Horizon – News and Trends in Sustainability Law

Deadline alert

US: California. Producers in scope of SB 707, the Responsible Textile Recovery Act of 2024, have until July 1 to register with Landbell USA, the producer responsibility organization (PRO) managing the act’s extended producer responsibility (EPR) program.

US: California. California Air Resources Board (CARB) has postponed the deadline for reporting Scope 1 and Scope 2 disclosures under SB 253 from August 10 to November 10.

European Union. The EU Packaging and Packaging Waste Regulation enters into force on August 12. Key compliance milestones and targets will phase in through 2040.

Disclosures and voluntary reporting

CARB proposes postponed GHG reporting deadline amid ongoing rule revisions. On June 24, CARB announced it is updating its proposed regulations under SB 253 to defer the initial Scope 1 and Scope 2 greenhouse gas (GHG) reporting deadline from August 10 to November 10 – a three-month delay tied to CARB’s ongoing rulemaking revisions. The agency has withdrawn its previously submitted Initial Regulation from final review to allow for targeted clarifications, which will be released for a forthcoming 15-day public comment period before resubmission. CARB indicated that the deferral is intended to provide reporting entities – companies doing business in California with more than USD1 billion in annual revenue – additional time and regulatory certainty following final approval of the regulations. The underlying program remains unchanged in scope, with first-year reporting limited to Scope 1 and Scope 2 emissions, assurance requirements suspended for the initial reporting cycle, and reporting expected to expand to Scope 3 beginning in 2027. The public comment period will commence once CARB issues the text of the revised rules, but that date remains to be announced.

EU publishes draft sustainability reporting standards for non-EU companies. The European Financial Reporting Advisory Group (EFRAG) has released draft sustainability reporting standards for non-EU companies (N ESRS), setting out how the European Union’s Corporate Sustainability Reporting Directive (CSRD) will apply to large foreign businesses operating in the bloc. The draft, issued on June 3, significantly narrows the reporting scope, reducing the number of affected non-EU companies from around 10,000 to approximately 1,200. The requirements will apply to a limited number of very large non EU companies generating more than EUR450 million in EU turnover in each of the last two consecutive financial years and with a significant EU presence through high revenue branches or subsidiaries. Reporting obligations will typically fall on the ultimate parent company at group level. A key change is the shift from double materiality to impact materiality, meaning companies will report on their environmental and social impacts, particularly climate-related impacts, without assessing related financial risks. This change is expected to reduce compliance burdens and reflects a move toward closer alignment with international sustainability reporting frameworks. Next, the exposure draft of the N ESRS will be discussed by EFRAG’s Sustainability Reporting Board, then will be subject to public consultation before being finalized.

European Council agrees position on simplified transparency rules for sustainable financial products. On June 24, the Council of the European Union agreed its negotiating position on revised transparency rules for sustainable financial products, marking a key step in the ongoing review of the Sustainable Finance Disclosure Regulation (SFDR). The proposed changes aim to simplify the existing framework, reduce administrative burdens for financial market participants, and improve the ability of investors to understand and compare sustainability-related financial products. A central feature of the proposal is the introduction of three new product categories: “sustainable,” for products contributing to sustainability objectives; “transition,” for products supporting entities or projects on a credible path to sustainability; and “ESG basics,” for products that integrate environmental, social, or governance considerations but do not meet the criteria for the other categories. These categories are intended to replace existing product classifications that have been criticized for contributing to greenwashing and inconsistent market practices. The Council’s position will form the basis for negotiations with the European Parliament, with the final framework to be agreed through the EU legislative process.

EU launches consultation on guidelines for CSDDD. On June 12, the European Commission launched a public consultation on guidance that is proposed to be developed to support the implementation of the Corporate Sustainability Due Diligence Directive (CSDDD), an EU directive aimed at fostering sustainable and responsible corporate behavior. The consultation reflects the Commission’s effort to ensure that the guidance is proportionate, actionable, and aligned with existing international standards such as the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance and the UN Guiding Principles on Business and Human Rights. It seeks stakeholder input on how companies can effectively identify, prevent, mitigate, and end adverse human rights and environmental impacts across their operations and value chains. Information gathered in the consultation will inform the development of guidelines providing practical clarity on due diligence obligations, including risk identification, prioritization, stakeholder engagement, and the integration of due diligence into corporate policies and management systems. These guidelines are expected to also address expectations around monitoring effectiveness, public communication, and the establishment of grievance mechanisms. The consultation closes on July 24. The Commission has indicated it plans to adopt a set of guidelines in the first quarter of 2027.

EU adopts regulation establishing harmonized framework for transport GHG emissions accounting. The EU’s Regulation (EU) 2026/1030 – a significant step toward standardizing emissions accounting in the transport and logistics sector – is now in force, with core requirements that will apply from December 2, 2030. The regulation establishes a single, mandatory, harmonized framework for the calculation and disclosure of GHG emissions from transport services. With the aim of ensuring consistency and comparability of data across the EU, the regulation introduces a common methodology based on the EN ISO 14083 standard for measuring emissions across freight and passenger transport. It applies to transport operators, logistics providers, data intermediaries, and related service providers involved in the calculation and disclosure of transport emissions. The framework also sets out rules on the use of primary and secondary data in emissions calculations, the development of EU databases and calculation tools, and verification and certification requirements for emissions data and supporting systems.

