March 27, 2026 | CRA Member Newsletter Updates: Legislative, Regulatory, Federal, Local & Legal, Members News and Reminders & More.

AB 2564 Threatens Loyalty Programs & Customer Discounts in California

AB 2564 (Ward) was heard this week in the Assembly Privacy & Consumer Protection (P&CP) Committee and the following information outlines what it means for retailers and California consumers.

The Bottom Line:

While AB 2564 is framed as a consumer protection and affordability measure, the hearing made clear that, as currently drafted, the bill risks limiting discounts, reducing consumer choice, and increasing costs for everyday Californians.

What the Bill Does:

AB 2564 would prohibit so-called “surveillance pricing,” broadly defined as using personal information (including purchase history, browsing behavior, or location data) to offer customized prices.

While the author emphasized that the bill is not intended to eliminate discounts, the bill’s language is expansive, applying to pricing decisions made “in whole or in part” on personal data and backed by significant penalties - up to $12,500 per violation.

What We Heard in the Assembly Privacy Hearing

Supporters’ Perspective:

• Framed the bill as necessary to prevent unfair or discriminatory pricing
• Raised concerns about lack of transparency in how data may be used
• Positioned the bill as addressing a gap in current privacy law

Concerns Raised by CRA & the Business Community:

• The bill does not distinguish between price increases and discounts
• Many common practices - like coupons, loyalty rewards, and targeted promotions - could be restricted or discouraged
• The compliance structure is complex and ongoing, creating real operational challenges
• The level of legal risk could lead retailers to scale back or eliminate discounts altogether

Importantly, several committee members raised similar concerns and questioned whether the bill, as written, may be broader than intended.

Why This Matters for Consumers


The most effective point raised during the hearing and one that clearly resonated:

This bill doesn’t just target higher prices - it risks eliminating lower ones.

Consumers today rely on:

• Coupons and targeted savings
• Loyalty and rewards programs
• Promotions that help stretch household budgets

Restricting these tools does not improve affordability, it reduces access to savings.

Where Things Go Next

The bill passed out of committee, and will be heard next in the Assembly Judiciary Committee, but the conversation is far from over.

• The author signaled a willingness to continue discussions and consider amendments
• Committee members highlighted the need to address real-world implementation concerns

CRA will continue to engage with the author on the bill.

CRA’s Focus Moving Forward

CRA will continue to advocate for a balanced approach that:

• Protects consumer privacy
• Preserves access to discounts and savings
• Avoids unintended consequences that increase costs

At a time when affordability is a top priority for policymakers, our message is clear:

California consumers need more ways to save - not fewer.

If you have questions or would like to engage on this issue, please don’t hesitate to reach out. We will continue to keep you updated as the bill progresses.

Click HERE to read the alert we sent out to members yesterday, which includes our recap of the P&CP committee hearing.

SB 690 California Invasion of Privacy Act Reform and Litigation Landscape

SB 690 (Caballero) and the evolving litigation landscape under the California Invasion of Privacy Act (CIPA) is an issue that continues to present significant and growing legal exposure for retailers and other businesses operating in California.

Plaintiffs’ attorneys have increasingly sought to apply a 1967 wiretapping statute to routine online business practices. The result has been a wave of litigation targeting standard website technologies, often in ways that are difficult, if not impossible, for businesses to reconcile with existing compliance frameworks. SB 690 is intended to address that disconnect.

The bill advanced to the State Assembly (second house) and is expected to be heard in the Assembly Privacy Committee in April. At its core, SB 690 seeks to align CIPA with modern privacy law by clarifying that the processing of personal information for a commercial business purpose, particularly where already governed by the California Consumer Privacy Act (CCPA), does not constitute a violation of CIPA.

From a legal standpoint, this is a critical clarification. Today, businesses face a landscape where compliance with CCPA, California’s comprehensive and deliberately constructed privacy framework, does not insulate them from CIPA claims. SB 690 would help resolve that tension by recognizing that these statutes should operate coherently, rather than at cross purposes.

