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…
The proposed rule would scale back federal jurisdiction under the Clean Water Act.
By Nikki Buffa, John C. Heintz, Michael G. Romey, Jennifer K. Roy, Lucas I. Quass, and Samantha Yeager
On November 17, 2025, the United States Environmental Protection Agency (EPA) and the Department of the Army, Corps of Engineers (USACE) (together with EPA…
The rule positions the Railroad Commission of Texas as the primary permitting authority over Class VI wells and could expedite CCS projects in the state.
By Joshua T. Bledsoe, Nikki Buffa, Jennifer K. Roy, Nolan Fargo, and Samantha Yeager
The US Environmental Protection Agency (EPA) has approved Texas’s application to assume primary enforcement responsibility, or “primacy,”…
California Governor Gavin Newsom signed legislation lifting moratorium on transportation of carbon dioxide by pipeline.
By Joshua T. Bledsoe, Marc T. Campopiano, Brian McCall, and Shawna Strecker
On October 10, 2025, Governor Gavin Newsom signed legislation aimed at boosting California’s carbon capture, removal, utilization and storage (CCUS) market. CCUS involves capturing carbon dioxide (CO2) from point-sources —…
With the new proposal, EPA seeks to limit the reporting burden on the chemical industry.
By Julia A. Hatcher, Tom Lee, and Hunter J. Kendrick
On November 10, 2025, the US Environmental Protection Agency (EPA) released its much anticipated proposed changes to what is often referred to as the “8(a)(7) Rule” that requires businesses to report on…