UK: FCA proposes simplified climate reporting rules for investment products. The UK’s Financial Conduct Authority (FCA) has published a consultation on proposals to simplify climate-related reporting requirements for investment products. The proposals, announced on June 5, signal a shift in the FCA’s approach to climate disclosure, moving away from highly detailed reporting toward more proportionate and decision-useful information for investors. They would replace existing detailed product-level disclosures based on the Task Force on Climate-related Financial Disclosures (TCFD) with more targeted, consumer-focused information, aimed at improving clarity for retail investors while reducing reporting burdens. Firms would provide clearer information on how material climate risks could affect investment performance, while more detailed emissions data would be available on request. The FCA estimates that the reforms, which are part of a broader recalibration of UK sustainability disclosure frameworks (see our blog post here, for example), could result in savings of up to GBP20 million annually for firms, while maintaining meaningful disclosure of climate-related financial risks. Responses to the consultation are invited until July 13, with the FCA aiming to finalize the changes in fall 2026.

China Association for Public Companies releases first report on entities’ mandatory disclosures. In recent years, China’s Ministry of Finance and its stock exchanges introduced a series of sustainability and ESG disclosure guidelines for listed companies (including the Basic Standard and the Climate Standard on sustainability disclosures, as well as self-regulatory guidance), under which mandatory disclosure entities were required to publish their 2025 reports by April 30, 2026. On June 11, the China Association for Public Companies released its 2026 Analysis Report on Sustainability Information Disclosure by Mandatory Disclosure Entities, assessing that first annual cycle. The report indicates that, as of that date, all 430 mandatory disclosure entities had completed their disclosures. These companies generally structured their disclosures around the four core pillars of governance, strategy, risk and opportunity management, and metrics and targets. Climate-related disclosures, on the other hand, are evolving from basic emissions data toward financial impact analysis and integration into strategic management. Looking ahead, future regulatory and market assessments may place higher focus on the quality of disclosure, including more robust quantitative metrics, financial impact assessments, and tracking of target implementation.

Changes to Australia’s sustainability reporting regime. Australia’s proposed budget contemplates changes aiming to improve the country’s mandatory sustainability reporting regime. See our alert.

SBTi updates foundational standard. On June 12, the Science Based Targets initiative (SBTi) published its Corporate Net-Zero Standard V2.0, updating its original, widely adopted benchmark. While the original standard focused on validating businesses’ science-based net-zero goals, the updated standard is more expansive, additionally encouraging implementation, transition planning, and disclosure. It was created, SBTi states, to bring flexibility to target setting and implementation for businesses, “moving beyond a one-size-fits-all approach” to set out “target-setting options that reflect differing business contexts while remaining consistent with science.” Among the updates, the new standard encourages companies to prioritize direct emissions reductions across operations and value chains; recognizes best efforts, acknowledging that factors outside a company’s control may affect progress; and introduces a recognition mechanism to encourage companies to address the impact of their emissions in the short term. It also incorporates a longer-term requirement for larger companies to take progressive responsibility for their emissions. While the SBTi standard remains voluntary, it is widely regarded as a de facto global benchmark for corporate climate action, with significant implications for companies’ sustainability strategies and disclosures. The updated requirements may raise expectations around governance, data quality, and demonstrable progress, particularly for larger organizations. Overall, the development highlights a broader trend toward standardization and tightening of voluntary environmental, social, and governance (ESG) frameworks, which increasingly influence regulatory expectations and market practice. Alignment with SBTi standards may thus continue to shape how companies approach compliance with emerging sustainability reporting regimes, including in the EU and United Kingdom. More than 11,000 corporations globally already use the original Net-Zero Standard to support and advance their climate action. See the Corporate Net-Zero Standard Version 2.0 here.

ISO launches global consultation on net zero transition planning standard. On June 17, the International Organization for Standardization (ISO) opened a 12-week global consultation period for the draft ISO Net Zero Aligned Organizations Standard (ISO 14060) to ISO’s national members in more than 170 countries. The standard is the world’s first international independently verifiable standard designed to support organizations in developing credible and comprehensive net-zero transition plans. The proposed standard is intended to provide a common framework for organizations to develop and implement transition plans aligned with net‑zero objectives, supporting efforts to translate high‑level climate commitments into actionable strategies. The standard is sector agnostic, setting out guidance on governance, target setting, emissions reduction pathways, monitoring, and reporting. As with other ISO and SBTi frameworks, the standard will likely operate as a voluntary benchmark with quasi‑regulatory influence. Its development therefore signals continued convergence between market‑led standards and emerging regulatory requirements, particularly in areas such as climate disclosures and transition planning. The final standard is expected in 2027, subject to stakeholder feedback and the incorporation of comments received during the consultation process.

CDP expands disclosure system to include ocean data. CDP, formerly the Carbon Disclosure Project, has expanded its environmental disclosure system to include ocean data. In its press release, CDP noted “around 90% of global trade is transported on the world’s ocean, but decision makers still lack the data needed to understand their exposure to ocean-related risks and opportunities.” CDP, an independent voluntary environmental disclosure platform, also covers disclosure on data related to climate change, forests, water scarcity, biodiversity, and plastics. In 2025, more than 23,100 organizations disclosed environmental data through CDP. The 2026 CDP disclosure cycle opened June 15.