This legislative effort is being reinforced by a broad and growing coalition, including CRA’s partnership with the Alliance for Legal Fairness (ALF). As part of this work, we are continuing to elevate the real-world legal and operational impacts of CIPA claims, many of which involve routine technologies such as analytics, cookies, and advertising tools that are already expressly contemplated under CCPA.

For additional context and resources, visit the coalition website HERE.

In parallel, activity continues on the legal front. CRA and coalition partners are preparing an amicus brief in ongoing litigation to address the core legal issue: whether CIPA can appropriately be extended to modern digital interactions. The argument centers on the fact that CCPA already provides a comprehensive regulatory structure governing the data and technologies at issue. Courts are currently grappling with these questions and, in doing so, have issued inconsistent rulings, further compounding uncertainty for businesses. Notably, recent judicial commentary has acknowledged the lack of clarity and the need for legislative action - underscoring the importance of SB 690 moving forward. The current deadline for the amicus brief is April 8, 2026.

Looking ahead, advocacy will be critical. CRA will be joining coalition partners and other business organizations for a Lobby Day on May 12, 2026, where we will engage directly with legislators to share the real-world legal and business impacts of CIPA litigation. Additional details will be forthcoming, but we encourage participation, particularly from those with direct experience navigating these claims.

We also encourage you to review and share recent op-eds that help frame this issue from the perspective of impacted businesses:

• SB 690 Protects Small Businesses Like Mine
• Latino restaurants are caught in a legal trap

We will continue to provide our members updates as both the legislative and legal processes move forward. If you would like additional information, or to discuss how this may impact your company, please don’t hesitate to reach out to the CRA team.

Antitrust in California: New Risks, Rising Enforcement, Real Impact

AB 1776 (Ahuiar-Curry) – OPPOSE. Now in Print & Moving Quickly

The updated language for AB 1776 (Compete Act) is now officially in print and is expected to move to a hearing in Assembly Judiciary on April 7. You can read the bill language HERE.

The language closely tracks the California Law Revision Commission’s recommendations, and notably, the bill currently has limited co-author support, suggesting there is still meaningful opportunity for engagement.

From a retail perspective, this bill raises significant concerns:

• It represents a major expansion of California antitrust law, introducing new and untested standards
• It applies broadly to all businesses—regardless of size or market share
• It creates significant legal ambiguity, with limited guidance for courts or businesses
• It exposes retailers to increased litigation risk, including treble damages
• It may chill common, pro-consumer business practices, including pricing strategies, loyalty programs, and vendor relationships

CRA is joining a coalition letter, led by the California Chamber of Commerce, opposing AB 1776. As outlined in the coalition’s analysis, the bill departs from over a century of established antitrust precedent and introduces significant legal uncertainty that would impact businesses across all sectors of the economy. Read the DRAFT letter HERE.

Governor & Attorney General: Increased Focus on Antitrust Enforcement

Governor Newsom recently announced that California will take a leading role in antitrust enforcement efforts, positioning the state as a counterweight to perceived reduced federal activity and framing this effort as part of a broader strategy to address rising consumer costs. You can read his press release HERE.

Attorney General Rob Bonta has publicly indicated that his office is already deeply engaged in high-profile antitrust actions and is seeking additional funding and staffing to expand enforcement capacity.

His office is currently involved in major cases across media, entertainment, and live events markets. He emphasized that these cases are resource-intensive and ongoing, and that California intends to scale its efforts further. Additional staffing and outside counsel are under consideration to support this expanded enforcement agenda. You can read more HERE.

CRA's Legal Leadership

Developments like AB 1776 and the state’s expanding enforcement agenda underscore the need for coordinated, real-time legal strategy across the retail industry.

It is precisely for this reason that CRA launched the California Retail Law Center (CRLC) - to bring together in-house counsel and legal experts to engage directly on emerging legal, regulatory, and litigation risks impacting retailers.

The CRLC is designed to:

• Provide early intelligence and analysis
• Shape legal and policy strategy
• Ensure the retail industry has a strong, unified voice as these frameworks evolve

We strongly encourage member companies’ in-house legal teams to participate. Learn more about the CA Retail Law Center HERE.

