Developments in law and policy of energy, commodities and environment
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)…
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…
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…
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…
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…
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…
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…
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…
On July 23, the White House released its AI Action Plan, outlining the key priorities of the Trump Administration’s AI policy agenda. In parallel, President Trump signed three AI executive orders directing the Executive Branch to implement the AI Action Plan’s policies on “Preventing Woke AI in the Federal Government,” “Accelerating Federal Permitting of…
On June 23, 2025 the Council of the EU, which represents the 27 EU Member States, agreed on its negotiating mandate for the Corporate Sustainability Reporting Directive (“CSRD”) and Corporate Sustainability Due Diligence Directive (“CSDDD”) omnibus simplification.
This follows the European Commission’s omnibus proposal from February and is the next step in the EU’s legislative…
