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Tensions Rise Between EU and U.S. Law

As currently drafted, the PROTECT USA Act, introduced on March 12, 2025, may have the unintended impact of creating a significant tension between compliance with U.S. and EU laws by U.S. and non-U.S. companies....more

EU Omnibus Package Published: CSRD and CS3D to Be Delayed and Scaled Back

The European Union published its long-awaited "Omnibus" package, proposing to delay key European ESG rules, while simultaneously reducing the applicability and burden of corporate sustainability reporting and due diligence...more

SEC Signals It Will Abandon Defense of Climate Disclosure Rule

Acting Securities and Exchange Commission ("SEC" or the "Commission") Chairman Mark Uyeda directed SEC staff to request that the Eighth Circuit Court of Appeals not schedule an oral argument in the pending litigation...more

New York Enacts Climate Change Law That Fines Companies for Historical Emissions

On December 26, 2024, New York enacted a law requiring certain energy companies to contribute cumulatively $75 billion to a climate "superfund" over the next 25 years....more

EPA Releases National Strategy to Prevent Plastic Pollution

In November 2024, the U.S. Environmental Protection Agency ("EPA") released its National Strategy to Prevent Plastic Pollution, a comprehensive plan with the goal of eliminating the release of plastic waste into the...more

The CFTC Finalizes Guidance on Voluntary Carbon Credit Contracts for Derivatives Markets

The Commodity Futures Trading Commission (“CFTC” or “Commission”) has inserted itself in recent years into efforts to scale the cash market for “high integrity” voluntary carbon credits. On September 20, 2024, the Commission...more

Landmark Climate Change Case Overturned: The Hague Court of Appeals Overturns Ruling Ordering Shell to Reduce CO2 Emissions

On November 12, 2024, The Hague Court of Appeals overturned the landmark climate change litigation case that imposed a 45% CO2 reduction obligation on Shell....more

California Imposes Mandatory Disclosure Law for Voluntary Child Labor Audits

California recently imposed new mandatory disclosure requirements related to social compliance audits....more

California Enacts First-of-its-Kind Clothing Recycling Law

The Law: California enacted the Responsible Textile Recovery Act of 2024, the first extended producer responsibility law for clothing producers in the United States....more

Mandatory Climate Disclosure Laws to Take Effect in Australia

Australia has now officially passed laws that will introduce a mandatory climate-related financial disclosure regime from 1 January 2025. This is one of the most significant reforms to corporate financial reporting in...more

The Climate Report | Third Quarter 2024

REGULATORY ISSUES & UPDATES - Update on Australia's New Climate-Related Financial Disclosure Regime - Australia's mandatory climate-related financial disclosure regime is inching closer to implementation after the proposed...more

Australia Publishes Draft Antitrust Guidance on Sustainability Collaborations

The Development: Recently, the Australian Competition and Consumer Commission ("ACCC") published draft guidelines designed to assist businesses to understand how they can collaborate on sustainability initiatives without...more

California's Climate Disclosure Laws Move Forward After Governor Newsom's Proposal to Delay Implementation Fails

The California legislature continues to press forward with the implementation of two of the state's sweeping climate disclosure laws after a proposal to delay the implementation dates by the governor failed to be considered...more

U.S. SEC Climate Disclosure Rules Spark Flurry of Litigation (UPDATE)

Following the U.S. Securities and Exchange Commission ("SEC")'s adoption of the climate-related disclosure rules on March 6, 2024, dozens of parties filed petitions for review across different appellate courts. The Judicial...more

SEC Settles Charges with Keurig Over ESG Disclosures

On September 10, 2024, the SEC settled charges against Keurig for "incomplete and inaccurate" ESG disclosures about the recyclability of Keurig's K-Cup pods, signaling a continued focus on environmental-related disclosures...more

D.C. Appellate Court Revives Case Against Coca-Cola, Placing "Sustainability" Claims Under Scrutiny

In reversing a lower court ruling, the D.C. Court of Appeals makes actionable vague, aspirational statements of sustainability as deceptive and misleading representations under the D.C. Consumer Protection Procedures Act...more

Coming Soon: Mandatory Climate Disclosure Laws in Australia

The Development: On August 22, 2024, the Australian Senate passed the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024 ("Bill")....more

APAC ESG Update | Spring Quarter 2024

This White Paper focuses on ESG developments through the Asia-Pacific (“APAC”) region since the start of 2024. For businesses present in the APAC region, as well as doing business there, it is imperative to be vigilant of...more

IRS Issues Final Prevailing Wage and Apprenticeship Regulations for Clean Energy Tax Credits

The Background: The Inflation Reduction Act ("IRA") created or enhanced various tax credits for qualifying renewable energy projects. However, a taxpayer loses 80% of otherwise-available IRA credits unless prevailing wage...more

U.S. Corporation Found Liable for Complicity in Human Rights Violations in Colombia

A recent jury verdict finding Chiquita Brands International ("Chiquita") responsible for deaths by a Colombia paramilitary group marked the first "bellwether trial" in a massive multidistrict litigation and is reported to be...more

U.S. SEC Climate Disclosure Rules Spark Flurry of Litigation

On March 6, 2024, the United States Securities and Exchange Commission ("SEC") adopted the much anticipated climate-related disclosure rules, two years after publishing the proposed rules. Immediately following the adoption...more

Vermont Law Requires Energy Companies to Pay for Climate Change Damage

Vermont passed a first-of-its-kind law requiring energy companies to pay for part of the damages from extreme weather events, but the law likely will face legal challenges....more

Mandatory Disclosure on "Forever Chemicals," PFAS, in One State Propagates Consumer Class Action in Another

In what appears to be a new pathway for PFAS litigation, California plaintiffs recently filed a lawsuit against the manufacturer of BIC razors stemming from disclosures the company made under Maine's PFAS law, which were...more

European Court's Landmark Ruling Deems Climate Inaction Amounts to Violation of Human Rights

The Context: Litigation over State obligations to mitigate climate change intensifies globally, with NGOs and individuals pressuring corporations to cut emissions. The European Court of Human Rights ("ECtHR") issued three...more

Enhanced Sustainability Requirements for Federal Contractors

On April 22, 2024, the U.S. government issued a final rule ("Rule") to restructure and update the Federal Acquisition Regulation ("FAR") to implement a requirement for agencies to procure sustainable products and services to...more

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