Long-awaited study highlights data gaps and stops short of making definitive safety determinations.
By Julia A. Hatcher, Tom Lee, Hunter J. Kendrick, and Meryl E. Bartlett
Key Points:
Based on product listings submitted from 2022 through August 2024 identifying all ingredients in each product, FDA identified 51 PFAS intentionally added as ingredients, which were present in 0.41%…
The European Commission has adopted a delegated act setting out certification methodologies for permanent carbon removals.
By Jean-Philippe Brisson, Michael D. Green, James Bee, and Toon Dictus
Key Points
The EU has adopted methodologies for certifying activities that remove carbon dioxide from the atmosphere and store it.
The voluntary EU CRCF framework is intended to build increased…
UK SRS S1 and S2 are now available for voluntary use, while the UK government considers which companies should be required to report under the new standards.
By Michael D. Green, Nicola Higgs, Betty M. Huber, Anne Mainwaring, James Bee, Toon Dictus, and Sara Sayma
On 25 February 2026, the UK government’s Department of…
The publication marks the finalisation of the Sustainability Omnibus process, resulting in increased certainty for businesses.
By Michael D. Green, James Bee, and Toon Dictus
On 26 February 2026, the EU’s Omnibus I Directive, otherwise known as the Sustainability Omnibus, which introduces significant amendments to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive…
The recently announced stockpile represents significant opportunities, but much of that depends on unresolved details that companies must continue to monitor.
By Charles E. Carpenter, Joshua W. Marnitz, and Austin J. Pierce
Key Points:
The $12 billion stockpile has been characterized as similar to other US strategic “reserves” but has a distinct setup with both public and private…
The use of PFAS, often referred to as “forever chemicals”, is widespread, but certain compounds have been linked to environmental harm and human health impacts.
By Michael D. Green, Julia A. Hatcher, Tom Lee, Hunter J. Kendrick, James Bee, and Toon Dictus
Key Points:
The UK government’s PFAS Plan is built on three pillars: understanding…
The FCA is seeking views on proposals to update its climate-related disclosure rules for listed issuers to align with the new UK SRS.
By Mark Austin CBE, Michael D. Green, Nicola Higgs, Betty M. Huber, Anne Mainwaring, James Bee, Toon Dictus, and Sara Sayma
Key Points:
On 30 January 2026, the FCA published…
The amended rule adds to the growing patchwork of state-level PFAS laws and to compliance burdens.
By Julia A. Hatcher, Tom Lee, and Hunter J. Kendrick
Key Points
Any product in excess of the 50 ppm total fluorine threshold is presumed to contain “intentionally added” PFAS and subject to the rule unless this presumption is rebutted with “credible…
This year we expect ESG/sustainability to be influenced by several macro trends, including technology, geopolitics, and capital markets.
By Paul A. Davies, Betty M. Huber, and Michael D. Green
In 2026, we expect that business and legal leaders who successfully disentangle and separate economic, political, and legal risk with a clear strategic focus will be best able to…
Six legislative proposals from the Commission are intended to simplify environmental legislation.
By Paul A. Davies, Michael D. Green, James Bee, and Toon Dictus
Key Points:
Target areas for simplification include industrial emissions, circularity, extended producer responsibility, environmental assessments, and geospatial data.
The Environmental Omnibus will now be submitted to the European Parliament and the Council for…
Following complex negotiations, the EU has agreed substantive changes to sustainability reporting and due diligence rules.
By Paul A. Davies, Michael D. Green, James Bee, and Toon Dictus
Key Points:
Major changes to the CSRD and CSDDD include narrowed scope, removal of the climate transition plan obligation, and targeted exemptions and timing reliefs.
The final text reflects…
Proposed rules would reverse Biden-era regulations under the ESA and return to the regulatory framework implemented during the first Trump administration.
By Nikki Buffa, Jennifer K. Roy, and Janice M. Schneider
Key Points:
The proposed rules would revise definitions and analysis standards for interagency consultations, move toward species-specific rather than blanket protections, and increase agency discretion in determining…
