling, proper end-of-life management, or an appropriate combination thereof, of discarded carpet.

Recycling: to separate, dismantle or process the materials, components or commodities contained in discarded carpet for the purpose of preparing the materials, components, or commodities for use or reuse in new products or components. "Recycling" does not include:

(a) energy recovery or energy generation by any means, including but not limited to, combustion, incineration, pyrolysis, gasification, solvolysis, waste to fuel or any chemical conversion process; or
(b) landfill disposal of discarded carpet or discarded product component materials.

Closed-Loop Recycling: Recycling in which materials that are reclaimed are returned to the original process or processes in which they were generated and they are reused in the production process.

Key Resources

NYSDEC — Carpet Recycling Program Page

Full Statutory Text — ENV Article 27, Title 33

DEC Program Timeline (PDF)

DEC Enforcement Discretion Letter, Dec. 19, 2025 (PDF)

DEC Pre-Rulemaking Stakeholder Meeting (PDF)

For retailers: See slide 16
For installers: See slide 26

Frequently Asked Questions:

What is a producer responsibility organization (PRO)?

A PRO is the "representative organization", which is a not-for-profit organization established by a producer or group of producers to implement the carpet collection program.

What products are covered by the law?

The law applies to all carpet, including synthetic turf (sports fields and landscape) and underlayments (shock pads), sold into New York State.

What does this mean for turf and shock pad manufacturers selling into New York?

Turf producers must either establish their own carpet collection program or join a representative organization's program, submit that plan to DEC for approval, and meet the same escalating post-consumer recycled content and recycling-rate benchmarks that apply to other carpet types. After December 31, 2026, a turf producer cannot lawfully sell into New York without an approved program in place.

Shock pad manufacturers must either establish their own carpet collection program or join a representative organization's program.

Does the law apply to turf retailers and installers?

Yes, but only to the extent that retailers sell or offer turf for sale directly to consumers. Per the statute, retailers may not sell carpet, including turf, unless the producer of that product participates in an approved collection program. Retailers can also opt to serve as a voluntary collection site.

Installers and retailers have no obligation to join a PRO, only to sell products from producers in an approved program. Producers can comply individually, jointly, or through whichever representative organization they choose.

DEC is considering defining “installer” as any person who places carpet in position or removes carpet prior to placing flooring material in position. Once installer universe is defined, the entity type’s role and responsibilities can be clarified in this program.

What is the role of turf recycling companies?

Recyclers are not "producers", "retailers" or "consumers" under the statute. Producers or their respective organization contract with third-party recyclers/processors to handle discarded carpet and turf once it's collected.

How does the PFAS provision affect turf?

Starting December 31, 2026, turf sold or offered for sale in New York may not contain or be treated with PFAS substances for any purpose. This is a hard deadline that applies independently of a producer's program-participation status.

Do STC members use PFAS-based raw materials in their manufacturing?

No. STC members are committed to maintaining the highest quality standards for synthetic turf systems. Our member manufacturers proactively engage with their component and raw material suppliers to ensure that their products contain no PFAS-based ingredients, including polymeric PFAS processing aids. Additionally, our members self-audit through voluntary testing processes that rely on EPA-approved methods for individual PFAS analytes and/or a total organic fluorine test to verify the absence of intentionally-added PFAS. These tests are widely used and provide verifiable, consistent data across different projects and regions. While PFAS are unfortunately present in our environment, STC members are committed to do our part to ensure the absence of intentionally-added PFAS in our products.

When do the recycled-content and recycling rates take effect?

They are measured from the date a producer's or representative organization's program plan is approved by DEC — not from a fixed calendar date. The first benchmark (10% post-consumer recycled content) applies one year after approval, with additional recycled-content and recycling-rate targets at the 5-, 10-, and 15-year marks.

Disclaimer: This page is intended for informational purposes only and does not constitute legal advice. Members or stakeholders with compliance questions specific to their operations should consult qualified counsel and confirm requirements directly with NYSDEC.

Last Updated: August 20, 2026