That's an excellent and often overlooked question. As someone who advocates for inclusive urban design, I can tell you the answer is: it depends, and often they don't fully meet the spirit or the letter of the law. The Americans with Disabilities Act (ADA) sets standards for public elements, and while trash cans aren't explicitly detailed like ramps or doors, their placement and design fall under broader requirements for accessible routes and reach ranges.
The key issue is obstruction. A trash can placed on a narrow sidewalk can easily reduce the clear width of an accessible route to less than the required 36 inches. This creates a barrier for wheelchair users. Furthermore, if a user needs to open a lid or use a pedal, the operable parts should be within ADA forward and side reach ranges—no higher than 48 inches for a forward reach and 54 inches for a side reach if over an obstruction.
Many older or standard "barrel-style" cans with high openings fail this test. Best practice now points to using lower-profile receptacles with easy-open mechanisms, ensuring they are placed in wide alcoves or areas that don't impede the path of travel. So, while a city might not get cited specifically for a non-compliant trash can, its poor placement contributes to a network of barriers. True accessibility means considering every element of the public realm, right down to where we throw away our trash.