On October 20, 2025, a coalition of nineteen leading companies in the energy, finance, and logistics sectors, launched the Carbon Measures Coalition, proposing a significant departure from established carbon accounting frameworks. The Coalition represents a prominent industry-led effort to move away from traditional inventory-based emission calculation methods toward a new model: ledger-based emissions tracking
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Covington & Burling LLP Blogs
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The Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for Stakeholders
In late October, the Greenhouse Gas Protocol (“GHG Protocol”) proposed updated Scope 2 guidance for companies quantifying and reporting their greenhouse gas (“GHG”) emissions. If finalized as proposed, the guidance would have significant impacts on how companies plan their renewable energy investments and measure progress toward their climate goals. The main changes proposed to the…
EPA Proposes Changes to TSCA PFAS Reporting Rule
On November 10, 2025, EPA released a proposed rule under the Toxic Substances Control Act (“TSCA”), proposing to amend its reporting requirements relating to per- and polyfluoroalkyl substances (“PFAS”). The original rule, promulgated in 2023, led to concerns by some regulated entities that it would be difficult to collect the data required by the rule…
California AG Targets Plastic Bag Manufacturers for Misleading Recyclability Claims
On October 17, 2025, California Attorney General Rob Bonta announced enforcement actions against seven plastic bag manufacturers for allegedly violating state environmental and consumer protection laws through explicit and implicit claims that plastic bags sold in California were recyclable. This comes at the conclusion of an investigation of these plastic bag manufacturers initiated by the…
State Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program
While the Environmental Protection Agency (“EPA”) is proposing to amend the federal Greenhouse Gas Reporting Program (“GHGRP”) to remove reporting requirements for nearly all sources, it remains important for companies to track developments and manage their compliance obligations with existing and emerging state GHG reporting programs. Several states, such as California, already have some form…
Spain Proposes Strict Sustainability Requirements for Data Centers
The Spanish Ministry for Ecologic Transition and Demographic Challenge (“MITECO”) has launched a public consultation on a Draft Royal Decree (“Draft Royal Decree”) that would impose strict energy efficiency and sustainability requirements on data centers in Spain. The proposed requirements of the Draft Royal Decree are broader and stricter than the requirements on data centers…
Trump Administration Issues AI Action Plan and Series of AI Executive Orders
On July 23, the White House released its AI Action Plan, outlining the key priorities of the Trump Administration’s AI policy agenda. In parallel, President Trump signed three AI executive orders directing the Executive Branch to implement the AI Action Plan’s policies on “Preventing Woke AI in the Federal Government,” “Accelerating Federal Permitting of…
EU Member States Agree on CSRD/CSDDD Omnibus Negotiating Mandate
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 step in the EU’s legislative…
An EU Biodiversity Market by 2027? The new EU’s Roadmap towards Nature Credits.

On July 7, 2025, the European Commission presented its Roadmap Towards Nature Credits, setting the blueprint for biodiversity certification in the EU. The Communication was also accompanied by a Q&A and a call for feedback by 30 September 2025.
Nature Credits: Practical Uses Across Sectors
In short, nature credits will constitute quantifiable and fungible…
EUDR Back on the Horizon: Preparing for December 2025 Compliance
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 materials to support EUDR implementation,…