- The Commission has unveiled a package of EUDR measures aimed at providing guidance and easing implementation.
- The delegated act will adjust the range of commodities and products falling within the EUDR’s scope.
- The Commission has confirmed that it will not reopen the text of the EUDR, so companies should continue preparing for the 30 December
Environmental Regulation
FCA Consults on UK SRS-Aligned Disclosure Rules for UK Listings
- 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
Federal Agencies Move to Return the Endangered Species Act to 2019 Interpretation
- 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 protected habitat.
- The US Fish and Wildlife Service and the National Marine Fisheries Service are accepting public comment on the
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 Grants Texas Primacy Over Class VI Carbon Storage Wells
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,” for Class VI underground injection control (UIC) wells within the state. Class VI UIC wells are used for the permanent…
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…
European Commission Maintains 30 December 2025 Application Date for EU Deforestation Regulation
The Commission has proposed new amendments to streamline EUDR obligations, while maintaining the application date for large and medium enterprises.
By Paul A. Davies, Michael D. Green, James Bee, and Toon Dictus
On 21 October 2025, the European Commission (Commission) announced a proposal introducing amendments designed to facilitate the implementation of the EU Deforestation Regulation (EUDR). Notably, the Commission proposed to maintain the current application date of 30 December 2025 for large- and medium-sized enterprises, contrary to…
EPA Proposes Repeal of GHG Reporting Program, Grants Arizona Primacy for UIC Wells
The agency’s actions have significant implications for the domestic carbon capture and storage industry.
By Joshua T. Bledsoe, Nikki Buffa, Jennifer K. Roy, Nolan Fargo, and Samantha Yeager
In the same week, the US Environmental Protection Agency (EPA) took two rulemaking actions with significant implications for the domestic carbon capture and storage (CCS) industry. On September 12, 2025, EPA proposed repealing the Greenhouse Gas Reporting Program (GHG Reporting Program), under which CCS projects report their emissions…
EPA Proposes Granting Texas Primacy for Class VI Wells
The proposal could accelerate the permitting process for carbon capture and storage projects in the state.
By Joshua T. Bledsoe, JP Brisson, Nikki Buffa, Michael Dreibelbis, Jennifer Roy, Nolan Fargo, and Samantha Yeager
On June 9, 2025, the US Environmental Protection Agency (EPA) signed a proposed rule that, if approved, would grant Texas primary enforcement authority, or primacy, for permitting Class VI Underground Injection Control (UIC) wells under the Safe Drinking Water Act (SDWA).
EPA Proposes Repeal of Power Plant GHG Emissions Standards
If finalized, the rule would eliminate both Obama- and Biden-era limits on GHG emissions from fossil fuel-fired power plants.
By Karl A. Karg, Stacey L. VanBelleghem, Nikki Buffa, Devin M. O’Connor, and G. Jack Mathews
On June 11, 2025, the US Environmental Protection Agency (EPA) released a proposed rule under the Clean Air Act (CAA) titled “Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units” (the Proposed Repeal).
Under the current Obama- and…