U.S.-based entities with at least $1 billion in global annual revenue that do business in California should revisit their 2026 SB 253 compliance plans following the release, by the California Air Resources Board (CARB), of 15-day modifications to its proposed regulations. The modifications provide additional time and flexibility within the first program year, allow parent companies to submit consolidated reports, and clarify how companies should assess whether they are covered.
https://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Caleb J. Bowershttps://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngCaleb J. Bowers2026-08-04 14:06:462026-08-04 14:06:46SB 253/SB 261 Update: What CARB’s 15-Day Modifications Mean for Business Compliance Plans
On July 30, on the last day of the SAE International Automated Transportation Symposium, the National Highway Traffic Safety Administration (NHTSA) released several rulemakings and announcements focused on automated driving systems (ADS). These announcements further NHTSA’s efforts to, in the agency’s words, “accelerate American automated vehicle (AV) innovation.” In remarks at the conference, NHTSA’s Administrator Jonathan Morrison indicated the agency’s approach “is one of balance, combining policy choices that enable innovation with an unapologetic exercise of our oversight and enforcement authorities.”
https://environmentalhealthsafetybrief.sidley.com/wp-content/uploads/sites/4/2025/06/AdobeStock_213612076.jpg400600Adam M. Ravivhttps://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngAdam M. Raviv2026-08-04 11:14:012026-08-04 11:14:01NHTSA Announces a Host of Actions on Autonomous Vehicles
Companies that manufacture products bearing recyclability labels have received temporary relief from impending compliance obligations. On July 14, 2026, the U.S. District Court for the Southern District of California issued a preliminary injunction preventing California, “the State,” from enforcing SB 343, the “Truth in Recycling” law, as litigation continues. The law was set to take effect on October 4, 2026, and the preliminary injunction could impact the implementation of SB 54, California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, which establishes the State’s Extended Producer Responsibility (EPR) program.
https://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Maureen F. Gorsenhttps://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngMaureen F. Gorsen2026-07-17 11:32:112026-07-17 11:32:11Court Order Blocks Enforcement of California’s SB 343 Recycling Law and Could Impact State’s Extended Producer Responsibility Program
The U.S. Fish and Wildlife Service and National Marine Fisheries Service have issued a final rule rescinding the regulatory definition of “harm” under the Endangered Species Act (ESA). The change is significant because the longstanding definition provided that prohibited “harm” could include significant habitat modification or degradation that kills or injures protected wildlife by impairing essential behavioral patterns, such as breeding, feeding, sheltering, spawning, rearing, or migrating. After the rule becomes effective, the agencies will instead apply the ESA’s statutory definition of “take” without a separate definition of “harm.”
https://environmentalhealthsafetybrief.sidley.com/wp-content/uploads/sites/4/2025/10/MN-21065-Images-for-Environmental-Blog-14-1.jpg313600Caleb J. Bowershttps://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngCaleb J. Bowers2026-07-15 13:05:272026-07-15 13:05:27Federal Agencies Rescind Endangered Species Act Definition of “Harm,” Narrowing the Scope of Prohibited Activity Affecting Wildlife
On July 7, 2026, the Department of Transportation released its 2026 unified rulemaking agenda. Many of the items on it relate to autonomous driving systems. They signal that the Trump Administration is accelerating its efforts to promote the development and deployment of autonomous technologies, while — with notable exceptions, particularly fuel economy — putting other regulatory efforts on the back burner. (more…)
https://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Adam M. Ravivhttps://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngAdam M. Raviv2026-07-09 11:57:402026-07-09 12:03:02The Department of Transportation’s 2026 Regulatory Agenda: Acceleration of Autonomous Vehicle Rulemaking and Future Action on Fuel Economy
Companies preparing to comply with California’s Senate Bill (SB) 253 and submit their first required disclosures in August 2026 have received an update this week from the California Air Resources Board (CARB) that will delay reporting deadlines. On June 24, 2026, CARB deferred the deadline for entities to report Scope 1 and Scope 2 greenhouse gas (GHG) emissions from August 10, 2026 to November 10, 2026. The three-month deferral will provide additional time for reporting entities following the anticipated approval and formal adoption of CARB’s proposed regulation. CARB will propose limited changes to the regulation to clarify requirements. These changes will be made available for comment in a forthcoming 15-day public comment period.
