Horizon – News and Trends in Sustainability Law

Disclosures and voluntary reporting

CARB holds public hearing on comments to its proposed regulations for SBs 253 and 261. On February 26, the California Air Resources Board (CARB) held a hybrid hearing on its proposed regulations to implement SB 253, the Climate Corporate Data Accountability Act, and SB 261, the Climate-Related Financial Risk Act. CARB has moved forward with rulemaking to implement the laws despite the Ninth Circuit’s ongoing injunction against the latter. As we reported last month, the proposed regulations, announced in early December, include a formula for calculating fees, authorize CARB to penalize entities that fail to pay required fees, and set August 10 as the initial deadline for in-scope entities to report their Scope 1 and 2 emissions under SB 253. The regulations also state that, starting this year, CARB will issue fee notices to in-scope entities by September 10 annually. The fees will cover the costs of administering the programs. During the February 26 hearing, the issue garnering the most attention was CARB’s proposal to exempt insurance companies from greenhouse gas (GHG) reporting under SB 253 to avoid potential duplication with requirements promulgated by the California Department of Insurance (DOI). Currently, the DOI requires insurance companies in California to report on their climate-related financial risk in accordance with the Task Force on Climate-related Financial Disclosures (TCFD) framework, which has a line item for disclosing Scope 1 and 2 emissions and, if appropriate, Scope 3 emissions. Insurance industry representatives supported the exemption because it would help avoid duplication and potential conflicts between the disclosure requirements of DOI and CARB. Other participants, including legislators and their representatives, argued that CARB lacks the statutory authority to exempt insurers from the requirements of SB 253 and that requiring reporting would not result in conflict or even duplication. CARB addressed these concerns by noting the DOI disclosure requirement and by citing the avoidance of duplication as one of the mandates the agency must observe when regulating. CARB announced that it has approved the proposed regulations, which must now be submitted to the Office for Administrative Law for approval. Also see our report on the related litigation in Chamber of Commerce v. CARB.

New York Senate passes Climate Corporate Data Accountability Act. The New York State Senate has passed SB 9072, the Climate Corporate Data Accountability Act, and the bill has moved to the Assembly’s Standing Committee on Codes for review. SB 9072 aims to combat greenwashing and encourage greater accountability in corporate environmental activities by increasing transparency in corporate climate reporting. Like California’s SB 253, under SB 9072, companies doing business in the state of New York whose revenue exceeds USD1 billion annually will be required to publicly disclose all Scope 1 and Scope 2 emissions data from the prior fiscal year to an emissions reporting organization, starting in 2028. In 2029, this reporting standard will also apply to Scope 3 emissions. For every day a reporting entity does not comply, it could be fined up to USD100,000 (but not exceeding USD500,000 a year) until its emissions are appropriately reported. The bill, if passed and signed by the Governor, will be effective 180 days after becoming law. Of note: SB 9072 is just one of several corporate climate data reporting measures now before the New York legislature; other bills remain in various committees. The current legislative session ends on June 4.

EU Omnibus I Directive will enter into force on March 18. The European Union’s Omnibus I Directive amending the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) was published in the Official Journal of the European Union on February 26. The Omnibus I Directive will enter into force 20 days later, on March 18. As we’ve reported in past updates, the purpose of the Omnibus I Directive is to introduce targeted simplification and scope narrowing measures aimed at streamlining key reporting and compliance requirements introduced by the bloc’s Green Deal. As a reminder:

• For the CSRD, the reforms remove about 80 percent of companies from scope, applying to EU companies with more than 1,000 employees and more than EUR450 million in annual net turnover and EU parent companies of a group which, on a consolidated basis, meets those thresholds. Non-EU companies that are ultimate parent companies with more than EUR450 million in net annual turnover in the EU and which have an EU subsidiary or branch with a net annual turnover of more than EUR200 million will also be in scope.
• For the CSDDD, the scope is now limited to EU companies with more than 5,000 employees and more than EUR1.5 billion in net turnover worldwide, and EU ultimate parent undertakings of a group which, on a consolidated basis, meets the thresholds. Non-EU companies that generated more than EUR1.5 billion in net turnover in the EU and ultimate parent companies of a group which, on a consolidated basis, meets those thresholds will also be in scope.
• Member states must adopt and publish implementing laws relating to the CSRD by March 19, 2027 and must adopt and publish implementing laws relating to the CSDDD by July 26, 2028.
• Some EU member states, among them France and Italy, previously transposed the original CSRD into law, meaning that so-called Wave 1 companies that were previously in scope of CSRD but which now fall out of scope may still be required to report under member state legislation, unless those member states have chosen to exempt the companies from reporting. Once member states adopt the new thresholds for CSRD, only in-scope companies will be required to report.

ESG disclosures for the 2026 proxy season. As public companies enter the 2026 proxy season, proxy advisory firms seeking to advance environmental, social, and governance (ESG) policies through the shareholder voting process face regulatory scrutiny at both the federal and state levels. Nevertheless, many investors continue to expect ESG-related disclosures in the proxy statement regarding companies’ programs, policies, and oversight of ESG-related risks. According to research conducted by DLA Piper’s Corporate Data Analytics team, approximately 79 percent of S&P 500 companies provided ESG disclosures (excluding ESG metrics related to executive compensation plans) in their 2025 proxy statements, which represented a slight decrease from approximately 84 percent of S&P 500 companies providing such disclosures in their proxy statements in 2024. Many of the companies providing ESG disclosures in their proxy statements in 2025 (approximately 88 percent) also referenced an external ESG or sustainability report, and in approximately 24 percent of such instances, the company’s ESG disclosure comprised just a single reference to the availability of an external sustainability or ESG report. In addition, approximately 27 percent of S&P 500 companies replaced the term “ESG” with “sustainability” in their 2025 proxy statements. Find out more in our coming alert on preparing the 2026 proxy statement.

More, but modest, changes coming for EUDR. In a private meeting, the European Commission told stakeholders that it will not reopen the European Union Deforestation Regulation (EUDR) again for further simplification, the media outlet Euractiv is reporting. Rather, the Commission stated that it intends to propose modest adjustments to the EUDR’s list of covered products. The EUDR prohibits the import into the bloc of commodities such as timber, soy, beef, palm oil, rubber, cocoa, and coffee, along with their derivatives, unless their importers certify them as deforestation free. The regulation has already been extensively simplified, and its compliance deadlines have been postponed twice – currently, the compliance deadline is December 31. Last year, the Commission agreed to submit a new simplification package by the end of April 2026. According to Euractiv, this will include a delegated act amending the annex that specifies which products fall under the rules. Among the changes reportedly being considered for possible inclusion are instant coffees and soaps made with palm oil, which are not mentioned in the regulation at present. Leather products, which are currently listed, could possibly be excluded. Euractiv also reported that the EUDR benchmarking system, under which countries are classified by their deforestation risk, will not be reviewed this year, and any update would only occur once the regulation is fully in force.

