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Key Environmental Law and Policy Issues to Watch in President Trump’s Second Administration

On November 5, President Donald Trump was elected President-elect for a second time. We anticipate that President Trump’s upcoming term will usher significant shifts in U.S. environmental and natural resource law and policy,...more

EPA Finalizes HFC Emissions Reduction and Reclamation Program

Key Takeaways - What Happened? On October 11, 2024, the U.S. Environmental Protection Agency (EPA) published a final rule establishing the Emissions Reduction and Reclamation (ER&R) Program to manage certain...more

Extended Producer Responsibility Comes to California Apparel and Textile Producers

What Happened: On September 28, the Responsible Textiles Recovery Act of 2024 was signed into law which is designed to increase responsibilities of apparel and textile article producers regarding the reuse, repair, and...more

Minnesota Becomes Fifth State to Enact EPR Law for Packaging and Paper; First to Enact EPR Law for Boat Wrap

Key Takeaways - What Happened? On May 21, 2024, Minnesota Governor Tim Walz signed the Packaging Waste and Cost Reduction Act (the Act). Minnesota is the fifth state to enact laws implementing packaging EPR rules,...more

Canada Amends the Competition Act to Target Greenwashing

Canada is increasing accountability for environmental claims by explicitly requiring companies to substantiate claims promoting the environmental benefits of their products and business activities. Bill C-59 (which received...more

Ecology Proposes Significant—And Legally Vulnerable—Changes to Washington’s Industrial Stormwater General Permit

Key Takeaways - What is Happening? The Washington State Department of Ecology (Ecology) published for public comment its proposed 2025 Industrial Stormwater General Permit (ISGP), which authorizes the discharge of...more

EPA Issues New Policy Calling for Closer Coordination Between Civil and Criminal Enforcement

The U.S. Environmental Protection Agency’s (EPA) new Strategic Civil-Criminal Enforcement Policy, announced last week by David Uhlmann, Assistant Administrator for the Office of Enforcement and Compliance Assurance (OECA),...more

Mitigating “Greenwashing” Litigation Risk in the U.S. and Beyond

Companies should take note – there is increased global scrutiny around environmental or green marketing, or so-called “greenwashing,” claims. These claims stem from alleged wrongdoing in companies’ marketing representations...more

EPA Issues Final Rulemaking on Clean Water Act Hazardous Substance Facility Response Plans

Key Takeaways - • What Is Happening? On March 14, 2024, The U.S. Environmental Protection Agency (EPA) signed a final rule requiring certain facilities to develop Facility Response Plans (FRPs) for a potential worst-case...more

Oil Pollution Act: Tips for Spill Response, Compliance, and Enforcement

Oil spills commonly occur when least expected and, even in smaller quantities can significantly disrupt business operations and create risks for enforcement and/or litigation. It’s important that companies are prepared and...more

EPA Proposes Cleanup Authority Expansion Under RCRA for PFAS and Other Emerging Contaminants

On February 8, 2024, the U.S. Environmental Protection Agency (EPA) proposed two rules to expand the Agency’s authority to address releases of per- and polyfluoroalkyl substances (PFAS) and other emerging contaminants at...more

CalRecycle Seeks Stakeholder Feedback on Single-Use Packaging EPR Program

Tomorrow, February 1, the California Department of Resources Recycling and Recovery (CalRecycle) will host a hybrid question and answer session to discuss the draft rulemaking on their extended producer responsibility (EPR)...more

California’s Transformational Single-Use Packaging EPR Law Moves Toward Implementation

Governor Gavin Newsom signed SB 54 on June 30, 2022, creating an extended producer responsibility (EPR) program and imposing some related prohibitions for certain single-use packaging and plastic single-use food service ware...more

EPA Ramps Up Climate Enforcement

Facilities operating across the country need to be prepared for increased climate-driven enforcement at all levels of federal government—especially at the U.S. Environmental Protection Agency (EPA). With EPA’s Climate...more

The Biden Boomerang Effect Reaches Clean Water Act Section 401: EPA Reverses Trump-Era Rules that Reduced State Certification...

On September 15, 2023, the U.S. Environmental Protection Agency (EPA) issued its final rule governing water quality certifications under Section 401 of the Clean Water Act (CWA). Section 401 requires the applicant for a...more

Washington State Proposes Sweeping Changes to Key Greenhouse Gas Regulation: Ecology’s Proposed Rule Targets Hydrofluorocarbons...

On July 13, 2023, the Washington State Department of Ecology (Ecology) published proposed amendments to Chapter 173-443 WAC, Hydrofluorocarbons (HFCs). Key provisions of the Proposed Rule include...more

Washington State Proposes Sweeping Changes to Key Greenhouse Gas Regulation

On July 13, 2023, the Washington State Department of Ecology (Ecology) published proposed amendments to Chapter 173-443 WAC, Hydrofluorocarbons (HFCs). Key provisions of the Proposed Rule include...more

D.C. Circuit Vacates Key Element in HFC Rules under AIM Act

A new D.C. Circuit opinion addressed the limits of non-delegation doctrine, upheld the U.S. Environmental Protection Agency’s (EPA) authority to regulate HFC/HFO blends, and struck down the agency’s authority to enact...more

Supreme Court Narrows CWA Jurisdiction Over Waters of the U.S.

On May 25, the U.S. Supreme Court issued its long-awaited decision in Sackett v. EPA, No. 21-454, holding that Clean Water Act (CWA) jurisdiction extends to wetlands only if they have a continuous surface connection to...more

Fishers' Livelihood Concerns Could Bring SCOTUS Sea Change for Environmental Law

The Supreme Court has agreed to hear a group of New Jersey herring fishers’ challenge to a long-standing key administrative law doctrine—the “Chevron doctrine.” It could be the next term’s most consequential case. The Chevron...more

EPA Finalizes SNAP Rule 25 and Lists New HFC Alternatives

On April 19, 2023, EPA finalized Rule 25 – Protection of Stratospheric Ozone: Listing of Substitutes under the Significant New Alternatives Policy Program in the Refrigeration & Air Conditioning and Fire Suppression Sectors....more

Six Tips for Companies Making “Climate-Smart Agriculture” Claims

Agriculture is on the very frontlines of our changing climate. Climate change directly affects many of the most fundamental aspects of agricultural production: the length of crop growing seasons; the ranges of insects, weeds,...more

Green Marketing Claims To Receive Increased Scrutiny

Green Marketing Updates in the European Union (EU) - Background - On March 22, 2023, the European Commission (Commission) published a Proposal for a Directive on Green Claims (Proposal). The Proposal is part of the EU's...more

DOJ Implements Nationwide “Voluntary Self-Disclosure” Program: All U.S. Attorneys’ Offices Instructed to Follow Updated Corporate...

The U.S. Department of Justice (DOJ) formally implemented a nationwide Voluntary Self-Disclosure policy (VSD policy) on February 22, 2023—effective immediately—that has been in the works for several years. The VSD policy...more

Ninth Circuit Causes a Ripple

On February 21, 2023, the U.S. Court of Appeals for the Ninth Circuit (Ninth Circuit) issued the latest in a series of opinions involving the Trump Administration’s rule interpreting Section 401 of the Clean Water Act (CWA)....more

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