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Advanced Clean Fleets Regulations No Longer in Force for Most Fleet Operators and Owners

In the face of the Trump administration’s hostility toward California’s Clean Air Act waivers in general, CARB withdrew its request to EPA for a waiver for the Advanced Clean Fleets (ACF) regulation on January 13, 2025....more

A New Era of Climate Accountability: State Climate Superfund Laws Gain Momentum

As climate adaptation and mitigation costs escalate, a wave of state climate superfund legislation is emerging across the United States. This novel approach to climate accountability, pioneered by Vermont and New York,...more

APHIS Reinstates Legacy Biotechnology Regulations: Implications for CRISPR-Edited Plants

USDA Animal and Plant Health Inspection Service (APHIS) announced on January 23, 2025, that it is reinstating its legacy notification procedure as of February 7, 2025, providing a streamlined alternative to permits for...more

California Updates Prop 65 Short-Form Warning Requirements

On January 1, 2025, new regulations governing Proposition 65’s so-called safe-harbor warnings went into effect. Proposition 65 requires businesses that employ 10 or more persons to provide “clear and reasonable” warnings on...more

EPA’s PFAS Enforcement Plan Advances As Two PFAS Reporting Requirements Set To Go Into Effect

EPA Adds Nine New PFAS to List of Chemicals Subject to Toxic Chemical Release Reporting Under the Emergency Planning and Community Right-to-Know Act and The Pollution Prevention Act On January 6, 2025, the EPA published a...more

FDA Issues Action Levels for Lead in Baby Food

On January 6, 2024, the U.S. Food and Drug Administration (FDA) issued its final guidance establishing action levels for lead in processed food intended for babies and young children. This is the first FDA guidance directly...more

MoFo’s State + Local Government Enforcement Newsletter (December 2024)

Morrison Foerster’s State and Local Government Task Force is pleased to provide our bimonthly newsletter summarizing some of the most important and interesting developments from state attorneys general (State AGs) across the...more

California Climate Laws, CARB Opens Comment Period Seeking Industry Input by February

On December 16, 2024, the California Air Resources Board (CARB) called for public comment on key issues related to the implementation of California’s two major climate disclosure bills, the Climate Corporate Data...more

An Insecure Future: Court Ruling Guts USDA Regs On Genetically Engineered Plants

In a decision that raises significant questions about the future oversight of genetically engineered (GE) plants in the United States, the U.S. District Court for the Northern District of California on Monday, December 2,...more

Prepare to Disclose: California Legislature Declines to Extend AB 1305 Voluntary Carbon Market Disclosure Deadline, Leaves...

Last year, California passed three first-in-the-nation climate laws imposing disclosure obligations on thousands of companies with a presence in California. In October of 2023, California signed into law AB 1305, requiring...more

EPA May Now Pursue PFOS and PFOA Manufacturers and Users under CERCLA

Effective as of yesterday, July 8, 2024, two widely used per- and polyfluoroalkyl substances (PFAS)—perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) are deemed hazardous substances under the Comprehensive...more

Biden Administration Releases Joint Policy Statement and Principles for Voluntary Carbon Markets

The Biden Administration released a landmark Joint Policy Statement and Principles on May 28, 2024, formalizing the U.S. government’s approach to advancing high-integrity Voluntary Carbon Markets (“VCMs”) and affirming the...more

Now Is The Time For PFAS Manufacturers And Importers To Prepare For TSCA's Retrospective Reporting Requirements

Manufacturers and importers of Per- and Polyfluoroalkyl Substances (“PFAS”) must report information regarding all PFAS produced or imported since January 1, 2011, by either May 5, 2025, or November 10, 2025. The EPA recently...more

CARB Advanced Clean Fleets: High Priority Fleets Should Report by February 1

Next week marks the first compliance deadline for “high priority fleets” under California’s Advanced Clean Fleets (ACF) regulation. Under the rule, by February 1, 2024, companies that own or direct fleets of vehicles for...more

California Enacts AB 1305 to Strengthen the Voluntary Carbon Market and Continues to Lead on Climate Regulation

On October 7, 2023, California took a significant step toward promoting transparency and integrity of voluntary carbon markets (VCMs) and climate-related claims by enacting Assembly Bill 1305: the Voluntary Carbon Market...more

Uncertainty in Carbon Markets Leads to Novel Carbon Offset Litigation

Net zero goals and carbon neutrality have hit the mainstream, propelled over the past decade by consumer and investor demands that businesses curb greenhouse gas emissions to counter the climate crisis. In response, companies...more

FTC Extends Deadline to Comment on 10-Year Update to Green Guides

The Federal Trade Commission (FTC) is seeking public comment on its Guides for the Use of Environmental Marketing Claims (“Green Guides” or “Guides”) as part of a 10-year review process. The FTC extended the public comment...more

The $369bn Climate Deal: America’s Path to Climate Resilience

Two weeks after Sen. Joe Manchin tanked the downsized Build Back Better package, Senate Democrats on July 27, 2022 released the proposed Inflation Reduction Act of 2022 (the “Act” or IRA). While not focused entirely on...more

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