As part of an emergency certification bill, Connecticut passed a new warehouse quota law effective July 1, 2026. Connecticut joins California, New York, Minnesota, Washington and Oregon in passing laws that regulate quotas regarding productivity in warehouse distribution centers.
Why? What are the Consequences?
The new law is aimed at protecting the physical safety of warehouse workers, who face the highest workplace injury rates in the state. The law is intended to prohibit unreasonable production standards which might encourage warehouse workers to take shortcuts. The law empowers employees to challenge “unreasonable” efficiency standards that may lead to higher levels of injury.
However, beyond this, the law may have unintended consequences that affect the entire state, not just warehouse employers and employees. Critics worry about the increased operational and litigation costs Connecticut businesses may face. If they are correct, Connecticut may see warehouses leave the state and relocate to states with lower operational costs and litigation risk. This could have a ripple effect if employers decide to remove related operations out of the state as well. This is especially true given the ease with which an employer could move (only a limited distance) and be in another state.
On the other hand, supporters argue Connecticut could be a pioneer for workplace safety while still balancing the operational efficiency and costs for employers. On principle this sounds good, but the case for the critics seems a much easier one to make.
Which Employers are Impacted?
Connecticut’s new Warehouse Quota Notice Law will apply to non-exempt employees who work at “warehouse distribution centers” with at least 250 employees at a single site, or 1,000 employees statewide. Additionally, it will only apply to operations identified by certain North American Industry Classification System codes: General Warehousing and Storage, Merchant Wholesalers, Electronic Shopping and Mail-Order Houses, Couriers and Express Delivery Services, Warehouse Clubs and Supercenters, All Other General Merchandise Stores and Home Centers. For a complete list of the applicable codes, click here (see lines 1330-39). Connecticut’s version of the law will not apply to drivers who travel to and from warehouse distribution centers, but only those working on-site.
What is Required of Employers?
The law regulates “quotas” which is defined as a work performance standard related to productivity speed or the number of tasks performed within a certain time-period. Covered employers must provide their non-exempt employees with written descriptions of any quota and the repercussions for failing to meet the quota. The notices are required to be distributed by August 1st, 2026. Any employees who join after that date must be provided with the notice upon hire. Similarly, if an employer decides to modify the quota, affected employees must receive notice of the change, in writing, within two days of the rule’s effective date.
Connecticut also prohibited any quotas that set a performance standard for increments of time shorter than a single workday. Also, quotas that measure performance based on the work of other employees are prohibited.
The new law also includes a recordkeeping requirement for covered employers. All records regarding productivity quotas and notices must be maintained for three years.
How Should Employers Proceed?
Connecticut employers must first determine if they are covered by this new law. If so, compliance, including required notices, must be added to the Company’s standard policies and practices. All of this must be done while keeping operating and litigation costs as low as possible. If Employers have any questions, they should seek competent Connecticut employment and labor law counsel.
On a deeper level, everyone should recognize this law exemplifies a serious trend of state and federal agencies monitoring and controlling how businesses operate. This is not new and happens on both a state and/or federal level. To the extent such laws keep workers safe, this may be good. To the extent it takes over the Company’s business judgement and places the burden and risk on the Employer, there is reason for concern.
Brody and Associates regularly advises management on compliance with the latest local, state and federal employment laws. If we can be of assistance in this area, please contact us at info@brodyandassociates.com or 203.454.0560.