https://environmentalhealthsafetybrief.sidley.com/wp-content/uploads/sites/4/2026/06/AdobeStock_192168592.jpg449600Maureen F. Gorsenhttps://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngMaureen F. Gorsen2026-06-30 11:22:372026-06-30 11:22:37SB 253 Update: CARB Delays Reporting Deadline to November 2026 and Proposes to Clarify Requirements
On June 26, the National Highway Traffic Safety Administration published another proposed rulemaking designed to promote the deployment of autonomous vehicles on public roads. The proposal would amend Federal Motor Vehicle Safety Standard (FMVSS) No. 135, “Light vehicle brake systems,” by removing requirements for hand- and foot-operated brake controls in vehicles that operate without a human driver, while retaining stopping distance performance requirements. This rulemaking represents a meaningful—if still incremental—step in modernizing the federal regulatory framework for autonomous vehicles, particularly those that are manufactured without the standard equipment designed for human drivers.
https://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.png00Adam M. Ravivhttps://goodlifesci.sidley.com/wp-content/uploads/sites/6/2022/03/sidleyLogo-e1643922598198.pngAdam M. Raviv2026-06-29 16:30:332026-06-29 16:30:33NHTSA Proposes Amending Federal Brake Standards for Autonomous Vehicles
The Occupational Safety and Health Administration (OSHA) has scheduled several informal public hearings on more than 20 deregulatory rulemaking proposals that OSHA released last summer, along with a recent proposal addressing compliance deadlines under OSHA’s Walking-Working Surfaces standard. Together, these proposals reach standards that touch employers across a wide range of industries. Stakeholders who want to shape the outcome have a narrow window to act. These virtual hearings kick off beginning Wednesday, August 19, 2026, at 9:30 a.m. EST.
The proposals fit under the administration’s Executive Order 14192 on “Unleashing Prosperity Through Deregulation” and the U.S. Department of Labor’s related deregulatory initiative. OSHA describes its overarching goal as modernizing workplace safety standards, reducing compliance burdens, and increasing flexibility across industries.
SB 253/SB 261 Update: What CARB’s 15-Day Modifications Mean for Business Compliance Plans
U.S.-based entities with at least $1 billion in global annual revenue that do business in California should revisit their 2026 SB 253 compliance plans following the release, by the California Air Resources Board (CARB), of 15-day modifications to its proposed regulations. The modifications provide additional time and flexibility within the first program year, allow parent companies to submit consolidated reports, and clarify how companies should assess whether they are covered.
(more…)
Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Maureen F. Gorsen
Century City
maureen.gorsen@sidley.com
Alexandra Sirota
Century City
alexandra.sirota@sidley.com
NHTSA Announces a Host of Actions on Autonomous Vehicles
On July 30, on the last day of the SAE International Automated Transportation Symposium, the National Highway Traffic Safety Administration (NHTSA) released several rulemakings and announcements focused on automated driving systems (ADS). These announcements further NHTSA’s efforts to, in the agency’s words, “accelerate American automated vehicle (AV) innovation.” In remarks at the conference, NHTSA’s Administrator Jonathan Morrison indicated the agency’s approach “is one of balance, combining policy choices that enable innovation with an unapologetic exercise of our oversight and enforcement authorities.”
(more…)
Adam M. Raviv
Washington, D.C.
adam.raviv@sidley.com
Court Order Blocks Enforcement of California’s SB 343 Recycling Law and Could Impact State’s Extended Producer Responsibility Program
Companies that manufacture products bearing recyclability labels have received temporary relief from impending compliance obligations. On July 14, 2026, the U.S. District Court for the Southern District of California issued a preliminary injunction preventing California, “the State,” from enforcing SB 343, the “Truth in Recycling” law, as litigation continues. The law was set to take effect on October 4, 2026, and the preliminary injunction could impact the implementation of SB 54, California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, which establishes the State’s Extended Producer Responsibility (EPR) program.