If you are interested in joining or would like additional information, please reach out to the CRA team.

CRA supports fair and competitive markets. However, proposals like AB 1776, combined with a significant expansion in enforcement, risk creating uncertainty, increased costs, and unintended consequences for both retailers and consumers.

We will continue to advocate for a balanced approach that protects consumers while preserving the ability of retailers to innovate, compete, and deliver value.

Please do not hesitate to reach out with any feedback, questions or if you would like to engage more directly in these efforts.

Additional Legislative Outreach Updates

CRA Sponsored Bill to Establish a CalFresh and WIC Contingency Fund Passed Out of First Policy Committee Hearing

AB 2072 (Solache) was heard in Assembly Human Services this week and passed out of the committee unanimously. The bill heads to Appropriations next. CRA's Leticia Garcia provided lead testimony on the bill.

CRA's Sponsored bill to Fix California's Covered Battery-Embeded Product Program is Moving

AB 2549 (Zbur) Solid waste: Electronic Waste Recycling Act of 2003 is scheduled to be heard in its first policy committee - Assembly Environmental Safety & Toxic Materials (ESTM) - on April 14 with letters and bill amendments due April 6. CRA's Sarah Pollo Moo is working with Assembly ESTM Committee Chief Consultant Josh Tooker to update some sections of the bill that need clarification and also working with Assemblymember Zbur's office to meet with other stakeholders including Californians Against Waste. Sarah is also meeting with ESTM committee members and their staff.

Other Legislative Activity

CRA signed onto an Oppose Unless Amended coalition letter for SB 1180 (Allen) Plastic Pollution Prevention and Packaging Producer Responsibility Act: California Plastic Pollution Mitigation Fund and met with the Senate Environmental Quality (EQ) Committee Chief Consultant Brynn Cook to discuss our concerns with the bill, which have its first policy committee hearing on April 8 in Senate EQ. Read the draft opposition letter HERE. We will circulate a final copy once we have it.

CRA signed onto an oppose coalition letter for SB 1123 (Wiener) Administrative Procedure Act: major regulations, a bill of significant importance to anyone governed by regulations in California. SB 1123 would eviscerate the present obligation for agencies passing major regulations to complete a SRIA (Standardized Regulatory Impact Assessment) before implementing the regulation and make such regulations pass faster and with less thorough economic analysis. View the draft letter HERE. The bill will likely be heard in its first policy committee in mid-April.  

CRA did a "me too" in support for AB 2217 (Zbur) Criminal procedure: alternatives to arrest in the Assembly Public Safety Committee.

CRA signed onto an oppose coalition letter for AB 2021 (Schiavo) California Consumer Privacy Act of 2018: whistleblower complaints. Read the draft letter HERE.

CRA relayed our work with the author's office on AB 2076 (Lowenthal) The Parent’s Accountability and Child Protection Act: online marketplaces: nitrous oxide in the Assembly Privacy & Consumer Protection Committee. CRA was oppose unless amended to the previous version of the bill and are reviewing the recent changes with our members.

CRA did a "me too" in opposition to AB 1898 (Schultz) Workplace artificial intelligence tools in the Assembly Privacy & Consumer Protection Committee. View the opposition letter HERE.

CRA did a "me too" in opposition to AB 1777 (Garcia) in the Assembly Natural Resources Committee as part of a large coalition opposed to the Indirect Source Rule bill, which has been labeled a "Cost Driver" by the California Chamber of Commerce. View the draft oppose coalition opposition letter HERE.

CRA supported AB 1622 (Rubio) Electrified security fences in the Assembly Local Government Committee

CRA relayed our concerns in Assembly Public Safety Committee for AB 1605 (Ransom) Driving under the influence: alcohol sales.

Legislative Deadlines

• March 26 - Spring Recess
• May 29 - House of Origin Deadline
• June 15 - Budget Deadline
• July 3 - Summer Recess begins
• August 3 - Legislature reconvenes
• August 31 - Last Day for Legislature to pass bills
• September 31 - Last day for Governor to sign or veto bills

New CalRecycle E-Waste Branch Chief

CalRecycle hired the new branch chief for the e-Waste program, Alan Ilusorio.