UK finalizes Sustainability Reporting Standards; FCA proposes mandatory reporting. On February 26, the government of the United Kingdom (UK) released the finalized UK Sustainability Reporting Standards (UK SRS) and endorsed them for voluntary use. The UK SRS align with two key International Financial Reporting Standards, IFRS S1 and S2. IFRS S1 sets out general requirements for sustainability-related financial disclosures, while IFRS S2 focuses on disclosure of climate-related risks and opportunities. Reporting under the UK SRS will, at least initially, be voluntary, but the government also stated that it will consider in future whether to make such reporting mandatory for corporations.

Relatedly, the UK’s Financial Conduct Authority (FCA) has released a consultation paper, CP 26/5, proposing new rules that would mandate UK-listed in-scope entities to report against UK SRS S1 and S2. The exposure drafts of those standards were published in June 2025 by the UK’s Department of Business and Trade, which has not yet released final versions. The FCA’s consultation paper does not propose mandatory disclosure of Scope 3 emissions data, instead calling for businesses to provide such data on a “comply or explain” basis in annual financial reports. Overall, the rules, FCA states, aim to "drive greater consistency and comparability in disclosures" and strengthen international alignment – about 40 jurisdictions around the world have adopted or contemplating adoption of the IFRS standards. The new UK disclosure requirements would enter into force on January 1, 2027 for financial years starting on or after that date. Comments may be submitted to FCA by March 20.

Extended producer responsibility

Newly introduced state EPR bills. A growing number of US states are considering extended producer responsibility (EPR) bills. Here are the latest, all in early legislative stages:

In Georgia, the legislature is considering HB 1237, introduced on February 6, which would establish an EPR program and establish a deposit return system for beverage containers. Like many extant state EPR laws, HB 1237 includes carve-outs for smaller producers – those with less than USD2 million in global gross revenue and distributing less than one ton of covered products annually would be exempt. Only a few materials are specifically exempted from the definition of "covered material" – most notably, materials used for long-term storage of durable products and materials used to package pesticide products regulated by the Federal Insecticide, Fungicide, and Rodenticide Act. The bill also prohibits certain toxic additives in packaging, including lead, cadmium, mercury, hexavalent chromium, phthalates, and per- and polyfluoroalkyl substances (PFAS), four years after the bill takes effect.

The New Hampshire legislature considered HB 1789, which would have created a statewide EPR framework intended to reduce municipal expenses by shifting disposal costs to producers, while increasing recycling rates and incentivizing less-toxic packaging. HB 1789 focused on packaging reduction, setting annual reduction targets that increase over time: 5 percent within two years, 20 percent within five years, and 50 percent within ten years (with restrictions on meeting targets through plastic substitution). The bill also set recycling rate targets of 30 percent within five years, 50 percent within eight years, and 70 percent within 12 years. Notably, HB 1789 would have banned polyvinyl chloride (PVC), polystyrene, and polycarbonate in packaging two years after rules were adopted. Producers with less than USD1 million in gross revenue or distributing less than one ton of packaging annually would have been exempt. The measure was introduced on February 19 but was voted "Inexpedient to Legislate" by the House on the same day.

The Tennessee legislature is again considering SB 0269, the Tennessee Waste to Jobs Act, which would establish an EPR program in the state by requiring producers of goods to participate in a responsibility organization for recycling, re-use, and composting of certain packaging material. SB 0269 would exempt "de minimis producers" – those with less than USD10 million in global gross revenue or introducing less than one ton of covered material annually – from its requirements, effectively moving funding of the EPR program to large entities. Monies garnered under the program would be used to address Tennessee’s landfill shortage, improve recycling infrastructure, establish markets for recyclable materials, and fund educational efforts around recycling and circularity. Notably, certain large counties (those with populations of more than 200,000, including Montgomery, Williamson, Rutherford, Hamilton, Knox, Davidson, and Shelby counties) would be required to operate under a producer responsibility plan as a service provider, while other counties may opt in. The same bill failed to advance in the legislature last year.

Wisconsin’s legislature is considering AB 772, introduced in December and drawing on elements from several existing state EPR models. AB 772 would create a producer responsibility organization (PRO) through which the state contracts directly with a stewardship organization rather than operating alongside it. Like other state EPR proposals, it would exempt smaller producers – those with less than USD1 million in gross revenue or distributing less than one ton of packaging material annually. The bill sets ambitious recycling rate targets: 30 percent within five years, 50 percent within eight years, and 70 percent within 12 years (with provisions that reduction requirements cannot be met through plastic substitution). The bill also includes provisions addressing toxic substances in packaging, though, unlike New Hampshire's bill, it does not include an outright ban on polystyrene and PVC materials.

California SB 54 update: Public comment period closes, next steps ahead. The 15-day public comment period on the California Department of Resources Recycling and Recovery (CalRecycle) revised draft regulations for SB 54 closed on February 13 with final regulations still pending. CalRecycle had withdrawn its proposed regulations on January 9 and published new draft regulations on January 29, narrowing the definition of food and agriculture categorical exclusions and imposing a higher burden of proof for qualifying for exclusions. The Circular Action Alliance (CAA) is now working toward its June 15 program plan submission to the Producer Responsibility Advisory Board. Once submitted, the plan will be published on CAA's website with a 60-day window for public comments. CAA held a webinar on February 19 – its largest to date, with more than 2,300 registrants – providing updates on the California program, reporting timelines, and producer compliance requirements. Key takeaways included that producers should not wait to submit baseline data, that annual supply and source reduction reporting is due by May 31, and that CAA is targeting May 1 to publish draft fee rate ranges and incentive approaches.

Who will run California’s groundbreaking textile EPR program? California’s Responsible Textile Recovery Act, SB 707, will fundamentally restructure how textiles are designed, financed, and circulated in California’s market. Now CalRecycle has until March 1 to approve a single PRO that can most effectively implement the state’s EPR program. Our alert looks at the three applicants’ different approaches to textile recycling and their potential impact on business.