Extended producer responsibility

California’s EPR Program Plan: Costs, compliance, and design considerations for producers. On June 15, Circular Action Alliance (CAA) submitted its inaugural Program Plan to California’s Packaging Producer Responsibility Advisory Board, launching implementation of California’s packaging EPR program under SB 54. The Plan sets out the law’s implementation framework, detailing how producers will fund, administer, and execute the program to meet California’s source-reduction, recycling, and circular-packaging mandates. For companies selling packaged products into California, EPR may require coordinated compliance and challenge strategies. Our alert outlines key elements of the Program Plan and compares the Plan to CAA-managed programs in Oregon and Colorado, helping producers assess multi-state exposure and identify compliance opportunities relevant to cost, design, and market planning.

Two lawsuits against CalRecycle over SB 54. The California Department of Resources Recycling and Recovery (CalRecycle) is facing two separate lawsuits over SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act. In the first, announced on June 2, three environmental nonprofits sued the agency in state court, alleging that the regulations implementing SB 54 are inconsistent with the Act’s requirements and are arbitrary, capricious, or without reasonable or rational basis. The regulations, they argue, weaken the act by not excluding chemical recycling from the definition of “recycling.” They are calling on the court to issue “a declaration that the final regulations challenged in this suit are inconsistent with the Plastic Pollution Prevention and Packaging Producer Responsibility Act” and to mandate CalRecycle “to correct the invalid final regulations forthwith.” This case is in its earliest stages. See the complaint here.

In the second case, on June 22, a coalition of 17 State Attorneys General and the National Association of Wholesaler-Distributors (NAW) filed suit in the US District Court for California’s Eastern District, calling on the court to immediately block enforcement of the law. The suit argues that SB 54 is “a blatant and unprecedented attempt” by California “to impose its own policy preferences on the entire nation.” The law, the complaint states, violates the US and California constitutions in numerous ways, including by infringing on the sovereignty of other states. The program’s management by CAA, the complaint continues, “improperly vests power in an unelected, unaccountable body.” The plaintiffs are calling on the court to immediately block enforcement of the law. This case, too, is in its earliest stages. See the complaint here.

Launch of new universal symbol for reusable packaging and reuse systems. PR3: The Global Alliance to Advance Reuse has released a new universal symbol designed to identify reusable packaging and reuse systems worldwide. The symbol, journalist Elizabeth Segran reports in Fast Company, is part of a long-running “global effort to build the standards and logistics required to create a reuse system at scale.”

The symbol is already being added to a broad range of reusables and reuse infrastructure, ranging from foodware and beverage containers to cleaning products and infrastructure, in more than 12 countries, among them Canada, the UK, and the US. A growing number of stadiums in the US are reportedly providing reusable beverage cups that bear the symbol. They have also implemented reuse systems in which service providers handle pickups, washing, deliveries, and inventory, while digitally tracking the cups across the supply chain. The new reuse symbol reflects specific criteria in PR3’s Marking & Labeling Standard, soon to be published through the American National Standards Institute: Most notably, the symbol cannot be used for single-use, disposable products and may only be used by organizations that have designed and operate a complete, end-to-end loop that ensures the product is used, returned, sorted, cleaned, and reused.

Colorado enacts first-in-nation EPR framework for EV propulsion batteries. Colorado Governor Jared Polis has signed SB 26-003, the End-of-Life Management of Electric Vehicle Batteries Bill, expanding the state’s existing battery stewardship framework to set out an EPR framework for electric vehicle (EV) batteries. This is the first such law in the US. Among SB 26-003’s requirements, it:

• Requires propulsion battery providers – that is, automakers – to collect certain unwanted batteries and ensure their responsible management
  
  
• Bans sending propulsion batteries to landfills, starting July 1, 2029, a requirement aimed at laying the groundwork for their safe reuse, repurposing, or recycling
  
  
• Mandates specific recovery benchmarks for extracting critical minerals – a minimum recovery rate by 2031 of 50 percent for lithium and 90 percent for cobalt and nickel. By 2035, the recovery rate for lithium will rise to 80 percent
  
  
• Sets out key compliance deadlines:
  
  
  • By July 1, 2027, businesses that sell or distribute propulsion batteries or vehicles containing them into the state must register with Colorado’s Department of Public Health and Environment (CDPHE)
    
    
  • By January 2, 2029, battery providers must submit an education and outreach plan to the Colorado Department of Public Health and Environment
    
    
  • By July 1, 2029, the prohibition on retail sales by providers that do not participate in a battery stewardship program begins, along with their collection obligations
    
    
  • By June 1, 2030, battery producers must begin submitting annual reports to CDPHE that specify how they manage the batteries they collect, including recycling processes and mineral recovery rates

See SB-26-003 here.

California legislature considers adding medium-format batteries, vape pens to its EPR programs. The California state Senate is considering SB 501, which would update the Responsible Battery Recycling Act of 2022, the state’s battery EPR program, to include medium-format batteries, which it defines as rechargeable batteries weighing between 11 and 25 pounds or rated between 300 and 2,000 watt-hours. That definition would cover batteries for such products as lawnmowers, portable power systems, and e-bikes. In late May, SB 501 passed the Senate 20–10, and at this writing it is scheduled for an Assembly Environmental Safety and Toxic Materials Committee hearing. In addition, the state legislature is considering AB 2667, which would require the state Department of Toxic Substances Control to study ways to properly dispose of vape pens.

