Regular Session
Government Affairs & Regulatory Compliance Analysis
HB3866 establishes a strict regulatory regime for Intermediate Bulk Container (IBC) recycling and reconditioning facilities, implementing a mandatory 2,000-foot buffer zone from private residences and a new TCEQ registration program. While existing facilities are grandfathered, any facility commencing operations on or after September 1, 2025, faces immediate siting prohibitions and significant annual fees if they store more than 50 IBCs.
Rep. Brooks Landgraf·House Bill·Regular Session
Municipalities (authorized to adopt ordinances prohibiting operations within 2,000 feet of residences) • Texas Commission on Environmental Quality (TCEQ)
This legislation has regulatory implications for the following Texas businesses and organizations:
Affected business types:
mediumModerate costs expected for implementation.
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Key implementation requirements and action items for compliance with this legislation
JD Key Consulting specializes in Texas regulatory compliance strategy. Work directly with James Dickey—former Chairman of the Republican Party of Texas—to understand this bill's impact on your operations and develop an actionable compliance plan.
Schedule a ConsultationInformation presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.
This bill's path through the Texas Legislature
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Common questions about HB3866
HB3866 establishes a strict regulatory regime for Intermediate Bulk Container (IBC) recycling and reconditioning facilities, implementing a mandatory 2,000-foot buffer zone from private residences and a new TCEQ registration program. While existing facilities are grandfathered, any facility commencing operations on or after September 1, 2025, faces immediate siting prohibitions and significant annual fees if they store more than 50 IBCs.
HB3866 was authored by Texas Representative Brooks Landgraf during the Regular Session.
HB3866 was signed into law by Governor Greg Abbott on June 20, 2025.
HB3866 is enforced by Municipalities (authorized to adopt ordinances prohibiting operations within 2,000 feet of residences) and Texas Commission on Environmental Quality (TCEQ).
The cost impact of HB3866 is estimated as "medium". This may vary based on industry and implementation requirements.
HB3866 addresses topics including environment, environment--hazardous, toxic & nuclear waste, environment--water, safety and storage tanks.
Key dates for HB3866: Effective date is 2025-06-20. Rulemaking: Establish annual registration fees and inspection protocols via rulemaking. (Prior to March 31, 2027). Consult with legal counsel regarding applicability.
HB3866 establishes the following penalties: administrative penalty of Variable (Standard TCEQ administrative penalties) for Installing/operating a non-exempt facility within 2,000 feet of a private residence.; administrative penalty of Variable (Standard TCEQ administrative penalties) for Failure to register a facility holding >50 intermediate bulk containers.. Consult with legal counsel for specific applicability to your situation.
JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.