Oregon EPR: District court issues preliminary injunction partially halting the Plastic Pollution and Recycling Modernization Act. On February 6, the US District Court for the District of Oregon granted a preliminary injunction preventing the Oregon Department of Environmental Quality (DEQ) from enforcing Oregon’s Plastic Pollution and Recycling Modernization Act (RMA) against the National Association of Wholesaler-Distributors (NAW) and its members. The case presents constitutional questions regarding the implementation of EPR programs in Oregon and beyond. The court’s ruling provides interim relief to affected producers that are members of NAW while the case proceeds to trial, which is scheduled to begin on July 13, 2026. Notably, non-NAW members remain subject to the RMA's registration, reporting, and fee payment requirements, and DEQ retains full enforcement authority over them. CAA has confirmed that its operations continue unchanged; based on current DEQ direction and the approved RMA framework, all registration, reporting, and fee processes continue for obligated producers. CAA has also indicated that it is sending letters to non-NAW member producers reinforcing that the injunction does not alter their compliance obligations and that the RMA remains in effect. Find out more in our alert.

EPR requirements in the US and Canada – see our interactive master map. EPR legislation is expanding to numerous jurisdictions around the world. Our interactive map sets out information about the full spectrum of EPR laws across the US and Canada, including related to affected materials and compliance deadlines. Check out the map on our EPR home page.

EU’s Packaging and Packaging Waste Regulation enters into force in August. The EU’s Packaging and Packaging Waste Regulation (PPWR) enters into force on August 12. The PPWR requires all manufacturers, importers, and distributors to ensure that all packaging offered on the EU market is recyclable, designed for re-use, and contains minimum recycled content. The regulation covers packaging of any type and applies through the entire product life cycle, from production to disposal. Among its key requirements, which come into effect gradually over the coming years and tighten over time: all packaging must be designed for recycling, any plastic packaging must meet mandatory minimums for recycled plastic content, packaging must be minimized, and labels must be harmonized and must indicate the packaging’s material composition and set out waste disposal instructions. Businesses preparing for these imminent requirements are registering with the EPR schemes in every member state where they market their products.

European Commission publishes regulations supporting ESPR’s ban on destroying unsold apparel and footwear. The European Commission has published two regulations that support aspects of the Ecodesign for Sustainable Products Regulation (ESPR). The ESPR itself is framework legislation created to forward the EU’s transition to a circular, sustainable, and competitive economy by improving the durability, reparability, and recyclability of products sold within the bloc. It affects nearly all physical products, exempting only a few categories, such as human foods, animal feed, and medicinal products. The two regulations published on February 9 specifically address the destruction by businesses – whether brick and mortar or online – of unsold apparel, accessories, and footwear. The Implementing Regulation, the Commission explains, introduces a standardized format for businesses to disclose the volumes of unsold consumer goods they are discarding. This regulation applies from February 2027. The accompanying Delegated Regulation clarifies the circumstances under which destruction of unsold goods is permitted – for instance, if a garment is damaged. Both the ESPR’s ban on destruction of unsold products and the Delegated Regulation will apply to large companies starting on July 19 this year. The Implementing Regulation will apply to large companies starting in February 2027. The ESPR, the Commission states, also requires companies “across all product sectors to disclose annual information on unsold consumer products on their website, such as the number and weight of products they discard, as well as their reasons for doing so.” For large companies, that requirement is already in effect.

EPR in Egypt: Key compliance points for businesses. Egypt continues to advance its regulatory framework for sustainable waste management, including through measures imposing EPR obligations on manufacturers and importers of designated materials. One such measure is Prime Ministerial Decree No. 662/2025, issued under Section 17 of Waste Management Law No. 202/2020, which brings certain single‑use plastic bags within the scope of Egypt’s EPR regime. Our alert tells you more.

India updates solid waste management regulations. In a significant regulatory shift, India has updated its solid waste management regulations, moving key responsibilities from municipalities to large manufacturers and industrial parks. The overarching goal of the reforms is to strengthen India’s global manufacturing position by more closely aligning its domestic practices with the expectations of US and European buyers. The new rules, which will particularly affect textile factories and large production complexes, come into force on April 1. Among the changes brought by the new rules is the obligation for producers to separate waste into four streams – organic, dry, sanitary, and special treatment – which must be disposed of through authorized waste managers. The rules also impose tighter limits on landfilling. For instance, non-recyclable waste with high calorific value must be converted into refuse-derived fuel (RDF) or diverted to other energy recovery processes.

Sustainability: Regulatory

EPA rescinds greenhouse gas endangerment finding, eliminates mobile source GHG emissions standards. The US Environmental Protection Agency (EPA) has published a final rule rescinding its 2009 determination that greenhouse gas (GHG) emissions from motor vehicles and engines contribute to air pollution that endangers public health and welfare. That finding has formed the basis for EPA regulation of GHG emissions from motor vehicles and engines for nearly 15 years. The final rule also repeals all GHG emission standards for new light-, medium-, and heavy-duty motor vehicles and engines manufactured for sale in the US; and may set the stage for US Supreme Court reconsideration of its decision in Massachusetts v. EPA, which held that the federal Clean Air Act authorized EPA to regulate emissions of GHG. See our alert, and see a related development in the Litigation section.

EPA further delays compliance date for coal ash clean-up, and the 2024 MATS update is repealed. On February 10, EPA issued a final rule that postpones, by another 33 months, the compliance deadlines for monitoring and clean-up of coal ash at inactive coal ash ponds, landfills, and other fill sites at coal-fired power plants. Owners and operators of such sites now have until February 2032 to comply with clean-up requirements under the Resource Conservation and Recovery Act. The rule also postpones groundwater monitoring requirements for such sites from May 2028 to February 2031. EPA estimates that the delay will save the owners of such sites USD8.1 million to USD30 million a year. “The final rule may result in incremental health risk to children (and other populations),” the rule also states. Nationwide, the change affects 189 coal ash disposal sites at 110 coal-fired generating units, according to EPA. See the rule here.

Then, on February 20, EPA finalized its repeal of the 2024 updates to the Mercury and Air Toxics Standard (MATS). With this repeal, emissions requirements for coal- and oil-fired power plants revert to requirements first issued in 2012. The 2024 updates strengthened limits on emissions of mercury, arsenic, cadmium, chromium, lead, and nickel as well as other particulate emissions from coal-burning power plants, while requiring that they continuously monitor their emissions. EPA Administrator Lee Zeldin stated that the 2024 updates, if implemented, “would have destroyed reliable American energy,” adding that the 2012 standards provide “an ample margin of safety to protect public health.”

