- On 30 January 2026, the FCA published its Consultation Paper on the switch from TCFD-aligned disclosure rules for listed companies to UK SRS-aligned disclosure rules (CP26/5
FCA Consults on UK SRS-Aligned Disclosure Rules for UK Listings
Washington State’s Amended PFAS Rule Restricts New Product Categories and Adds Total Fluorine Threshold
- 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 evidence.”
- Washington State’s adoption of a total fluorine threshold breaks from other states that previously adopted total organic fluorine thresholds,
Trump Administration Proposes New Rule Defining “Waters of the United States”
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 Agencies) announced a proposed rule that would revise the definition of “waters of the United States” (WOTUS) under the
EPA Proposes Exemptions to TSCA PFAS Reporting Rule, New Deadline Extension
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 the manufacture and import of certain per- and polyfluoroalkyl substances (PFAS).1 As the name suggests, the rule derives from
New York Establishes CERCLA-Like Liability for Inactive Hazardous Waste Disposal Sites
New statute allows the government to recover costs and natural resource damages from a broad set of PRPs.
By Gary P. Gengel, Thomas C. Pearce, G. Jack Mathews, and Gina Kwon
On May 9, 2025, New York Governor Kathy Hochul signed into law a broad array of amendments to the state’s Environmental Conservation Law sections pertaining to the Inactive Hazardous Waste Disposal Site program, also known as the state Superfund program (the Amendments). The Amendments address (1)
European Commission Proposes Further One-Year Delay to the EU Deforestation Regulation
A new proposal could delay the EUDR implementation to 30 December 2026, as the Commission cites IT concerns.
By Paul A. Davies, Michael D. Green, James Bee, and Toon Dictus
On 23 September 2025, the European Commission (Commission) announced that it will propose postponing the application of the EU Deforestation Regulation (EUDR) by an additional year.
The Commissioner for Environment, Water Resilience and a Competitive Circular Economy sent letters to the European Parliament and the Council indicating
Singapore Signs Further Implementation Agreements and Announces Nature-Based Carbon Credit Projects
Singapore continues to expand its list of approved host countries, carbon crediting programs, and methodologies that meet the established criteria.
By Paul A. Davies, Michael D. Green, Farhana Sharmeen, James Bee, Kevin Mak, and Qingyi Pan
On September 16, 2025, Singapore signed an implementation agreement on carbon credits in cooperation with Vietnam, expanding the total number of executed implementation agreements to nine. The Ministry of Trade and Industry (MTI) announced: “Singapore is committed to channelling
South Korea Reintroduces Human Rights and Due Diligence Act
The reintroduction of South Korea’s due diligence law potentially marks a significant advancement for human rights and ESG initiatives in the region.
By Paul A. Davies, Michael D. Green, Wonsuk (Steve) Kang, Farhana Sharmeen, and Jiou (Alex) Park
On June 13, 2025, South Korean Representative Jung Tae-Ho reintroduced the proposed “Bill for the Protection of Human Rights and the Environment for Sustainable Business Management” (the Bill). The current draft of the Bill builds upon a similar
SEC Responds to Eighth Circuit, Asking Eighth Circuit to Rule on Climate Disclosure Litigation
The SEC has stated that a ruling would help it determine the relevance of future rulemaking.
By Betty Huber and Austin Pierce
On July 23, 2025 the US Securities and Exchange Commission (SEC or Commission) submitted a status report ordered by the Eighth Circuit in April 2025 on the Commission’s plans with respect to the pending litigation challenging the SEC’s final climate disclosure rules (the Rules).
As a reminder, the SEC approved the Rules — which require companies to disclose
European Commission Unveils Two Proposals Impacting the EU Batteries Regulation
The proposals are part of the broader “omnibus” initiative and would postpone due diligence obligations and introduce a “small mid-cap” category for in-scope companies.
By Paul A. Davies, Michael D. Green, James Bee, and Toon Dictus
On 21 May 2025, the European Commission (Commission) published two proposals affecting the timeline and scope of the Regulation concerning batteries and waste batteries (the Batteries Regulation, or EUBR), aimed at streamlining compliance and providing clarity for economic operators within the