Lithium batteries: Emerging risks for manufacturers, handlers, and recyclers. Lithium-ion batteries power a wide range of consumer, industrial, and energy applications, from vehicles and mobile devices to data centers and grid-scale storage. As deployment has grown, so has the legal and regulatory activity surrounding the battery lifecycle. Increasingly, that activity is driven by large-scale environmental incidents. Recent incidents illustrate how events at a single site may result in broader environmental impacts, regulatory scrutiny, and questions about upstream responsibility. Companies that have never owned or operated battery storage or recycling facilities may now face enforcement actions, cleanup exposure, and statutory compliance obligations arising from downstream failures they did not control. Our alert looks at this rapidly evolving legal landscape for stakeholders across the lithium battery lifecycle.

Find out more about EPR. Visit DLA Piper’s Extended Producer Responsibility Hub to learn more about the firm’s work assisting businesses with their EPR obligations up and down the supply chain.

Sustainability: Regulatory

Bonn Climate Change Conference lays groundwork for COP 31. Diplomats in Bonn, Germany concluded their work in preparation for COP 31, the annual United Nations Climate Change Conference, on June 18. These mid-year conferences host negotiating sessions and technical discussions among the signatories to the United Nations Framework Convention on Climate Change to set the course for the annual COP summits, often revealing key sticking points. This year, negotiators were unable to move past stalemates in several key areas. Most notably, negotiators failed to make headway on issues related to financing climate adaptation in developing countries and on carbon-related trade restrictions. Important headway was made, however, on the Just Transition Work Programme, now formalized as the Belém–Antalya Mechanism, which aims to ensure that the benefits and burdens of transitioning away from fossil fuels are distributed fairly throughout society. Another significant development took place outside of the formal proceedings: a proposal from Turkey, dubbed “35 by 35,” to set a global electrification target, increasing the global share of final energy consumption from 20 percent to 35 percent by 2035. This joins two other initiatives Turkey is reportedly working to advance in preparation for COP 31 this November: cutting global waste and waste-derived methane emissions in half and reducing energy consumption in infrastructure 25 percent. COP 31 will convene in Antalya, Turkey from November 9 to 26 under the joint presidency of Turkey and Australia.

EPA sends four more California emissions waivers to Congress. On June 12, the Environmental Protection Agency (EPA) announced that it has transmitted four California pre-emption waivers to Congress for review under the Congressional Review Act (CRA). Those waivers authorized California to enact its own emission standards for cars, trucks, and certain power tools, equipment, and off-road engines. EPA contends that the waivers are administrative rules that should have been submitted to Congress for review under the CRA. In a media statement announcing the action, EPA stated, “Each of these waivers is a rule under the CRA, and because previous Administrations failed to transmit them [for CRA review], Congress has not been provided with its statutorily required opportunity to review these rules.” The four California waivers submitted to Congress are:

• Greenhouse Gas Emission Standards – 2009 and Subsequent Model Years, which allows the state to adopt and enforce strict vehicle GHG emissions standards
• Reinstatement of ACC I, which allows California to impose vehicle emission requirements higher than federal standards
• Motor Vehicle Evaporative Emissions and Greenhouse Gas (Advanced Clean Cars I, ACC I), which sets CA vehicle emission requirements stricter than federal standards
• Small Offroad Engine (SORE) Amendments, which sets California emissions standards for certain offroad engines and equipment

Earlier this year, EPA rescinded the Endangerment Finding, which serves as the basis for regulating vehicle GHG emissions, and repealed existing and future vehicle GHG emissions standards.

UK issues further guidance to support biodiversity net gain implementation. The UK government has published a series of updates and guidance materials supporting implementation of the biodiversity net gain (BNG) framework, including detailed information on:

• Registering biodiversity sites and allocating them to developments, clarifying the process for entering land into the biodiversity gain site register and how biodiversity units can be formally assigned to specific projects, including those consented under the planning and nationally significant infrastructure projects (NSIP) regimes. In England, BNG will be mandatory for NSIPs from November 2
• Statutory biodiversity credit pricing, providing updated pricing for government-issued biodiversity credits, which act as a last resort compliance mechanism where developers cannot achieve sufficient on site or off site biodiversity gains
• What can be counted toward a development’s biodiversity net gain, setting out eligibility criteria for on site habitat creation, off site gains, and statutory credits, and clarifying how different interventions contribute to the required net gain calculation
• Use of the statutory biodiversity metric and associated tools, offering further guidance on how to calculate biodiversity value using the official metric, including habitat condition assessments, unit calculations, and use of supporting tools and guidance documents

Together, these materials provide further operational clarity on the functioning of the BNG regime. While not introducing new legal requirements, the updates are expected to support more consistent application of the framework and help developers prepare for the extension of mandatory BNG requirements to NSIPs.

China releases report on product carbon footprint management. China’s Ministry of Ecology and Environment has released its Progress Report on the Establishment of a Product Carbon Footprint Management System (2026). The report, issued on June 17, follows the 2024 Implementation Plan on Building a Carbon Footprint Management Framework. It shows that, as of the end of 2025, China had issued 15 national standards for product carbon footprint accounting, covering such sectors as electrolytic aluminum, chemical fibers, and electrical and electronic products, alongside more than 200 group standards across industries including steel and chemicals. Work on carbon footprint factors and supporting databases is progressing, with key datasets, including those for the power sector, gradually being published and refined. In parallel, pilot schemes for product carbon labeling and certification have been launched, covering products such as lithium batteries, photovoltaics, steel, and electronics, with selected institutions participating in certification activities. See the progress report here.