Coalition of State AGs warns businesses about their participation in sustainable packaging initiatives. On February 19, a coalition of ten State Attorneys General (AGs) announced they have written to nearly 80 US companies to warn them not to take part in plastics-related section 501(c)(3) and section 501(c)(6) organizations that advocate for sustainable packaging and less use of plastics. Such participation, the AGs wrote, may violate federal and state antitrust and consumer protection laws. The companies receiving the letter are all members of such organizations as the US Plastics Pact, Consumer Goods Forum, and Sustainable Packaging Coalition. The letters cite the AGs’ concerns about competition law and consumer choice, then warn the companies that their involvement in these groups may lead to “formal investigative demands, subpoenas, or other compulsory legal process(es)” arising from their participation. Signing the letter were the AGs of Florida, Georgia, Iowa, Kansas, Nebraska, North Dakota, South Dakota, Montana, Texas, and West Virginia. Florida Attorney General James Uthmeier, who is leading the effort, stated, “Multiple advocacy organizations have pressured companies into artificially changing the output and quality of their goods and services in a way that normal market forces would not otherwise bring about. These groups were warned that their activity presents serious conflicts with antitrust and consumer protection laws, and advocacy for a particular agenda is not a basis to mislead consumers.”

The states move forward. Federal actions to eliminate environmental regulation are prompting some states to ramp up their efforts to cut GHG emissions and address the climate crisis. For instance, several US state legislatures are considering bills that would create state-level superfunds to cover the cost of infrastructure resilience and adaptation projects addressing climate impacts. The newest bills under consideration are Illinois SB 2981, introduced on January 27, and Oregon SB 1541, re-introduced on February 2, each modeled on Vermont’s Climate Superfund Act. and New York’s Climate Change Superfund Act. The foundation for all these measures is the polluter-pays model enshrined in the 1980 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). As in Vermont and New York, the Illinois and Oregon climate superfunds would be financed by payments from entities seen as responsible for significant historical emissions. Should these bills become law, they could face legal challenges similar to the ongoing suits seeking to overturn the Vermont and New York acts. The legislatures of Connecticut, Maine, Rhode Island, Tennessee, and Virginia have also been considering similar bills. Late last year, the Maryland legislature overrode a gubernatorial veto of HB 0128, the Responding to Emergency Needs from Extreme Weather (RENEW) Act, which then became law on December 16, 2025.

Meanwhile, three state legislatures are considering polluter-pays bills to recover insurance costs arising from climate disasters. The bills, also based on the polluter-pays model, would seek compensation from fossil fuel companies for higher insurance costs arising from climate disasters.

• In California, SB 982, the Affordable Insurance Recovery Act, would authorize the state AG to bring civil lawsuits seeking compensation from fossil fuel companies for the surging cost of insurance premiums arising from climate-related disasters. Monies received through such litigation would be used to compensate California policyholders as well as the California FAIR Plan, the state’s insurer of last resort. SB 982 was introduced on February 4.
• In Hawaii, SB 3000, introduced on January 23, would authorize the state AG as well as the Hawaii Property Insurance Association and Hawaii Hurricane Relief Fund, or any private insurer licensed in the state, “to bring a civil cause of action against a responsible party to recover its costs and losses resulting from climate attributable harm.”
• In New York, S8585, introduced in November 2025, would allow “private insurers, the New York Property Insurance Under-writing Association (NYPIUA), and the New York State Attorney General to seek damages from fossil fuel corporations in cases of climate-related catastrophic incidents and disasters.”

All these bills are in the early stages of the legislative process. States are also taking other legislative steps to address sustainability and environmental concerns. Here are just a few examples.

• In February, the Virginia legislature passed SB347/HB711, which establishes state-level siting standards for solar projects. The legislation recommends that solar projects be built at least 150 feet away from homes and at least 50 feet from roadways and allows for "reasonable" local regulations – but prohibits local governments from entirely banning large solar projects. At this writing, Governor Abigail Spanberger has not signed the measure.
• In Colorado, legislation will be introduced in the coming weeks which, starting in 2027, would raise the state tax credit for purchasing a new electric vehicle (EV) to USD2,000 from the current USD750. Among existing programs in the state is Vehicle Exchange Colorado, which gives a point-of-sale rebate of up to USD9,000 to income-qualified residents who trade in an older, high-emitting vehicle for an EV.
• In New York, proposed legislation to criminalize conduct by corporate executives that causes widespread injury and damage was introduced to the Assembly on February 12. A10210 would create the crime of corporate catastrophe, which it defines as “widespread injury or damage by explosion, fire, flood, avalanche, collapse of building, release of poison gas, radioactive material or other harmful or destructive force or substance, or by any other means of causing potentially widespread injury or damage; establishes crimes for causing, risking, or failing to prevent a catastrophe.” Similar measures are already in place in several US states, such as Illinois, Missouri, Pennsylvania, and Utah. This legislation is in the earliest stages.
• In New Jersey, four interrelated bills addressing affordability, environmental, and energy infrastructure issues are before the legislature. They are S 679, the Climate Corporate Data Accountability Act, which would require certain companies to publicly disclose data about their annual GHG emissions; S 684, which would establish a three-year pilot program authorizing gas public utilities to build geothermal energy infrastructure; S 685, which would establish a Fleet Conversion Task Force to develop strategies for transitioning commercial motor vehicle fleets to zero-emission; and S 687, which would establish a Joint Blue Ribbon Task Force on Impacts of Climate Change on Property Insurance. The latter two measures reported out of committee to the Senate floor on February 12. The former two have been referred from the Senate Environment and Energy Committee to the Senate Budget and Appropriations Committee.
• Twenty-four state legislatures are considering bills that would remove regulatory hurdles for households to install so-called plug-and-play solar systems – convenient, small panels capable of generating enough electricity to power laptops or small refrigerators. These measures are moving ahead with considerable bipartisan support.
• New Mexico’s SB 18, the Clear Horizons Act, has failed on the Senate floor. The bill sought to codify the emissions reduction goals set out in Governor Michelle Lujan Grisham’s 2019 “Executive Order on Addressing Climate Change and Energy Waste Prevention.” Focusing on the state’s largest emitters of GHGs, SB 18 would have put in place GHG monitoring and reporting requirements, setting an ultimate goal of net-zero emissions by 2050 compared to 2005 levels, with an intermediate goal of a 45-percent reduction by 2030. State agencies would have been empowered to plan and measure progress toward those goals. Only New Mexico’s largest, stationary emitters, those producing 10,000 metric tons or more of GHG emissions a year, would have been in scope. Seven Democratic senators joined 16 Republicans to reject the measure.

European Parliament adopts binding emissions reduction target of 90 percent by 2040, postpones enforcement of ETS2. On February 10, the European Parliament overwhelmingly adopted the European Union Climate Law, making the goal of climate neutrality by 2050 a legally binding obligation for all EU member states. The Climate Law sets out a binding intermediate 2040 emissions reduction target of 90 percent over 1990 levels. It allows up to 5 percent of that target to be offset through carbon credits purchased from countries outside the bloc. It also leaves open the possibility that, under the EU’s Emissions Trading System (ETS), hard-to-abate emissions could be addressed through domestic permanent carbon removals. A European Parliament press release explains that, once the European Council has endorsed the Climate Law, the text will be published in the Official Journal of the European Union and will enter into force 20 days later.

