• 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 trust and transparency for carbon credit methodologies and is expected to influence existing and emerging practices for certification in the

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 funding.
  • Questions remain on how the stockpile will take into account US policy priorities and function in practice.

Introduction

On

  • 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,

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

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 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)