EU Waste Shipment Regulation enters into application with launch of digital tracking system. Marking a significant step in modernizing EU waste governance, most provisions of the revised EU Waste Shipment Regulation have entered into application, alongside the launch of the EU’s Digital Waste Shipment System (DIWASS). The revised Regulation, adopted in 2024, forms part of the EU's broader efforts to strengthen controls on waste exports and improve the traceability of waste movements across borders. The new framework introduces stricter controls and fully digitalized, real-time procedures for managing cross border waste shipments across the EU, requiring waste movements to be processed through a central electronic system. It also reinforces the use of prior informed consent (PIC) procedures, under which exporters must obtain approval from relevant authorities in both the exporting and receiving countries before waste can be shipped. Overall, these requirements are expected to strengthen oversight of cross border waste movements and support efforts to combat the trade in illegal waste. The introduction of DIWASS also reflects a broader trend toward digitalization of environmental compliance, which is likely to increase reporting and monitoring expectations for businesses while improving regulatory consistency across member states. For operators, this may require adjustments to internal systems, processes and data management to ensure compatibility with the new digital platform. At present, transitional arrangements apply for certain waste categories, with operators allowed to continue using paper based procedures for some non hazardous waste shipments until December 31.

Sustainability: Litigation

Administration asks for voluntary dismissal of its appeal in wind EO litigation. On June 10, the Department of Justice (DOJ) filed a motion with the US Court of Appeals for the First Circuit asking for voluntary dismissal of its appeal in New York v. Trump, and on June 15, the court acceded, dismissing the Administration’s appeal. In this case, 17 US states, the District of Columbia, and an environmental nonprofit had challenged the President’s January 20, 2025 Executive Order (EO) halting federal permitting and leasing for wind projects. The dismissal of the case affirms the December 8, 2025 ruling by the US District Court for the District of Massachusetts vacating the EO, which froze federal leasing and permitting activities for both onshore and offshore wind projects. The district court concluded that the EO was unlawful, arbitrary, and capricious and that, in seeking to ban wind energy projects, the President was exceeding his authority. The outcome of this litigation is being widely reported as a sign that the Administration is abandoning its attempts to stop US wind energy projects. Despite this reversal for the Administration, however, the EO has significantly impacted the wind industry in the US, through still-extant tax guidance (making it harder for wind and solar projects to receive federal tax credits), buyouts (as of June 30, paying more than USD2.5 billion to offshore wind developers to surrender their leases), and administrative delays (such as requiring additional layers of review that affect project financing). On December 22, 2025, more than two weeks after the Massachusetts court’s ruling that vacated the EO, the Administration paused leases for five large-scale offshore wind projects under construction along the East Coast, stating that the Pentagon had identified national security risks in each of the projects.

Louisiana governor signs HB 804, immunizing companies against most climate accountability litigation. On June 11, Louisiana Governor Jeff Landry signed HB 804, the Louisiana Energy Protection Act, granting companies operating in the state sweeping, retroactive immunity in state court against civil lawsuits seeking redress for personal injury, property, or economic damage arising from climate change. Under HB 804, businesses may still be sued in a Louisiana state court for violating workplace safety standards, government-mandated emissions caps, or the explicit terms of environmental permits. The legislation also allows litigation already in process to move forward and allows climate-related litigation when a suit is filed under the Louisiana Coastal Resources Management Act of 1978.

Greenwashing

Another coffee company faces allegations of greenwashing. Recyclability claims have served as a significant source of greenwashing litigation risk for consumer products companies. A recent example is Tye v. Gavina, a putative class action brought in the Superior Court of the State of California. The allegations in this case are highly similar to those being brought against Keurig Dr. Pepper, which we covered in recent issues. The plaintiff in the matter alleges that F. Gaviña & Sons, a gourmet coffee roaster, falsely advertises its coffee pod products as recyclable, but that “coffee pods are not presently recyclable, and were not recyclable at any time within the operative Limitations Period.” This marketing, the complaint states, is “illegal, false, deceptive and/or misleading advertising constituting unlawful, unfair and/or fraudulent business acts or practices.” The complaint also specifically states that the action involves greenwashing. The defendant is seeking, among other things, class action certification, “an order to correct, destroy, and change all false, deceptive, untrue, unlawful and/or misleading labeling relating to the Claims,” and monetary relief. This case is in its earliest stages.

Appeals court rules greenwashing language mandates in Maryland law are unconstitutional. The US Court of Appeals for the Fourth Circuit has partially blocked Maryland’s SB 1, finding that its limitations on the ways suppliers can describe their renewable energy products are unconstitutional restrictions on speech. SB 1 was enacted in 2024 to strengthen consumer protections in Maryland’s retail electricity market. At question in the case was the bill’s requirement that retail energy companies substantiate any green claims they make about their products. As the appeals court explained in its ruling, the state had found that “consumers were increasingly unaware that despite selecting and paying a premium for a supplier they believed to be providing renewable energy, the electricity introduced to the grid from that supplier was not derived from solely renewable sources.” SB 1, the court concluded, failed to meaningfully address that confusion. The court also considered new regulations issued in the middle of the case by the Maryland Public Service Commission prescribing mandatory disclosure language about providers’ use of renewable energy certificates (RECs), concluding that the mandated language also overstepped. (Here is EPA’s explanation of RECs.) In its ruling, the appeals court directed the US District Court for the District of Maryland to preliminarily enjoin SB 1’s language limits on electricity suppliers’ "clean, green, eco-friendly, environmentally friendly” and similar claims. The remainder of SB 1 was untouched. The case is Retail Energy Advancement League & Green Mountain Energy Co. v. Brown.