The Climate Law also allows the EU to postpone to 2028 the enforcement of ETS2, the new, complementary cap-and-trade system that complements the ETS by addressing emissions from road transport and heating systems. Like the ETS, ETS2 sets annual caps – which shrink over time – on GHG emissions.

Meanwhile, internal talks on redesigning the ETS itself are reportedly progressing. At present, the ETS sets a cap on the number of CO₂ permits released into the market. This cap falls every year to ensure that emissions decrease over time; in 2039, the cap falls to zero. Negotiations are reportedly focusing on moving that goalpost, which would allow in-scope industries to continue emitting GHGs beyond that date and allow them additional time to decarbonize. Details about these proposed changes will likely be released in Q3 2026, to be followed by debate among governments and stakeholders.

Newly elected head of EU environment committee affirms support for Green Deal, energy independence. Pierfrancesco Maran, the newly appointed chair of the European Parliament's Committee on Environment, Public Health and Food Safety, has launched his mandate by reaffirming his support for the European Union’s Green Deal. “We must be resolute in continuing in the transition that we have embarked on. This means implementing the Green Deal while making surgical fixes where necessary,” he stated shortly after his election on February 9. Calling the Green Deal “a freedom deal,” Maran went on to assert the importance of clean transport and circularity as well as “homegrown energy” – that is, renewables like solar and wind power – to the bloc’s energy independence and economic well-being. “We must prove that our environmental goals are the engine of our prosperity, not a brake on our progress,” Maran stated.

Environmental protection regulation increases in Latin America. Environmental protection regulation, particularly in the areas of biodiversity and conservation and circularity, is increasing in many Latin American countries, with new laws taking effect or advancing in the legislative process. Some recent developments include the below.

• In Chile, the new Biodiversity and Protected Areas Service – created by Law 21,600 – began operating on February 1, assuming unified management of 22 protected areas in eight regions of the country and marking an institutional milestone in the conservation of ecosystems and biodiversity. Also, the Single-Use Plastics Law (Law No. 21,368) came fully into effect this month, prohibiting the provision of plastic utensils and packaging in food outlets, takeaways, and delivery services. The law prohibits the provision of single-use products unless they are biodegradable and certified. Its entry into force coincides with the publication of the regulation for the law’s implementation, a necessary step in its enforcement.
• In Brazil, the Senate recently approved a bill that introduces changes to environmental licensing procedures, allowing project developers to classify the level of environmental impact of their activities and assigning a greater role to local authorities in the assessment process. In addition, the federal government authorized oil exploration activities in Block 59, located in the Amazon region, a decision that has attracted public attention due to the environmental characteristics of the area.
• In Argentina, the administration of President Javier Milei is promoting a reform of the Glacier Law aimed at redefining the scope of protected glaciers and surrounding periglacial areas. The proposed changes would modify the regulatory framework applicable to economic activities in these zones, with potential implications for sectors such as mining and water resource management.
• In Peru, Law No. 32537 was enacted last year to extend the deadline for the formalization of small scale and artisanal mining activities to December. As part of this extension, the law introduces additional requirements, including a national registry of miners and mandatory geolocation of mining operations. At the same time, a new Small Scale and Artisanal Mining Law (Ley de la Pequeña Minería y de la Minería Artesanal or MAPE Law), intended to establish an updated regulatory framework for the sector, is currently under consideration.
• In Puerto Rico, the Legislative Assembly extended until December 31 the deadline for the Joint Commission to submit the final report on the Climate Change Mitigation, Adaptation and Resilience Plan, a draft of which was presented in 2024. The Assembly cited the need for further technical analysis prior to the plan’s finalization.
• As we reported in last month’s Horizon, in Mexico, the General Law on Circular Economy, unanimously approved by Congress in December 2025, has entered into force. The law establishes a comprehensive legal framework to promote resource efficiency, waste reduction, and the re-use and recycling of materials. It also creates a National Circular Economy System and formally recognizes the role of grassroots recyclers within waste management processes.

ISO issues new climate adaptation standard for governments. The International Organization for Standardization (ISO) has issued a new international standard, ISO 14092:2026 – Requirements and guidance on adaptation planning for local governments and communities. Announced on February 17, the standard offers practical guidance for governments as they plan their climate change adaptation at the local scale. Set out in a step-by-step framework, it provides structured, actionable guidance to support the full adaptation planning cycle, from understanding climate risks to implementation. ISO states that the new standard will help government entities better access adaptation finance, which “increasingly depends on clear, evidence-based planning processes supported by transparent governance.” The standard upgrades ISO/TS 14092:2020, which was a technical specification rather than a full international standard. See ISO 14092:2026 here.

Sustainability: Litigation

Rescission of Endangerment Finding: first legal challenge. Seventeen prominent environmental advocacy and scientific groups are calling on the US Court of Appeals for the District of Columbia Circuit to review the EPA’s rescission this month of the Endangerment Finding and the motor vehicle GHG emission standards under the Clean Air Act. This is the first lawsuit to be brought responding to the Trump Administration’s actions to overturn the Endangerment Finding. Among the petitioners in the matter are the American Lung Association, American Public Health Association, Center for Biological Diversity, Environmental Defense Fund, Physicians for Social Responsibility, Sierra Club, and Union of Concerned Scientists. The petition was filed on February 18. See it here.

New Jersey appellate court upholds landmark environmental justice regulations. The New Jersey Superior Court, Appellate Division has affirmed the regulations implementing S 232, the state’s landmark environmental justice law. In force since 2023, this far-reaching law requires the New Jersey Department of Environmental Protection (NJDEP) to identify the state’s “overburdened communities” and requires certain facilities located in such communities to analyze and mitigate their impacts on those communities – for instance, by providing an Environmental Justice Impact Statement with any new, renewed, or expansion permit application. Such permits will be granted only when the NJDEP determines that the facility will have no disproportionate, cumulative environmental impacts on the community. Two consolidated challenges sought to overturn NJDEP’s implementing regulations, charging that they are unconstitutionally vague, arbitrary, and capricious, and that they exceed NJDEP’s authority. In January, the court’s three-judge panel rejected each of these arguments. The panel unanimously concluded that, in issuing the implementing regulations, the agency was acting within its authority. The definitions, methodologies, and permitting framework of the implementing regulations, the panel found, are reasonable, consistent with the legislature’s intent, and entitled to substantial deference. Of note: Since the panel’s decision was unanimous, the plaintiffs would need to obtain certification from the New Jersey Supreme Court to launch an appeal. See the panel’s opinion here.

