SB 253 Update: CARB Still Wrestling With Draft Regulations in March 2026
Companies preparing to comply with California’s SB 253 and submit their first required disclosures in August 2026 received additional guidance this week from the California Air Resources Board (CARB). At a public workshop on March 23, CARB outlined proposed approaches under its developing rulemaking, including options for phasing in compliance over time, and solicited public feedback on those concepts. The following article summarizes the key developments from that workshop.
NHTSA Proposes Amending Federal Crash Avoidance Standards for Autonomous Vehicles
On March 16, the National Highway Traffic Safety Administration published two proposed rulemakings designed to ease the path for manufacturing autonomous vehicles and deploying them on public roads. Both proposals would amend existing Federal Motor Vehicle Safety Standards (FMVSS) by removing requirements for certain safety equipment that may be unnecessary in vehicles without a human driver. These rulemakings represent an incremental step, not a game changer, in paving the way for a driverless future.
California’s Textile EPR Law: Key 2026 Milestones and Upcoming Producer Deadlines
California continues to expand its extended producer responsibility (EPR) framework to new product categories, capturing an ever-greater number of “producers” responsible to comply across supply chains. In September 2024, Governor Gavin Newsom signed Senate Bill (SB) 707 — the Responsible Textile Recovery Act of 2024 — establishing the first statewide EPR program for apparel and other textile products in the United States. The program is now in the implementation phase, and 2026 marks the first major compliance milestones including the selection of a Producer Responsibility Organization (PRO) and initial producer registration. The law represents another step in California’s broader push toward producer-funded product stewardship programs.
Parent Company Liability Under the Clean Air Act: Federal District Court Applies Bestfoods and Imposes $100 Million Penalty and $20 Million in Mitigation
In a February 17, 2026 decision with significant implications for corporate parents, the U.S. District Court for the Eastern District of Michigan held in United States v. EES Coke Battery, LLC that parent company DTE Energy Company and two affiliates were liable as “operators” under the Clean Air Act (CAA) for New Source Review (NSR) violations at a subsidiary’s coke battery facility. In a case of first impression, the court applied the standard for direct parent company liability established in United States v. Bestfoods to a source under the CAA. Moreover, the ruling includes a $100 million civil penalty, one of the largest CAA penalties issued by a court to a stationary source. The court ordered an additional $20 million in community mitigation, and also ordered EES Coke to obtain an NSR permit that may require the source to install costly new pollution controls.
A New Global Milestone for Autonomous Vehicles: What the UN Global Technical Regulation on Automated Driving Systems Means for Autonomy in the U.S. and Around the World
In late January, a United Nations regulatory body, the UN Economic Commission for Europe (UNECE) Working Party on Automated/Autonomous and Connected Vehicles (GRVA), approved a Global Technical Regulation on Automated Driving Systems (ADS). The draft Global Technical Regulation (GTR), which took roughly 10 years to finalize, offers a framework for signatories on how to regulate and validate autonomous vehicles, emphasizing the “safety case” approach—a structured, evidence-based argument justifying the vehicle is sufficiently safe for market introduction. Rather than prescribing a single, bright-line performance metric, the framework leaves room for jurisdictions to be somewhat flexible in how they apply the guidance to their own, country-specific legal regimes.
