California regulators tasked with implementing and enforcing the state’s two landmark climate disclosure laws released draft regulatory text on December 9, 2025, providing additional insight on key issues, including initial deadlines for reporting greenhouse gas (“GHG”) emissions and details on how regulators will determine annual fees. The release of the draft regulations is the latest
Environmental
The European Commission’s New Green Claims Guidance: What Businesses Need to Know
The European Commission has published a detailed Q&A guidance document (the “Guidance”) on the interpretation and application of the Greenwashing Directive’s environmental claims and circular economy rules, which EU Member States will have to enforce from September 27, 2026.
The Greenwashing Directive updates the EU’s consumer protection rules to tackle greenwashing and promote products that are…
The CSRD/CSDDD Omnibus Endgame: Key Points for Companies
After months of uncertainty, the outlook for key EU sustainability laws is far clearer.
On November 13, 2025, the European Parliament adopted its negotiating position on the Corporate Sustainability Reporting Directive (“CSRD”) and the Corporate Sustainability Due Diligence Directive (“CSDDD”) Omnibus simplification. This follows the European Commission’s Omnibus proposal in February (see more here)…
Task Force for Corporate Action Transparency Launches New Frameworks for Climate Action Reporting
In the lead-up to COP30 in Brazil, the newly created Task Force for Corporate Action Transparency (TCAT) launched two comprehensive greenhouse gas reporting frameworks designed to fill an important gap in how companies measure, report on, and verify their corporate climate actions. TCAT leadership has indicated that the frameworks will be formally launched at COP30…
The Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for Stakeholders
In late October, the Greenhouse Gas Protocol (“GHG Protocol”) proposed updated Scope 2 guidance for companies quantifying and reporting their greenhouse gas (“GHG”) emissions. If finalized as proposed, the guidance would have significant impacts on how companies plan their renewable energy investments and measure progress toward their climate goals. The main changes proposed to the…
Carbon Measures Coalition Signals Growing Momentum for Ledger-Based Carbon Accounting
On October 20, 2025, a coalition of nineteen leading companies in the energy, finance, and logistics sectors, launched the Carbon Measures Coalition, proposing a significant departure from established carbon accounting frameworks. The Coalition represents a prominent industry-led effort to move away from traditional inventory-based emission calculation methods toward a new model: ledger-based emissions tracking…
EPA Proposes Changes to TSCA PFAS Reporting Rule
On November 10, 2025, EPA released a proposed rule under the Toxic Substances Control Act (“TSCA”), proposing to amend its reporting requirements relating to per- and polyfluoroalkyl substances (“PFAS”). The original rule, promulgated in 2023, led to concerns by some regulated entities that it would be difficult to collect the data required by the rule…
California AG Targets Plastic Bag Manufacturers for Misleading Recyclability Claims
On October 17, 2025, California Attorney General Rob Bonta announced enforcement actions against seven plastic bag manufacturers for allegedly violating state environmental and consumer protection laws through explicit and implicit claims that plastic bags sold in California were recyclable. This comes at the conclusion of an investigation of these plastic bag manufacturers initiated by the…
State Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program
While the Environmental Protection Agency (“EPA”) is proposing to amend the federal Greenhouse Gas Reporting Program (“GHGRP”) to remove reporting requirements for nearly all sources, it remains important for companies to track developments and manage their compliance obligations with existing and emerging state GHG reporting programs. Several states, such as California, already have some form…
Spain Proposes Strict Sustainability Requirements for Data Centers
The Spanish Ministry for Ecologic Transition and Demographic Challenge (“MITECO”) has launched a public consultation on a Draft Royal Decree (“Draft Royal Decree”) that would impose strict energy efficiency and sustainability requirements on data centers in Spain. The proposed requirements of the Draft Royal Decree are broader and stricter than the requirements on data centers…