Michigan sues energy companies on antitrust grounds. A novel suit brought in late January by the state of Michigan alleges that leading fossil fuel companies have acted together for decades to suppress renewable energy technology and to stymie marketplace competition from electric vehicles. We have previously reported on the array of lawsuits being brought against energy companies which make assertions that the defendant corporations can be held liable in court for environmental damages that, the complaints assert, result from GHG emissions. The case in the US District Court for the Western District of Michigan breaks new ground in its allegations under the antitrust laws that the defendants have conspired to foreclose renewable energy from the marketplace. See Michigan’s complaint here.

US Supreme Court will hear Boulder climate litigation. The US Supreme Court has agreed to hear a suit brought under Colorado state law by the county commissioners of Boulder County and the City of Boulder charging that two energy companies “intentionally misled the public” about the environmental impact of their products. As we previously reported, in May last year the Colorado Supreme Court ruled that the case, originally filed in 2018, is not pre-empted by federal law and may proceed in state court. In August, the defendants asked the US Supreme Court to review that decision, and, in September, the federal government filed an amicus curiae brief supporting that request. The defendants argue that the claims in the case are superseded by federal environmental laws as well as the federal government’s power to conduct foreign policy. US Supreme Court review, the defendants stated in a November brief, would resolve the “clear and acknowledged conflict on the question whether federal law precludes such claims.” The Colorado plaintiffs, meanwhile, contend that the US Supreme Court does not have the power under federal law to review the Colorado Supreme Court’s ruling at this point, because the overall case has not yet been decided. In agreeing to review the case, the Justices have instructed the litigants to address that question.

Greenwashing

Australian Federal Court dismisses greenwashing case against energy provider. Australia’s Federal Court has dismissed a suit brought against energy provider Santos Ltd. by the Australasian Centre for Corporate Responsibility (ACCR). In the closely watched suit, ACCR challenged the accuracy of the company’s 2040 Net Zero Roadmap, its description of natural gas as a clean fuel, and certain statements it made in investor documents. Those statements, ACCR charged, were misleading and deceptive and thus violated Australia’s Corporations Act. The case, according to the ACCR, was the first in the world to contest the veracity of a company’s statements about its pathway to net zero. On February 17, the Federal Court dismissed the case. The court concluded that none of the “alleged positive misrepresentations” made by Santos about its present and future emissions were misleading or deceptive – for instance, its statement that it is a “clean fuels company,” the court stated, was made in the context of its long-term hydrogen production goals. The court concluded that ACCR had “failed to make out any of its claims.” Santos, one of Australia’s largest energy providers, has operations in Australia, Papua New Guinea, Timor Leste, and the US.

Florida lawsuit challenges coffee pod recyclability claims. A putative consumer class action filed on January 29 in the US District Court for the Southern District of Florida challenges Keurig Dr Pepper, Inc.’s labeling and advertisement of its K-Cup single-use beverage pods as ”recyclable,” despite the allegation that a majority of consumers cannot recycle K-Cups. The company’s definition of recyclability, the complaint states, is the foundation of a marketing strategy that named plaintiffs’ allege is counter to the “fundamental principles” outlined in the FTC’s Green Guides and taps into consumer demand for environmentally responsible products. The plaintiff seeks, among other things, a “corrective” advertising and labeling/disclosure campaign. This case, Davin v. Keurig Dr Pepper, Inc., is in early stages. Keurig Dr Pepper’s recyclability claims have faced prior legal challenges.

Shein removes net-zero claims from its German website. Fast-fashion e-commerce giant Shein will no longer prominently feature statements about its net-zero goals on its German website. The move follows a complaint brought in December 2025 by German environmental organization Deutsche Umwelthilfe (DUH) against Infinite Styles Services Co. Ltd., the operator of Shein’s web platform. DUH charged that Shein engaged in consumer deception when it claimed it would achieve net zero by 2050 without providing “concrete, transparent, or credible” evidence to support that claim. Shein’s sustainability report, DUH noted, disclosed that the company’s total emissions in 2024 rose 23 percent. This month, Shein agreed to remove the unsubstantiated claims about its net-zero goals from its German site. As we reported last year, in August 2025 the Autorità Garante della Concorrenza e del Mercato, Italy’s competition and market regulator, imposed a fine of EUR1 million (USD1.16 million) on Infinite Styles Services over environmental claims on Shein's platforms.

Canada: Alberta’s amendments to its Securities Act may shield issuers from certain environmental claims. Bill 12, the Financial Statutes Amendment Act, revises Alberta’s Securities Act to provide the Lieutenant Governor in Council with the authority to issue regulations that may shield Alberta issuers from claims arising from their climate-related disclosures. The addition of this regulation-making authority to the Securities Act is reportedly a provincial-level response to 2024 amendments to the federal Competition Act which focus on greenwashing, creating reverse-onus requirements that require businesses to substantiate their environmental claims. The Alberta amendment responds to this by allowing the provincial government “to make regulations respecting circumstances in which a company will not be liable, or defences it may have, in any action or proceeding concerning the information it has disclosed in good faith under securities legislation, including climate-related information.” The Alberta Securities Commission stated that Bill 12 confers on it “the ability to extend the existing safe harbour regime for statutory civil liability under the Securities Act for issuers to include climate-related disclosure.” Neither the Securities Commission nor the government has indicated when draft regulations will be provided or when any consultation will take place. Bill 12 received Royal Assent on December 12, 2025. The provincial Act does not alter the federal Competition Act and does not shield issuers from environmental claims made pursuant to it.

Supply chain integrity and human rights

Illinois introduces bills setting out deforestation-free procurement requirements. Illinois has introduced companion bills in both the Senate and House that would create the Deforestation-Free Illinois Law by adding Article 54 to the Illinois Procurement Code. The Senate version, SB 2157, introduced by Senator Rachel Ventura, would prohibit the state and state agencies, effective January 1, 2028, from allowing contractors to purchase tropical hardwood or tropical hardwood products for use in completing state contracts. Limited exceptions are provided for Indigenous community harvesting and federal grant compliance. Additionally, the legislation would establish a phased-in certification requirement for forest-risk commodities, such as beef, cocoa, and coffee, under which contractors must certify that products furnished to the state were not extracted from, grown, derived, harvested, reared, or produced on land where deforestation or primary forest and old-growth forest degradation occurred. Large contractors with annual revenues of USD100 million or more would be required to adopt and publish forest policies that include procedures for identifying and mitigating deforestation risks and ensuring compliance with human rights standards, including the principle of Free, Prior, and Informed Consent of Indigenous peoples. The Department of Central Management Services would be required to adopt implementing rules by July 1, and a stakeholder advisory group comprising industry representatives, civil society experts, and Indigenous community members would advise on rulemaking and implementation. Violations may result in contract voiding and penalties of the greater of USD1,000 or 20 percent of the value of non-compliant products, and the legislation includes preferences for small, medium-sized, minority-owned, and women-owned businesses offering compliant Illinois state products.