Supply chain integrity and human rights

CBP forced labor enforcement continues with two more WROs. US Customs and Border Protection (CBP) has issued two Withhold Release Orders (WROs) against garments made in factories in Jordan. The WROs against the factories, which are operated by Needle Craft Ltd. and Casual Wear Apparel L.L.C., became effective immediately on June 23, the date they were issued. CBP stated, “Both WROs were issued due to violations of 19 U.S.C. § 1307, the law prohibiting goods made with forced labor from entering the United States.” These are the fifth and sixth WROs issued during this fiscal year. CBP will detain shipments of garments manufactured by Needle Craft and Casual Wear at all US ports of entry. With these latest developments, CBP is currently overseeing 58 WROs and eight Findings under 19 U.S.C. § 1307.

Canada raises the bar on forced labor enforcement: Bill C-35 intensifies supply chain compliance obligations. On June 2, the Office of the United States Trade Representative (USTR) presented findings that Canada is not effectively enforcing its forced labor import prohibition and has thus burdened US commerce. In light of the findings, the USTR proposed a 10-percent tariff on a wide range of Canadian products. Canada, under its Customs Tariff, has since 2020 prohibited the importation of goods mined, manufactured, or produced wholly or in part by forced labor. In the wake of the USTR report and proposed US tariffs, on June 12 the Canadian government introduced Bill C-35, An Act respecting the prohibition of the importation of goods produced by forced labour, which would replace the current import prohibition under the Customs Tariff. It would move the Canadian regime toward a more targeted model by allowing listed goods to become subject to prescribed information requirements and by deeming those goods prohibited imports if the requirements are not satisfied. Our alert tells you more.

UK to strengthen deforestation rules for key commodity supply chains. On June 23, the UK government announced plans to tighten rules on deforestation‑linked supply chains, expanding requirements to cover commodities such as coffee, cocoa, soy, and palm oil. The government stated that it plans to consult on the introduction of these mandatory due diligence requirements for businesses in Great Britain, including by using extant powers, such as those under the Environment Act, which focuses on illegal deforestation, and by strengthening the existing UK Timber Regulation. The proposed measures would aim to build on existing due diligence obligations by strengthening requirements for businesses to ensure that products placed on the UK market are not linked to illegal deforestation, with a focus on improving traceability and accountability across global supply chains. The measures would also bring Great Britain into closer alignment with the EU’s deforestation regulation. Further details on the consultation process will be announced in due course.

China issues rules on industrial and supply chain security investigations. On June 22, China’s Ministry of Commerce (MOFCOM) unveiled a set of rules regarding investigation of industrial and supply chain security. The rules, which took effect immediately upon publication, were formulated under the Regulations on the Security of Industrial and Supply Chains issued by the State Council in March. Under the rules, MOFCOM may initiate investigations when foreign countries, regions, or organizations impose discriminatory or restrictive measures on China's industrial and supply chains, or where foreign entities or individuals disrupt normal transactions with Chinese parties, take discriminatory actions, or cause or threaten harm to China's supply chain security. Investigation methods may include inquiries, document review, questionnaires, sampling and hearings, and on-site inspections, with parties required to cooperate. MOFCOM may also carry out on-site investigations overseas, except where the relevant country or region objects. Based on the result of the investigation, MOFCOM, along with other authorities, may impose countermeasures, such as trade restrictions, investment bans, special fees, sanctions, and entry or visa restrictions. See the rules here.

Energy and natural resources

CARB adopts updates to Cap-and-Invest Program. With the goal of facilitating California’s 2030 and 2045 climate goals, CARB has adopted key updates to the Cap-and-Invest Program, which requires large GHG emitters to purchase emission permits. CARB adopted changes on May 29 to align the program’s regulatory framework with the legislature’s reauthorization of the program last year through 2045, including:

• Doubling the Manufacturing Decarbonization Incentive Fund, which supports emissions reductions projects at industrial facilities, to USD4 billion
• Tightening allowance budgets by removing 118 million allowances from future budgets, which is expected to result in an 11-percent year-over-year reduction in the GHG emission cap for the rest of the 2020s and a projected average annual decline of 7 percent from 2031 to 2045

Cap-and-Invest is California’s long-running cap-and-trade emissions program, signed into law by Governor Arnold Schwarzenegger in 2006. Since then, the program has funded USD35 billion in “climate investments” ranging from wildfire prevention and environmental restoration to low-carbon transit and EV rebates. The program also funds the California Climate Credit, which is automatically applied to state residents’ electric and gas bills. On June 25, Québec, California, and the state of Washington signed a draft agreement to align and link their cap-and-invest programs, creating North America’s largest single market in emissions reductions.

North Carolina SB 730 would bar retirement of baseload power plants until utility obtains approval for nuclear plant construction. In early June, North Carolina’s House passed SB 730, the Ratepayers Protection Act, which includes measures that would block the state Utilities Commission from authorizing the retirement of baseload power facilities– such as coal-fired plants – until the state issues a certificate for the construction of at least one nuclear facility with 1,000 megawatts or more of generating capacity. That aspect of SB 730 is reportedly raising concerns about the environmental and financial consequences of prolonged fossil fuel-based facility operations. SB 730 also contains measures addressing the environmental footprint and community impact of data centers. Further, it would shift responsibility for a cost impact study of the state’s 2050 carbon neutrality goal from the General Assembly’s legislative service officer to the North Carolina Collaboratory, a state-authorized research-policy organization based at the University of North Carolina. At this writing, SB 730 has been sent back to the state Senate and has moved through two of that chamber’s committees.