Maureen F. Gorsen
Century City
maureen.gorsen@sidley.com
Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Brooklyn Hildebrandt
Los Angeles
bhildebrandt@sidley.com
Federal Agencies Rescind Endangered Species Act Definition of “Harm,” Narrowing the Scope of Prohibited Activity Affecting Wildlife
The U.S. Fish and Wildlife Service and National Marine Fisheries Service have issued a final rule rescinding the regulatory definition of “harm” under the Endangered Species Act (ESA). The change is significant because the longstanding definition provided that prohibited “harm” could include significant habitat modification or degradation that kills or injures protected wildlife by impairing essential behavioral patterns, such as breeding, feeding, sheltering, spawning, rearing, or migrating. After the rule becomes effective, the agencies will instead apply the ESA’s statutory definition of “take” without a separate definition of “harm.”
Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Peter Whitfield
Washington, D.C.
pwhitfield@sidley.com
Lauren E. DeCarlo
Chicago
lauren.decarlo@sidley.com
The Department of Transportation’s 2026 Regulatory Agenda: Acceleration of Autonomous Vehicle Rulemaking and Future Action on Fuel Economy
On July 7, 2026, the Department of Transportation released its 2026 unified rulemaking agenda. Many of the items on it relate to autonomous driving systems. They signal that the Trump Administration is accelerating its efforts to promote the development and deployment of autonomous technologies, while — with notable exceptions, particularly fuel economy — putting other regulatory efforts on the back burner. (more…)
Adam M. Raviv
Washington, D.C.
adam.raviv@sidley.com
SB 253 Update: CARB Delays Reporting Deadline to November 2026 and Proposes to Clarify Requirements
Companies preparing to comply with California’s Senate Bill (SB) 253 and submit their first required disclosures in August 2026 have received an update this week from the California Air Resources Board (CARB) that will delay reporting deadlines. On June 24, 2026, CARB deferred the deadline for entities to report Scope 1 and Scope 2 greenhouse gas (GHG) emissions from August 10, 2026 to November 10, 2026. The three-month deferral will provide additional time for reporting entities following the anticipated approval and formal adoption of CARB’s proposed regulation. CARB will propose limited changes to the regulation to clarify requirements. These changes will be made available for comment in a forthcoming 15-day public comment period.
(more…)
Maureen F. Gorsen
Century City
maureen.gorsen@sidley.com
Heather M. Palmer
Houston
hpalmer@sidley.com
Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Riley Desper
Washington, D.C.
NHTSA Proposes Amending Federal Brake Standards for Autonomous Vehicles
On June 26, the National Highway Traffic Safety Administration published another proposed rulemaking designed to promote the deployment of autonomous vehicles on public roads. The proposal would amend Federal Motor Vehicle Safety Standard (FMVSS) No. 135, “Light vehicle brake systems,” by removing requirements for hand- and foot-operated brake controls in vehicles that operate without a human driver, while retaining stopping distance performance requirements. This rulemaking represents a meaningful—if still incremental—step in modernizing the federal regulatory framework for autonomous vehicles, particularly those that are manufactured without the standard equipment designed for human drivers.
(more…)
Adam M. Raviv
Washington, D.C.
adam.raviv@sidley.com
OSHA Schedules Public Hearings on Deregulatory Proposals
The Occupational Safety and Health Administration (OSHA) has scheduled several informal public hearings on more than 20 deregulatory rulemaking proposals that OSHA released last summer, along with a recent proposal addressing compliance deadlines under OSHA’s Walking-Working Surfaces standard. Together, these proposals reach standards that touch employers across a wide range of industries. Stakeholders who want to shape the outcome have a narrow window to act. These virtual hearings kick off beginning Wednesday, August 19, 2026, at 9:30 a.m. EST.
The proposals fit under the administration’s Executive Order 14192 on “Unleashing Prosperity Through Deregulation” and the U.S. Department of Labor’s related deregulatory initiative. OSHA describes its overarching goal as modernizing workplace safety standards, reducing compliance burdens, and increasing flexibility across industries.
Alana Genderson
Washington, D.C.
alana.genderson@sidley.com
Rachel F. Wittenberg
Chicago
rachel.wittenberg@sidley.com
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