Alan has been a member of the CalRecycle team since 2009, and brings a strong expertise in compliance monitoring, data-driven enforcement, regulatory oversight, and program leadership. Most recently, as a Senior Environmental Scientist Supervisor in the Jurisdiction and Agency Compliance and Enforcement (JACE) Branch, Alan oversaw SB 1383 compliance for the past seven years—guiding teams through policy development, regulatory implementation, complex stakeholder challenges, and development of enforcement processes that strengthen statewide organic waste diversion and methane reduction goals.

Alan will be based at CalRecycle's CalEPA Headquarters in Sacramento on the 9th floor.

What Retailers Need to Know About Supply Chain & Operations for the 2028 LA Olympics and Paraolympics

With the 2028 Summer Olympic and Paralympic Games on the horizon, we have a once-in-a-generation opportunity, and responsibility, to prepare for how these Games will impact retail operations across Southern California.

The California Retailers Association is excited to invite you to a special briefing designed to help our members get ahead of what’s coming.

ZOOM MEETING WITH SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS (SCAG)

Friday, April 25th 9 am Pacific Time

Register for the zoom HERE.

What we’ll cover:

• Supply Chain Impacts: Anticipated disruptions to goods movement, including delivery restrictions, lane closures, and congestion across key corridors and last-mile delivery zones
• Freight & Logistics Strategies: Emerging approaches such as off-peak deliveries, rerouting, staging of goods, and curb management to maintain supply chain fluidity
• Employee Movement & Access: What to expect for workforce mobility across Los Angeles and the broader Southern California region during the Games
• Security & Venue Restrictions: How designated security perimeters and operational policies may impact store access, deliveries, and customer flow
• Direct Engagement: Opportunity to ask questions and provide input as regional planning efforts continue

Regional planning efforts are being led by the Southern California Association of Governments (SCAG) and public agency partners, these Games will bring significant operational changes, but also a coordinated effort to ensure businesses can continue to operate effectively through thoughtful planning and collaboration.

This session is not just about awareness - it’s about ensuring the retail community has a seat at the table as strategies are developed and implemented.

In a region as complex and interconnected as Southern California, proactive planning will be critical. Retailers that engage early will be best positioned to minimize disruption, manage costs, and continue serving customers seamlessly during the Games.

We hope you’ll join us for this important and timely conversation.

Los Angeles Draft CII Permit Update

Following the Los Angeles Regional Water Quality Board (Board) workshop on the draft Commercial, Industrial, and Institutional (CII) Permit, the coalition working on this issue, which includes CRA, is expecting to receive excerpts of the revised CII Permit for review. The coalition will then have about a week to provide feedback. In the meantime, Board staff was planning to provide an update on discussions/negotiations to the Board this week. While not firm, they are aiming to set an adoption hearing in June.

As a reminder, the Board directed staff to outreach to stake holders to discuss various topics for which board members requested additional input with the understanding that these discussions would help facilitate further refinements to the draft Permit that staff plan to report back to the Board by the end of the first quarter of 2026. These included:

• Who should be the permittee
• Option 1 capacity and pricing
• Permit implementation timing
• Application of the Permit to properties with Mixed Use designations
• Initial sampling requirements
• Definition of permeable surfaces

For more information on the draft Permit, please see HERE.

To see the revised draft Permit, please see HERE.

For more information, don't hesitate to reach out to Sarah or Ryan.

Federal Updates

IEEPA Tariff Refunds Slides and Recording

A copy of the presentation and a link to the recording from a talk hosted by the National Retail Federation about the latest The International Emergency Economic Powers Act (IEEPA) tariff refunds can be accessed HERE and HERE.

CRA ad NRF will continue to keep members up to date on tariff-related issues and will schedule future calls when there is additional guidance on the tariffs refund process.