California bill would enhance Transparency in Supply Chains Act. California SB 657, the California Transparency in Supply Chains Act of 2010, requires large retailers and manufacturers doing business in California that have more than $100 million in annual worldwide gross receipts to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. On February 20, Assembly Member Isaac G. Bryan introduced AB 2599, a measure that would expand the act’s reporting requirements by requiring certain in-scope businesses to complete an affidavit verifying that they have searched all their records for “records that the in-state entity or its related entities bought or sold persons subjected to slavery, used persons subjected to slavery as collateral, provided loans to purchase persons subjected to slavery, insured such transactions or the persons subjected to slavery, or provided related or other services to aid or otherwise facilitate those transactions.” The bill applies to large companies offering financial, insurance, railroad, rice, shipping, sugar, textile, and tobacco products. These companies would also be required to create a digital platform by January 3, 2028, to provide public access to affidavits and reports issued pursuant to the bill. The current text of the bill states, “By requiring an affidavit, and thus expanding the crime of perjury, the bill would impose a state-mandated local program.” At this writing, the bill is pending referral to a committee for review.

IRS Notice 2026-15 provides guidance on credit eligibility for certain cross-border supply chains in the clean energy industry. The Internal Revenue Service has released Notice 2026-15, which provides guidance on the Material Assistance Cost Ratio (MACR) rules enacted under the One Big Beautiful Bill Act. The Notice, published on February 12, establishes the interim framework for maintaining credit eligibility for clean energy industry participants with cross-border supply chains. Clean energy developers, manufacturers, and investors are encouraged to carefully review their supply chains and existing arrangements, particularly with respect to MACR calculations. See our alert to learn more.

UK: CMA issues new guidance for businesses making environmental claims. Building on the UK’s existing Green Claims Code, the Competition and Markets Authority (CMA) has issued new guidance which, CMA states, “provides additional clarity to businesses about where responsibility for making environmental claims lies for different businesses across the supply chain.” The guidance, released on January 22, emphasizes that businesses should already be taking proactive steps to understand their consumer law obligations around environmental claims. It goes on to warn that “not having, or not following, internal systems in place for verifying and for making environmental claims increases the likelihood of misleading claims being made.” The guidance includes five fictional examples of scenarios involving unfair commercial practices – for instance, a retailer making false claims about the recyclability of its own branded products and a supplier providing inaccurately labeled furniture to a number of retailers – to show what information a business should consider when presenting information to consumers and how CMA may determine where the responsibility for misleading claims may lie. The document also includes a practical checklist for businesses, emphasizing that businesses throughout the supply “should be able to back up their claims with robust, credible, relevant and up-to-date evidence.” Finally, CMA notes, the guidance “is limited to the CMA’s use of its consumer powers in relation to environmental claims. It does not bind or constrain other consumer protection enforcers.” See “Making green claims: Getting it right, across the supply chain” here.

European Commission considers “Made in Europe” requirements for strategic manufacturing. The European Commission is reportedly planning to propose the Industrial Accelerator Act, a regulation that would introduce “Made in Europe” requirements for manufacturers across a broad swath of strategic industries, among them renewable energy and alternative fuel vehicles. The goal of the legislation is to support the EU’s goals around decarbonization and the electrification of energy-intensive industries while stimulating European manufacturing. The proposed regulation reportedly contains a requirement – which is currently being described as provisional – for alternative fuel vehicles that receive public funding to source at least 70 percent of their components, excluding batteries, from the EU, or else must be fully assembled inside the bloc. Certain battery components, furthermore, must originate in the EU. For the construction sector, a minimum of 30 percent of the plastics used to manufacture windows and 25 percent of aluminum products must be made in the EU if those products are to qualify for public procurement contracts or subsidies. On February 23, the Commission announced that it is pushing the release of the proposed regulation to March 4.

New Zealand Parliament again considers a modern slavery reporting bill. A bill that would bring modern slavery reporting requirements to New Zealand was introduced this month in Parliament. The measure, Bill 242-1, would require in-scope entities to produce an annual modern slavery statement setting out the ways they identify, mitigate, and remediate incidents of modern slavery in their supply chains and their operations. Among other requirements, the statement would need to be published on the reporting entity’s public-facing website, where it would remain until superseded by the next year’s statement. In scope are all companies doing business in New Zealand with annual consolidated revenue during the reporting period of NZD100 million – including any entity that controls an entity meeting those benchmarks. Unlike some other countries’ modern slavery laws, this bill contains clear enforcement mechanisms, such as fines of up to NZD200,000 for entities that breach their reporting obligations and for individuals who knowingly provide false or misleading information in a modern slavery statement. Unlike earlier legislative efforts, under this version entities convicted of modern slavery reporting offenses would be excluded from government procurement. This bill is in the early stages of the legislative process, and its bipartisan sponsors state that their goal is to secure its passage before the next general election in New Zealand, slated for November 7.

Report: Climate risks could slash the fashion industry’s bottom line. A new report from the Apparel Impact Institute (AII) concludes that, if the fashion sector fails to prioritize climate action in the near term, it could see its profits decline, quickly and drastically. The Cost of Inaction – The Financial Risks of Delaying Decarbonization in the Apparel Industry draws on data from ten major apparel brands to show how climate risks are increasing costs for companies in the fashion industry. Rising expenses in three areas – carbon pricing, energy, and raw materials – would particularly impact the sector’s bottom line, with the potential to affect profits by up to 24 percent by 2030 and 67 percent by 2040. “If this trend continues, up to 70% of the value of a $1.8 trillion industry could disappear by 2040,” the AII report warns. The encouraging news, according to the report, is that the actions that reduce exposure, like electrification, renewable energy procurement, and supplier support, “are practical and investable.” Finally, the report states, “climate exposure may begin in the supply chain, but it fully arrives on the balance sheet.” Read the report here.