EU: Agreement on stronger price controls for ETS2 carbon market. The European Parliament and EU member states have reached a provisional agreement to strengthen price control mechanisms in the EU’s updated Emissions Trading System 2 (ETS2), a carbon market affecting buildings and road transport. ETS2, due to launch in 2028, will introduce carbon pricing on fuels used for heating and road transport, requiring fuel suppliers to purchase emissions allowances. The agreement brings with it enhanced safeguards to limit price increases and volatility, including a mechanism to release additional allowances onto the market if prices exceed 45 per tonne of CO₂. Under the revised system, the volume of allowances that can be released is increased to 40 million allowances per intervention, double the previous level, with the mechanism capable of operating multiple times per year. The revised framework will also extend the operation of the market stability mechanism beyond 2030. The agreement reflects an effort to balance the expansion of carbon pricing with concerns around affordability and market stability, particularly because ETS2 targets sectors with a direct impact on households and small businesses. Strengthening the price control mechanism provides greater predictability and is intended to reduce the risk of sudden price increases, which could affect consumer energy and fuel costs. At the same time, increasing the availability of allowances and introducing a defined price trigger could moderate carbon price levels in certain market conditions, potentially influencing the strength of the price signal intended to drive emissions reductions. The design therefore reflects a trade-off between price stability and the effectiveness of carbon pricing as a decarbonization tool. The provisional agreement is expected to be formally approved by the European Parliament and Council, after which the revised rules will be incorporated into the ETS2 framework ahead of its planned 2028 launch.

EU moves to strengthen Carbon Border Adjustment Mechanism. The Council of the EU has agreed its position on proposals to strengthen the Carbon Border Adjustment Mechanism (CBAM). The Council’s position will form the basis for interinstitutional negotiations with the European Parliament, with agreement on final amendments expected later in 2026. The proposed changes would:

• Extend CBAM’s scope to certain downstream products (e.g., goods made using steel or aluminium), addressing gaps where emissions could shift further along the value chain outside the EU
  
  
• Introduce new anti‑circumvention measures, including bringing certain scrap materials into scope and allowing the Commission to act against deceptive reporting practices
  
  
• Clarify rules allowing temporary exemptions in cases of serious market disruption, with more defined conditions for their use

The Council’s position forms the basis for negotiations with the European Parliament on final legislative amendments. The agreement represents a targeted strengthening of the CBAM framework and signals increasing regulatory focus on enforcement and real-world application, with likely implications for compliance expectations and scrutiny on importers and supply chains. The inclusion of flexibility mechanisms also reflects an effort to balance climate objectives with economic considerations. Overall, the update reinforces CBAM’s role as a central EU climate and trade instrument, with growing relevance for both EU and international market participants.

UK introduces funding framework for offshore carbon storage decommissioning. On June 11, the UK adopted the Carbon Dioxide Transport and Storage (Financing of Costs of Offshore Decommissioning) Regulations 2026, establishing a framework to ensure that the costs of decommissioning offshore carbon capture and storage (CCS) infrastructure are properly funded. The regulations, which come into force on July 10, require operators of offshore CO₂ transport and storage infrastructure to estimate future decommissioning costs and establish dedicated financial provision arrangements to cover those liabilities. Operators must make ongoing financial contributions based on approved funding and investment strategies, with oversight from the Secretary of State. The regulations represent an important step in addressing long‑term liability and funding risks associated with emerging carbon storage infrastructure. By requiring operators to set aside funds for decommissioning, the framework helps ensure that environmental obligations can be met without relying on future public funding.

China: Three-year action plan on industrial energy saving and carbon reduction. China’s National Development and Reform Commission has issued a three-year action plan to advance energy saving and carbon reduction upgrades in key industries. Starting this year, the plan focuses on nine sectors: steel, electrolytic aluminum, cement, flat glass, oil refining, ethylene, synthetic ammonia, methanol, and coal-fired power. The plan also sets out supporting measures, including financial support, price guidance, and standards, and establishes requirements for implementation. From 2028, the scope may be expanded to additional sectors depending on the progress of its implementation, and local authorities may implement the program based on local conditions. See the plan here.

Singapore to introduce measures to reduce emissions from cooling equipment. Singapore’s National Environment Agency (NEA) has announced plans to introduce new measures aimed at reducing emissions from refrigeration and air conditioning (RAC) equipment, a key source of GHG emissions. The measures will be introduced from July 2027 and will apply to large commercial refrigeration systems, transport refrigeration, and air-conditioning systems in passenger cars and light goods vehicles. The measures apply only to new equipment; businesses can continue using existing systems until those systems reach the end of their service lives. In particular, new refrigeration systems will be required to use refrigerants with a global warming potential (GWP) below specific thresholds, and businesses handling certain equipment will be required to comply with registration and refrigerant disposal requirements. The announcement signals a strengthening of Singapore’s approach to emissions reduction in the cooling sector, which is a growing area of focus globally due to rising energy demand and the climate impact of refrigerants. By targeting RAC systems, the measures address both direct emissions (from refrigerant leakage) and indirect emissions (from electricity consumption). The introduction of GWP limits for new equipment reflects a shift toward refrigerant transition frameworks already seen in jurisdictions such as the EU and Japan, indicating increasing international alignment in cooling regulation. Further details on the scope and implementation of the measures are expected as NEA formalizes the regulatory framework. Key requirements will begin to apply from July 2027 for commercial refrigeration and refrigerant management obligations, with additional requirements for vehicle air conditioning from July 2028. This will allow vehicle suppliers additional time to adjust as some models using lower-GWP refrigerants are not yet widely available.