Local Updates

South Coast Air Quality Management District Governing Board Leadership Changes and Appointments

On February 6, Councilmember Michael A. Cacciotti was sworn in as Chair of the Governing Board, with Councilmember Larry McCallon appointed Vice Chair. Chair Cacciotti has served on the Governing Board since 2008, representing the Cities of the Eastern Region of Los Angeles County. He also serves on the South Pasadena City Council and previously spent nearly 20 years as a Deputy Attorney General with the California Department of Justice. Vice Chair McCallon, a Governing Board member since 2015, is a U.S. Air Force veteran and retired businessman who brings decades of experience in regional leadership, transportation, and public service.

The Governing Board also welcomed Cedric Jamie Rutland, MD, FCCP, as a new member following his appointment by Governor Gavin Newsom. A triple boardcertified physician in internal medicine, pulmonary disease, and critical care medicine, Dr. Rutland brings significant clinical and public health expertise focused on respiratory health, patient care, and health equity.Get more information including additional leadership changes and appointments to the SCAQMD HERE.

Albertsons Southern California Reaches 1,000 RMC Graduates

The Western Association of Food Chains (WAFC) recognized the Albertsons Southern California Division for reaching a remarkable milestone — 1,000 graduates of the Retail Management Certification (RMC) program, a testament to the division's unwavering commitment to associate development and growth.

What began as an opportunity to provide free, accessible education for retail associates has grown into a true movement within the organization, one that continues to be backed by leadership at every level. Today, the program benefits from the steadfast support of Wayne Denningham, EVP & President of the SoCal Division; Jim Wallace, SVP of Operations and WAFC Board Member; Sheryl Salazar, SVP Marketing & Merchandising; Dana Rose Stauffer, VP of Human Resources; and Mario Fuentes, Manager of Learning & Development.

The program has cultivated a genuine culture of advocacy, with graduates enthusiastically sharing their experiences and encouraging peers to participate. What makes the SoCal RMC program truly exceptional is that it has never been just an HR initiative, a testament to its lasting impact. Keep reading.

Soles4Souls: Turning Excess Inventory Into Opportunity

Retailers across the world are partnering with Soles4Souls to reduce waste, extend product life, and create meaningful social impact.

Every year, millions of pairs of shoes and apparel items go unsold or unused. Instead of ending up in landfills, these products can create meaningful impact for people and communities around the world.



Soles4Souls is a global nonprofit that creates opportunity for people through shoes and clothing. By working with retailers and brands, Soles4Souls helps extend the life of usable goods while supporting sustainability and circularity initiatives.

Retailers partner with Soles4Souls in several ways — donating excess or returned inventory, launching customer take back programs, and engaging employees through volunteer opportunities and corporate giving initiatives. Together, these efforts keep usable goods in motion, reduce waste, and create meaningful impact for communities around the world.

Together with its partners, Soles4Souls has helped create millions of dollars in economic opportunity, supported communities recovering from disasters, and provided brand-new shoes to children in need.

Interested in partnering with Soles4Souls?

Learn how your organization can support sustainability and circularity initiatives while creating global impact - Partner With Soles4Souls

CRA Work Groups



The CRA Team continues our 2026 work group meetings including our Monthly Policy, Environmental Sustainability, Food, Alcohol and Grocery and Community Pharmacy and Privacy Groups. If you haven't yet, we encourage you and your teams - including your subject matter experts - to sign up for CRA's working groups today!

Click Here to View and Sign Up for CRA Work Groups

California CUPA Forum

CRA's Sarah Pollo Moo attended the annual California Certified Unified Program Agency Forum (Cal CUPA), which is a statewide association of local agencies throughout California including county - or in some cases city - environmental health or fire departments) that oversee hazardous materials management in the state.

There are a total of 81 CUPAS throughout California and each one can vary in terms of management and inspection style and procedures. These agencies are certified by CalEPA to consolidate, implement and enforce six hazardous waste and materials management programs.

The Forum coordinates these agencies to ensure consistent enforcement across the state and the event also includes industry, recycling service providers and some environmental non-profit organizations. Many of CRA's member companies were in attendance. The Forum provided a crucial learning and networking opportunity for the CRA Team as we continue to expand our work on environmental issues in California.

California Retailers Association https://calretailers.com/

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