Understanding New Mexico’s New PFAS Product Labeling Requirement

By Danelle Gagliardi and Abigail Dop on May 8, 2026 Posted in Chemicals & Products

Regulation of per- and polyfluoroalkyl substances (PFAS) in consumer products continues to accelerate across the United States at the state level. In addition to phase-outs and bans on certain consumer products containing PFAS, state regulators are turning to labeling requirements as a tool to drive transparency and liability.

One notable recent development comes from New Mexico. The New Mexico Environment Department (NMED) formally proposed a rule to require consumer-facing labels on products containing intentionally added PFAS. On March 23, the New Mexico Environmental Improvement Board (NMEIB) officially approved the rule, making New Mexico the first state to require such labels on all products containing PFAS, even if those products are currently exempt from reporting/disclosure obligations to the state. The labeling requirements will go into effect January 1, 2027.

Although the precise label is not yet finalized, the required label is expected to consist of an Erlenmeyer flask image containing the word “PFAS.” For products other than complex durable goods, this label will be required to appear on the product and in some cases the packaging as well. For complex durable goods (defined to include products with a useful life of at least five years and composed of at least 100 components) the label need not appear on the product but must be included in a consumer-facing product specification sheet and operation and maintenance manual.

UK Parliamentary Committee Publishes Report on PFAS Risks

By Francesca Puttock on April 23, 2026 Posted in Chemicals & Products, Climate Change & Sustainability, Environmental, Environmental Due Diligence, Food Safety, Food-Contact Materials and Articles, Health & Safety, Supply Chain, Water Quality

It has been a couple of months since the UK PFAS Plan was published and made countless headlines. Today (23 April 2026), having gathered evidence as part of a parliamentary inquiry, the House of Commons’ Environmental Audit Committee (“EAC“) published a report titled ‘Addressing the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)‘.

The report summarises the conclusions drawn by the EAC in the course of its inquiry and makes recommendations grouped into three areas:

Preventing PFAS at source
Human exposure and risk management
Addressing pollution.

There is a lot to digest in this report, so we have highlighted some notable examples of the conclusions and recommendations reached by the EAC:

Emerging State-Level Greenhouse Gas Emissions Reporting Frameworks

By Michael Cox and Phil Sandick on March 25, 2026 Posted in Air Quality, Climate Change & Sustainability, Rulemaking & Policy Development

As the US Environmental Protection Agency (EPA) rolls back greenhouse gas (GHG) laws, rules, and regulations consistent with Trump Administration priorities, several states are advancing legislation to create their own GHG emissions reporting frameworks. While some of these initiatives generally mirror California’s climate disclosure requirements, this new state-led regulatory landscape is creating a state-by-state patchwork that businesses must now monitor.

Federal Rollback

Beginning with President Trump’s Executive Order 14154, “Unleashing American Energy” (January 20, 2025), the Trump Administration has made clear that it opposes any laws—federal or state—addressing the causes or impacts of climate change. For example:

UPDATE: CARB Passes Initial Climate Disclosure Regulation under SB 253 and SB 261

By Alex Arensberg, Lianne Mantione, Michael Cox and Phil Sandick on March 13, 2026 Posted in Air Quality, Climate Change & Sustainability, Rulemaking & Policy Development

At its February 26, 2026 meeting, the California Air Resources Board (“CARB”) approved a key step in implementing California’s landmark climate disclosure laws. CARB adopted the long-awaited California Corporate Greenhouse Gas Reporting and Climate Related Financial Risk Disclosure Initial Regulation (“Initial Regulation”) implementing the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261). The Initial Regulation establishes the administration and implementation fee structure for SB 253 and SB 261 and sets the first emissions reporting deadline under SB 253: August 10, 2026. Notably, compliance with SB 261 remains voluntary after the U.S. Court of Appeals for the Ninth Circuit enjoined enforcement of that law.

Our previous, in-depth analysis of these two laws can be found here. In general, SB 253 and SB 261 require large companies doing business in California to disclose climate-related information, including Scope 1, 2, and 3 greenhouse gas (“GHG”) emissions and climate-related financial risks. SB 253 applies to companies with more than $1 billion in annual revenue, while SB 261 applies to companies with more than $500 million in annual revenue. As clarified in the Initial Regulation, these revenue thresholds are tied to entities’ gross receipts as reported to the California Franchise Tax Board.

USFWS Proposes Changes under the Endangered Species Act

By Tabitha Madziwanzira, Jennifer Tharp and Danelle Gagliardi on February 20, 2026 Posted in Endangered Species Act

The Endangered Species Act (“ESA”) has seen a 99% success rate in protecting listed species since its inception in 1973. After celebrating its 52^nd anniversary this year, there are diverging views about how to continue to advance this success while developing efficiencies in the decision-making process. Most recently, the US Fish and Wildlife Service (“USFWS”) published four proposed rulemakings in quick succession that generated thousands of comments from the public, zoo and animal foundations, and other interested parties. The four proposed rules specifically relate to listing and delisting decisions, interagency cooperation and consultation, allowance of economic factors in decision-making, threatened species protection, and critical habitat exclusions. The comment deadline for all four proposed rules was December 22, 2025, despite requests from multiple organizations for an extension of the comment period to March 2026. Over 300,000 comments were received on each proposed rule prior to the deadline.