Sustainability in financial services

New York City seeks new asset managers that support its pension funds’ ESG goals. On June 12, New York City Comptroller Mark Levine announced that the city’s five pension funds will launch a search for new asset managers to provide passive indexing of public equity stocks that support funds’ ESG goals. “This includes capitalization weighted indexes, smart beta/alternatively weighted indexes, or any other type of indexed portfolio (consistent with each System’s investment guidelines), such as those based on ESG factors and limits on carbon,” the Comptroller stated in a press release. The move seeks to replace two prominent asset managers whose contracts are not being renewed, per the recommendation of prior Comptroller Brad Lander, due to their unsatisfactory decarbonization strategies. Levine stated that New York City’s five pension fund systems held USD127.11 billion in public equity investments as of March 31, with “the majority invested in passive index products.” Of the five pension funds, three – the Board of Education Retirement System, Teachers’ Retirement System, and New York City Employees Retirement System – have set objectives to reach net zero across their portfolios by 2040. In April, Levine announced that those funds had already surpassed their interim targets and between 2019 and 2025 had a weighted average Scope 1 and Scope 2 emissions reduction of 48.13 percent. Asset managers have until July 15 to submit their applications.

ISO launches global net zero transition planning standard for financial institutions. In a development expected to create more structured and comparable transition planning in the financial sector, on June 4, the ISO launched ISO 32212:2026, a new global standard for net‑zero transition planning in financial institutions. The standard provides a common framework for banks, insurers, asset managers, and investors to develop, implement, and maintain transition plans aligned with the goals of the Paris Agreement. It applies across a wide range of financial activities and is designed to embed climate considerations into core business strategy and decision‑making. The framework sets out requirements and guidance for integrating transition objectives into governance, risk management, and financial activities, including assessing climate‑related risks and opportunities, setting targets, allocating capital, and monitoring and reporting progress over time. By embedding climate considerations into core financial decision‑making, the framework may influence how institutions approach lending, investment, and risk management, while also complementing emerging regulatory expectations on transition planning and disclosure. While voluntary, the standard is likely to function as a benchmark for credible transition plans in the sector, particularly as scrutiny from regulators and investors continues to grow. ISO 32212 is available for voluntary adoption, with uptake expected to develop over time as financial institutions integrate transition planning into broader ESG and resilience strategies and regulatory compliance processes.

China: Guidelines on applying sustainable investment strategies to public securities. The Asset Management Association of China has issued its Guidelines on the Application of Sustainable Investment Strategies for Public Securities Investment Funds (Trial). The guidelines provide a framework for the classification, application, and disclosure of sustainable investment strategies by public funds. They categorize sustainable investment strategies into negative screening, positive screening, ESG integration, thematic investing, and impact investing, and require fund managers to clearly define the methodologies they have applied, the sources of their data sources, and how these were used in investment decision-making. Consistency must be maintained across fund contracts, prospectuses, and ongoing disclosures, and key parameters, screening criteria, and potential data and model risks must be disclosed. In addition, Article 11 of the guidelines provides that, where a fund adopts a sustainable investment strategy, its performance benchmark should align with that strategy. When this requirement is not met, adjustments should be made starting from the implementation date of the guidelines, which was June 12.

Report: Major banks’ financing of fossil fuel projects rose globally in 2025. In 2025, financing of new fossil fuel projects by the world’s leading banks rose 8 percent over 2024, according to the annual Banking on Climate Chaos (BOCC) report. “The top 65 banks committed $508 billion to companies expanding fossil fuel developments in 2025 — a $108 billion increase since 2024, or roughly 27% in a single year,” the report stated. Among the BOCC’s key findings:

• The world’s 65 largest banks committed USD906 billion to companies conducting business in fossil fuels in 2025, a rise of USD64 billion or 7.6 percent from 2024
  
  
• A small number of global banks from a small number of countries provide the majority of fossil fuel financing to an increasingly smaller number of fossil fuel borrowers
  
  
• The US is the world’s single largest regional source of fossil fuel financing, with US banks providing 32 percent of such funding globally
  
  
• More than a third of the world’s largest banks (26 of 65) reduced their fossil financing from the previous year, mostly driven by certain European and Canadian banks

The report concludes by urging extensive macroprudential, monetary policy, and financial regulatory reforms, stating, “The momentum of clean energy deployment and the lived experience of fossil fuel instability facing billions of people demand that banks finally make that choice — and that governments enforce it.” The Banking on Climate Chaos report has been produced annually since 2009 by a consortium of environmental organizations, such as the Sierra Club, the Rainforest Action Network, and Reclaim Finance.

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

• High-level Political Forum on Sustainable Development will take place July 6 to 15, 2026 at United Nations Headquarters in New York City.
• 2026 UN Convention to Combat Desertification (UNCCD) COP17 will take place August 17 to August 28, 2026 in Ulaanbaatar, Mongolia.
• 14th International Conference on Sustainable Development will be held September 9 and 10, 2026 in Rome.
• United Nations Climate Week 4 will be held September 7 to 11, 2026 in Baku, Azerbaijan.
• 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 November 9 to 26, 2026 in Antalya, Turkey, with Australia presiding over 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.