Climate regulatory compliance is becoming a high-stakes puzzle for companies across the U.S., and 2025 has already seen several pivotal developments.
California’s Greenhouse Gas Reporting Delay: Kicking the Can Forward
California’s Air Resources Board (CARB) surprised many by delaying its much-anticipated greenhouse gas (GHG) emissions reporting regulations from December 2025 to early 2026. Businesses were expecting clear rules on how to report emissions, especially about what counts as “doing business” in California and how corporate connections impact reporting responsibilities.
Instead, CARB has offered only limited guidance so far, including FAQs, draft checklists, and preliminary reporting templates. This leaves companies in limbo, needing to prepare reports without finalized instructions. To add to the pressure, statutory deadlines stay firm, meaning organizations must ready themselves amid unclear regulations—like trying to build a puzzle with some missing pieces.
New York’s Court-Ordered Push for Climate Rules
Meanwhile, across the country in New York, the state Supreme Court has stepped in to ensure climate laws don’t gather dust. The court ordered the Department of Environmental Conservation (DEC) to finalize a full suite of greenhouse gas regulations by early 2026. These rules under the Climate Leadership and Community Protection Act (CLCPA) involve performance limits, compliance protocols, and the state’s cap-and-invest program.
The judicial nudge came after delays from DEC, which had so far only issued the GHG reporting rule but stalled on other key components. Environmental advocates pushed for the court’s intervention, emphasizing the urgency of meeting New York’s ambitious emission reduction commitments.
Legal Challenges to California’s Climate Laws
On the legal front, California’s pioneering climate laws are facing fresh courtroom tests. An oil company recently sued, arguing these laws infringe on First Amendment rights—specifically targeting the Climate Corporate Data Reporting and related mandates.
While this challenge is in early stages, California courts have already rejected similar attempts to halt enforcement. CARB currently maintains that compliance timelines remain intact despite the legal wrangling, urging companies to keep preparing and submitting their emissions data. It’s a reminder that regulatory compliance often involves weathering legal storms alongside environmental goals.
Extended Producer Responsibility (EPR) Gains Ground in California
For manufacturers, California’s packaging rules under Senate Bill 54 have shifted more responsibility onto producers for the entire lifecycle of their packaging materials—from production to recycling.
By November 15, 2025, many manufacturers must submit their EPR packaging reports—a deadline that demands close collaboration with suppliers and diligent data collection. Failure to comply could mean penalties and disruptions, emphasizing the rising importance of supply chain transparency in climate compliance.
Carbon Credit Markets and the Call for Clear Regulations
Finally, climate compliance is not just about reporting but also about practical tools like carbon credits. A recent roundtable during Climate Week NYC underscored the broad consensus on needing robust, high-integrity regulations for project-based carbon credit markets.
Such regulations are key to scaling credible carbon offset projects that companies increasingly rely on to meet both voluntary and compliance-related emission targets. Experts at the roundtable highlighted interoperability—rules that work seamlessly across regions—as a crucial goal to survive political changes and keep market momentum.
What This Means for Businesses
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Uncertainty Meets Urgency: Companies face a regulatory maze with shifting timelines and evolving rules, requiring flexible strategies and early preparation.
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Legal and Political Winds: Court decisions and lawsuits create additional layers of complexity but so far have not stopped compliance demands.
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Data Is King: Accurate emissions and packaging data collection, often involving multiple suppliers, is more critical than ever.
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Planning Ahead: Waiting for final regulations isn’t an option—businesses should continue using available tools and guidance to stay on track. <brNavigating climate compliance in 2025 means balancing incomplete instructions, legal challenges, and emerging responsibilities. But with proactive effort and attention to regulatory signals, companies can turn this complex landscape into a strategic advantage rather than a compliance quagmire.
References:
- https://www.jdsupra.com/legalnews/carb-kicks-the-can-what-the-climate-2876613/
- https://natlawreview.com/article/court-requires-dec-promulgate-regulations-nys-climate-regulation-case
- https://www.velaw.com/insights/californias-climate-laws-face-yet-another-challenge-based-on-alleged-violation-of-the-first-amendment/
- https://www.assent.com/blog/compliance-alert-q4-2025-regulatory-shifts-next-steps/
- https://www.energypolicy.columbia.edu/publications/regulatory-approaches-for-projectbased-carbon-credit-markets-roundtable-summary/
- https://www.bdlaw.com/publications/regulatory-reform-in-washington-clean-energy-siting-council-releases-2025-report-recommending-reforms-to-speed-clean-energy-projects/
- https://www.nylpi.org/hudson-mohawk-magazine-caroline-chen-discusses-breaking-news-regarding-long-overdue-clcpa-regulations/