Energy and natural resources

New EO directs Pentagon to buy coal-fired electricity. On February 11, President Donald Trump issued “Strengthening United States National Defense with America’s Beautiful Clean Coal Power Generation Fleet,” an Executive Order (EO) requiring the Secretary of War to “procure power from the United States coal generation fleet by approving long-term Power Purchase Agreements” with coal-fired energy production facilities to serve US military installations. During a White House event the same day, the President also announced that the US Department of Energy would invest USD175 million on upgrades for coal plants in Kentucky, North Carolina, Ohio, Virginia, and West Virginia and that he intends to continue approving permits for new coal mines.

California and UK ink clean energy MOU. On February 16, California Governor Gavin Newsom and Edward Miliband, Secretary of State for Energy Security and Net Zero of the United Kingdom, signed a memorandum of understanding (MOU) pledging the collaboration of their governments on clean energy technologies. The MOU, the UK government stated, would “boost transatlantic investment, supporting jobs and industry, and strengthening relationships between research institutions in the UK and California.” At present, California generates nearly two-thirds of its power from renewables, primarily solar, and the state hopes to expand its offshore wind capacity to generate another 25 gigawatts of energy to attain its target of 100-percent clean energy generation by 2045. The UK, meanwhile, is continually increasing its reliance on renewable energy, which in 2025 provided about 45 percent of its total electricity generation. The MOU supports collaborations between the two governments on clean energy technologies, including offshore wind and low-carbon hydrogen, and aims to provide greater access to the California market for UK energy suppliers. It further aims to forward cooperation between research institutions in California and the UK that support governmental efforts, shaped by the United Nations Framework Convention on Climate Change (UNFCCC) treaty, to address and mitigate climate change. Shortly after the MOU was signed, Octopus Energy, the largest energy supplier in the UK, pledged to invest USD1 billion in renewables projects in California.

Virginia aims to re-join multi-state carbon trading program. Virginia’s State AG, Jay Jones, has filed a joint motion that would pause the state’s appeal of a 2024 ruling that found the previous gubernatorial administration lacked the authority to withdraw the state from the Regional Greenhouse Gas Initiative (RGGI). The motion could help to clear the way for Virginia to rejoin the RGGI, a multi-state carbon trading program that requires electricity producers in participating states to purchase allowances for the emissions they produce above RGGI-established limits. Former Governor of Virginia Glenn Youngkin withdrew the state from the RGGI in 2020, despite a state law, the Clean Energy and Community Flood Preparedness Act, that requires Virginia to participate. In November 2024, the Floyd County Circuit Court ruled that the state’s withdrawal from RGGI was illegal and that Virginia must re-join. This month, Virginia lawmakers are reportedly exploring a number of legislative pathways that would create a pathway for the state to re-join the program. Funds obtained through the RGGI are returned to the participating states. Virginia, for instance, received about USD830 million for energy efficiency and flood preparedness programs.

Quebec’s Bill 17 would regulate CO₂ sequestration. Quebec’s legislature is considering Bill 17, which would put in place a legislative framework for regulating carbon capture and sequestration (CCS) projects – that is, the geological storage of CO₂ – in the province. The purpose of the bill is reportedly to support permanent removal of atmospheric carbon, unlock major investments, and achieve the province's target of net-zero emissions by 2050. A license would be needed to search for underground reservoirs or natural fluids, use a reservoir, store a fluid, or extract certain natural fluids found underground. The bill would set out the rules for site approvals, conditions of operations, and environmental and site restoration standards. Samuel Poulin, Quebec’s Minister Delegate for the Economy and Small and Medium Enterprises, stated that the bill would also help the several CCS projects that are already under development in Quebec but that, absent a permitting framework, have been unable to proceed. To support the province’s long-term energy goals, Bill 17 would also apply to compressed air storage, geothermal energy, and geological hydrogen projects. See Bill 17, An Act mainly to amend the Act respecting natural gas storage and natural gas and oil pipelines in order to provide a framework for underground reservoirs and certain pipelines, here.

Sustainability in financial services

While SEC proposes repealing Names Rule, compliance dates are postponed. On February 18, the Securities and Exchange Commission (SEC) announced it is proposing to repeal the 2023 amendments to the Names Rule which require investment funds with names suggesting a specific type of investment (such as sustainability) to invest at least 80 percent of assets in those areas in order to align fund names with investor expectations. Disclosures pursuant to the Names Rule are made using Form N-PORT, and the proposed repeal would also update that form. Last week, SEC Chair Paul S. Atkins stated at a hearing of the House Financial Services Committee that the agency is considering whether to eliminate the rule entirely. For now, the compliance date for the 2023 amendments to Form N-PORT is extended to November 17, 2027 for fund groups with net assets of USD10 billion or more as of the end of their most recent fiscal year, and to May 18, 2028 for fund groups with less than USD10 billion in net assets as of the end of their most recent fiscal year.

Sustainability in the marketplace

Energy Star program continues. President Trump signed bipartisan budget legislation in January that strengthened the Energy Star program, a public-private partnership that certifies energy-efficient home appliances. Last year’s federal budget sought to entirely defund Energy Star. However, starting in April 2025, a broad array of stakeholders – among them home builders, manufacturers, local governments, and business groups such as the US Green Building Council – began urging the Trump Administration to maintain the program. The new budget appropriates more than USD33 million for Energy Star, raising the program’s funding above 2024 levels. Congress also stipulated in the budget bill that monies be spent to keep the program within the government, rather than privatizing it. However, a spokesperson for the US Green Building Council told NPR that getting new products certified as Energy Star has been slowed by EPA’s loss of staff capacity, and the effects of those staff cuts are only beginning to be felt in the marketplace because previously approved products are still available in stores.

Calendar

Key global reporting deadlines

^{This calendar highlights coming reporting deadlines in key jurisdictions and is not a comprehensive summary of global sustainability regulations. Our Sustainability team’s interactive Global Sustainability Regulatory Dashboard provides our clients with an in-depth, comprehensive analysis of global sustainability regulations pertinent to their business. For more information about the Global Sustainability Regulatory Dashboard, please contact us via DLAPiperCorporateDataAnalytics@us.dlapiper.com.}

Coming events

• SF Climate Week takes place from April 18 to 26, 2026 in San Francisco.
• DC Climate Week takes place from April 20-26, 2026 in Washington, DC.
• London Climate Action Week takes place June 20 to 28, 2026 in London.
• Climate Week NYC takes place September 20 to 27, 2026 in New York City.
• The 2026 United Nations Climate Change Conference (COP31) will be held in November 2026 in Antalya, hosted by Turkey, with Australia serving as President of Negotiations.
• The 2026 United Nations Water Conference will take place December 2 to 4, 2026 in the United Arab Emirates.

For professional responsibility reasons, these summaries may not include discussions of developments relating to certain matters.