Sustainability

The European Commission has published a detailed Q&A guidance document (the “Guidance”) on the interpretation and application of the Greenwashing Directive’s environmental claims and circular economy rules, which EU Member States will have to enforce from September 27, 2026. 

The Greenwashing Directive updates the EU’s consumer protection rules to tackle greenwashing

Continue Reading The European Commission’s New Green Claims Guidance:  What Businesses Need to Know

After months of uncertainty, the outlook for key EU sustainability laws is far clearer.

On November 13, 2025, the European Parliament adopted its negotiating position on the Corporate Sustainability Reporting Directive (“CSRD”) and the Corporate Sustainability Due Diligence Directive (“CSDDD”) Omnibus simplification. This follows the European Commission’s Omnibus proposal in

Continue Reading The CSRD/CSDDD Omnibus Endgame: Key Points for Companies

On June 23, 2025 the Council of the EU, which represents the 27 EU Member States, agreed on its negotiating mandate for the Corporate Sustainability Reporting Directive (“CSRD”) and Corporate Sustainability Due Diligence Directive (“CSDDD”) omnibus simplification.

This follows the European Commission’s omnibus proposal from February and is the next

Continue Reading EU Member States Agree on CSRD/CSDDD Omnibus Negotiating Mandate

After its 12-month deferral, the EU’s Deforestation Regulation (“EUDR”) is set to apply from December 30, 2025.  Many companies are therefore refocusing EUDR compliance efforts. This blog provides an update on the rules and guidance and key, practical takeaways for companies.

The European Commission (“Commission”) recently provided new and updated

Continue Reading EUDR Back on the Horizon: Preparing for December 2025 Compliance

On Monday, December 16, the California Air Resources Board (CARB) issued an information solicitation inviting feedback on the implementation of SB 253 and SB 261. Comments are due by February 14, 2025. This information request arrives on the heels of a new CARB enforcement advisory focused on SB 253. Continue Reading California Air Resources Board Solicits Stakeholder Feedback on Implementation of Climate Disclosure Laws on the Heels of New Enforcement Advisory  

On April 9, the Board of Trustees of the Science Based Targets initiative (SBTi), a climate action organization that has validated corporate decarbonization targets for more than 4,200 companies to-date, issued a statement announcing that environmental attribute certificates (EACs), including carbon credits generated by voluntary carbon projects, may be used to abate Scope 3 greenhouse gas (GHG) emissions. It is possible to view the Board’s statement, unprecedented for SBTi, as recognition of the practical challenges associated with achieving Scope 3 emissions abatement without utilizing EACs. Yet, the statement also drew swift criticism from some stakeholders and observers, who argue that it represents a departure from SBTi’s science-based approach to corporate climate action. 

Following the criticism, on April 11, “the overwhelming majority” of SBTi’s staff, which felt “compelled to issue multiple clarifications” of the Board’s statement, published a remarkable public response.  Thereafter, on April 12, the Board supplemented its April 9 statement to clarify that no changes to the SBTi standards had been finalized. However, the Board’s statement and staff’s response show that interested stakeholders will have opportunities to provide SBTi with critical input regarding the use of EACs in Scope 3 emissions abatement that could have a material effect on any related revisions to the SBTi standards.  Continue Reading SBTi Board Announces Role for Carbon Credits in Scope 3 Emissions Abatement; Staff Clarifies Review Remains On-going

Yesterday, the European Parliament approved a new (recast) Urban Wastewater Treatment Directive (“UWWTD”) that will impose new additional costs on producers marketing pharmaceutical and cosmetic products in the European Economic Area by the end of 2027.  Some studies suggest that the costs that producers would have to collectively pay could be around €1 billion per Member State.  This is well above the figures published in the Commission’s impact assessment, which estimated the annual cost of implementing the various requirements of the UWWTD in all Member States at €3.8 billion, including €1.2 billion for micro-pollutants treatment.

The upcoming UWWTD lays down rules on the collection, treatment, and discharge of urban wastewater, and puts particular emphasis on the implementation of the polluter pays principle.  The Directive aims to address the environmental and health concerns resulting from the presence of micro-pollutants, other pollutants (e.g., heavy metals, PFAS), microplastics and antimicrobial resistant (“AMR”) bacteria in European waters.  It introduces new measures for the treatment of wastewater, including quaternary treatment for micro-pollutants, and makes producers of pharmaceutical and cosmetic producers pay for such treatment.Continue Reading New EU Wastewater Treatment Fees on Producers of Pharmaceutical and Cosmetic Products

California’s Department of Resources Recycling and Recovery (CalRecycle) recently released a preliminary report analyzing data related to the recyclability of certain materials in California.  The report, issued in accordance with CalRecycle’s obligations under California Senate Bill 343 (SB 343), is intended to help the public determine whether businesses may legally

Continue Reading California Publishes Preliminary Report on Recyclability of Materials Under SB 343

The European Commission is currently holding a public consultation on a Draft Delegated Act (“DDA”) on a common rating scheme on the energy performance of data centers in the European Union and European Economic Area (“EU/EEA”).  The DDA will lay out the energy key performance indicators that operators and owners of data centers must report, the sustainability indicators that will be calculated per data center, and the aggregated data that will be made publicly available, in accordance with the new EU Energy Efficiency Directive (“EED”). 

The adoption of the DDA will introduce specific mandatory environmental and energy performance reporting requirements for data centers for the first time in the EU/EEA, and probably in the world.  These reporting requirements may be the first step for the EU to adopt mandatory environmental performance targets for data centers within the next decade.Continue Reading Upcoming Sustainability Reporting Requirements for Data Centers in the EU