Defra releases anticipated ‘PFAS Plan’

By Francesca Puttock on February 3, 2026 Posted in Chemicals & Products, Environmental, Food Safety, Food-Contact Materials and Articles, Health & Safety, Supply Chain

Today we published an update on Defra’s PFAS Plan: “UK Government Releases PFAS Plan Teased in December 2025“. This plan features among the commitments made in the Environmental Improvement Plan made public at the end of last year.

It is generally recognised that the UK needs a plan for PFAS management, but in the hours following the publication of the plan, some commentators expressed that some of the measures identified in the plan lacked clarity (in particular in relation to specific timeframes).

Tackling PFAS is a key policy area in the EU and UK. At the end of January, the European Commission published a report (“The cost of PFAS pollution for our society“) estimating that “if the current levels of PFAS pollution in Europe continue until 2050 without regulatory action, the cost will reach approximately €440 billion during that period. Tackling such PFAS releases at the source by 2040 would save €110 billion, whereas treating polluted water alone would cost more than €1 trillion.”

But PFAS are a wide group of substances, integrated into countless product supply chains, and across most industries, in many cases with no clear alternatives. Another notable piece of research focusing on six fluoropolymers and F Gas and examining the potential impact of a full or partial EU REACH restriction recently called for a “balanced approach that protects the environment while preserving industrial and technological capability” (“The [PFAS] and their role as enablers in the competitiveness of European industry“). This document will be of particular interest to businesses in the aerospace, defence, green energy, and semiconductor sectors.

UK Deposit Return Scheme (DRS) Update – Deposit Management Organisation (UK DMO) Trading Name and Logo

By Nicola Smith and Francesca Puttock on January 28, 2026 Posted in Chemicals & Products, Environmental, Uncategorized

The UK DMO (the body responsible for the design and delivery of the DRS across England, Scotland, and Northern Ireland) has announced:

its new trading name (Exchange for Change)
its brand icon that will appear on every bottle, can, and return point under the scheme. They say it the “icon shows bottles and cans turning into coins, designed to be instantly recognisable in households, shops and communities, and to reflect the full range of eligible containers within the scheme.”

What we don’t have yet is any (public facing) formal guidance on how and when to apply the logo, placement and sizing, etc. However, Exchange for Change says that “in the coming weeks” this will be shared and that “Supporting producers, retailers, wholesalers and hospitality will be a key focus as we move into this next phase.”

Please get in touch with Nicola Smith if you would like to discuss further.

‘A New Vision for Water’ – Defra’s White Paper and Other January 2026 Developments

By Caroline Almond, Francesca Puttock, Cristina Vela Gonzalez and Jody Li on January 23, 2026 Posted in Environmental, Uncategorized, Water Quality, Water Rights & Resource Management

It has been a busy start to the new year for water law and policy with various developments published in the last couple of weeks. Following the release in December 2025 of the Environmental Improvement Plan (EIP), which lists a number of commitments on water, Defra published a long awaited Water White Paper this week setting out the government’s action plan for water regulation. Earlier this month, we also saw Defra release details of the mandatory annual pollution-cutting plans that water companies will be obligated to produce under the Water (Special Measures) Act 2025 (the ‘2025 Act’). On the same day, the Office for Environmental Protection (OEP) issue information notices to Defra and the Environment Agency (EA) for ‘possible failures’ under the Water Framework Directive (WFD) Regulations.

We consider these developments below.

Defra’s Water White Paper revealed – ‘A New Vision For Water’

The Water White Paper marks Defra’s intention to break with the ‘piecemeal’ and ‘disjointed’ approach of past water reforms and to focus on its ‘most critical outcomes’, i.e., delivering a safe and secure water supply, a protected and enhanced environment, and a ‘fair deal’ to customers and investors.

Omnibus I Reforms

By Begonia Filgueira on January 12, 2026 Posted in Climate Change & Sustainability

After over 12 months of legal uncertainty, the EU has finalised the Omnibus I reforms and there is certainty as to who will need to report under the EU Corporate Sustainability Directive (CSRD) and EU Corporate Sustainability Due Diligence Directive (CS3D).

To recap and in summary, CSRD required around 46,000 companies established in the EU, and non-EU entities with a large presence in the EU, to report in their annual accounts their ESG impacts and opportunities. Reporting created greater transparency but became very costly and burdensome due to uncertain obligations, information requests across global value chains and untested ESG reporting standards.

The EU AI Act and The Automotive Sector: Why Are Product Conformity Regimes Relevant to High-risk AI Systems?

By Nicola Smith, David Naylor and Bartolomé Martín on December 18, 2025 Posted in Product Safety

Introduction

From autonomous-driving to ADAS (Advanced Driver Assistance Systems), to the potential for Artificial Intelligence (AI) to transform the aftermarket, AI is much-discussed as being transformational in the automotive sector; and there are numerous reported examples of AI being used already, for design, validation and performance management, connected with the manufacturing process.

However, automotive businesses developing, supplying and/or using AI tools now, or planning to do so in future, should be aware of emerging legislation that may impose mandatory legal obligations on parties involved in the AI system “life-cycle”.