Industrials Regulatory News and Trends - November 21, 2025

Welcome to Industrials Regulatory News and Trends. In this regular bulletin, DLA Piper lawyers provide concise updates on key developments in the industrials sector to help you navigate the ever-changing business, legal, and regulatory landscape.

Toyota’s North Carolina battery plant is open for business. On November 12, Toyota began production at its first battery factory outside Japan: a USD14 billion, 1,850 acre complex in Liberty, North Carolina, expected to create up to 5,100 jobs and supply batteries for both hybrid and fully electric vehicles. Toyota stated that, beginning in 2026, it will shift production of the Toyota RAV4s to 100-percent hybrid, and it expects plug-in hybrid vehicles to make up 20 percent of its overall US production. The company also announced an additional USD10 billion investment in its US operations over the next five years.

Ports of Long Beach, Los Angeles commit to developing zero-emissions infrastructure. On November 10, the Long Beach Board of Harbor Commissioners unanimously approved a binding cooperative agreement with the South Coast Air Quality Management District (SCAQMD) and the Port of Los Angeles that sets enforceable deadlines for developing zero-emission infrastructure across the nation’s busiest port complex. The twin ports of Los Angeles and Long Beach, known as the San Pedro Port Complex, handle 40 percent of all container cargo entering the US and, according to the Los Angeles Times, are the single largest source of smog-forming pollution in Southern California, releasing more emissions than the region’s six million cars each day. Approved by SCAQMD on November 7, the framework includes substantial enforcement provisions, with penalties ranging from USD50,000 to USD200,000 per violation. Those funds will be directed toward projects benefiting communities near the ports. The agreement outlines a phased approach to achieving zero-emission operations, covering multiple equipment types by May 2027, with finalized plans for all categories to be in place by the end of 2029. These commitments build on the Clean Air Action Plan (CAAP), a collaboration between the ports that since 2005 has guided them to reduce their emissions of diesel particulate matter by 90 percent, nitrogen oxides by 68 percent, and sulfur oxides by 98 percent.

North American manufacturers cut orders of raw materials amid weak supply chain conditions. Manufacturers in North America significantly reduced their purchases of raw materials and intermediate goods in October, according to the latest data from the GEP Global Supply Chain Volatility Index. The Index registered at -0.33 globally in October, showing that supply chain capacity is not being fully utilized. In North America, the Index fell to its lowest level since March: -0.45. This decline reportedly suggests a possible slowdown in production within North America, reflecting a global environment characterized by underutilized supply chains. Chinese factories are also reducing input buying, the Index reported, increasing spare capacity across Asia’s suppliers. Based on a monthly survey of 27,000 businesses worldwide, the Volatility Index tracks demand conditions, shortages, transportation costs, inventories, and backlogs. The next release of the GEP Global Supply Chain Volatility Index will be in December.

Navigating US congressional inquiries: Key considerations for non-US companies. United States congressional inquiries have become an important instrument to shape policy agendas, test industry practices, influence public opinion, and apply pressure on industries and companies seen as politically relevant. Non-US companies can face unexpected obstacles in these matters due to a number of factors, including cross-border considerations, conflicting laws, and cultural differences. Our alert looks at practical challenges non-US companies may face in congressional inquiries and provides strategic considerations.

US releases 2025 list of critical minerals, adding ten new ones. On October 7, the United States Geological Survey (USGS) published the final 2025 List of Critical Minerals in the Federal Register, adding ten new minerals to expand the 2022 list to 60 commodities. The new entries are boron, copper, lead, metallurgical coal, phosphate, potash, rhenium, silicon, silver, and uranium. These minerals were added to address supply chain vulnerabilities for industries like electronics, steelmaking, agriculture, renewable energy, nuclear power, and national defense. Last year, the US imported 80 percent of the rare earth elements it used. The expansion of the list reflects a strategic effort to bolster domestic production and reduce reliance on foreign sources for minerals essential to national security and the economy. Designating critical minerals unlocks expedited federal permitting under FAST-41, Defense Production Act funding, tax incentives, and streamlined reviews, potentially accelerating projects. The Department of Interior can also provide expedited permitting procedures for critical mineral projects.

UK’s Sustainable Aviation Fuel Bill features revenue certainty mechanism. The second reading of the United Kingdom’s Sustainable Aviation Fuel (SAF) Bill took place in Parliament’s House of Lords on November 20. The bill, introduced this summer, is part of the government’s Jet Zero strategy, which has set a target of zero emissions from aviation by 2050. It would require all fuel suppliers to blend a minimum proportion of SAF into their fuels, starting at two percent and rising to 22 percent by 2040. Furthermore, to support investment in SAF production in the UK, the Sustainable Aviation Fuel Bill introduces a new Revenue Certainty Mechanism (RCM). The RCM would ensure that clean fuel producers receive a guaranteed price for their fuel, offering long-term market stability and encouraging new investment – at present, the UK has only one SAF production plant. If the market price falls below a fixed point, the RCM would ensure that SAF producers are paid the difference. The mechanism would be funded through a levy imposed on UK aviation fuel suppliers, reflecting the "Polluter Pays" principle already enshrined in the Environmental Act 2021. Royal assent is expected by the end of 2026. The SAF Act is pursuant to the Renewable Transport Fuel Obligations (Sustainable Aviation Fuel) Order 2024, which went into effect on January 1 this year. Relatedly, in May, the UK Department of Transportation announced it would allocate an additional GBP400,000 in funding to support the testing and qualification of green fuels to get them to market more quickly.