Covington & Burling LLP

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In its public consultation on the review of the Market Surveillance Regulation (EU) 2019/1020, the European Commission suggests the possibility of “establishing an EU Market Surveillance Authority” to improve enforcement against products that do not comply with EU legislation regulating the environmental and safety requirements of products (“product legislation”).

The Commission’s review aims to

California regulators tasked with implementing and enforcing the state’s two landmark climate disclosure laws released draft regulatory text on December 9, 2025, providing additional insight on key issues, including initial deadlines for reporting greenhouse gas (“GHG”) emissions and details on how regulators will determine annual fees. The release of the draft regulations is the latest

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 and promote products that are

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 February (see more here)

In the lead-up to COP30 in Brazil, the newly created Task Force for Corporate Action Transparency (TCAT) launched two comprehensive greenhouse gas reporting frameworks designed to fill an important gap in how companies measure, report on, and verify their corporate climate actions.  TCAT leadership has indicated that the frameworks will be formally launched at COP30

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

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

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