In this edition of This Week in Sustainability, we unpack how the technology works, examine the evidence on both sides of the debate, and explore whether carbon capture is a vital climate tool or a dangerous distraction.

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The Basics: What is Carbon Capture?

Carbon capture refers to those technologies designed to prevent CO2 from entering the atmosphere in the first place and/or to remove it after the fact. Here is a general overview of the mainstream technologies:

Carbon capture and storage (CCS) technologies seize CO2 before it ever reaches the air. Most current projects use a liquid to chemically remove it from the smokestack, where the extracted CO2 then is compressed into a liquid-like state where it is transported typically through a pipeline to a storage site.1 At that point, it’s either stored deep underground or is transformed into things like building materials or synthetic fuel. In the case of the latter, this technology is referred to as CCUS, where the “U” stands for utilization.

Direct air capture (DAC) technologies extracts CO2 from the atmosphere. This process typically utilizes large fans that funnel air into machines to remove CO2 throughout a chemical process. But as the concentration of the gas in the air is about 300x less than in a smokestack, is a much more difficult and time-intensive process.2

Other removal methods exist like using bioenergy with CCS (BECCS). In this process, biomass (think of wood or plants) removes CO2 through photosynthesis, where the biomass is later harvested and burned for energy in a power plant that captures and stores CO2.3

There are plenty of different ways that CCS is being utilized, and more research is still being done to discover the full extent of its potential.

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The Case For Carbon Capture: Pragmatism and the Math of Net-Zero

Proponents of carbon capture argue that we simply cannot reach our decarbonization targets without it.

Organizations like the International Energy Agency (IEA) and the Center for Climate and Energy Solutions (C2ES) argue that while transitioning to wind, solar, and battery storage is the primary goal, renewable energy alone cannot decarbonize every sector of the economy alone.

The primary argument for CCS rests on “hard-to-abate” sectors like cement and steel production. These two industries alone account for nearly 15% of all global CO2 emissions.4 The chemical reactions required to make these foundational materials inherently release carbon dioxide, regardless of whether the factory is powered by a coal plant or a massive solar farm. For these industries, capturing the carbon at the source is currently one of the only viable pathways to zero emissions.

Furthermore, climate models from the Intergovernmental Panel on Climate Change (IPCC) and the IEA consistently show that hitting the Paris Agreement targets requires a significant scale-up of carbon capture.5 The argument here considers the vastness of the carbon that we’ve released into the atmosphere over the last century, merely cutting future emissions won’t be enough without the support of removing historical emissions.

From a pragmatic lens, carbon capture is more of a safety net to catch the emissions that the clean energy transition cannot yet reach than a replacement for renewables. It can be thought of as one of many tools used to combat the climate crisis rather than a single solution.

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The Case Against Carbon Capture: A Dangerous Distraction

Yet there is another side to mainstream conversation on carbon capture, where environmental watchdogs and climate justice advocates are very skeptical about the recent push for these technologies. Their perspective sees carbon capture as a false solution heavily promoted by the fossil fuel industry to justify continuing on with business as usual.

A core basis of this argument is rooted in the historical use-cases of captured carbon from CCS. For decades, a primary use of captured carbon has been for a process known as enhanced oil recovery (EOR).6 To illustrate, about 70% of the captured carbon in Canadian facilities is directed to EOR to extract more hard-to-reach oil from aging reservoirs and extend their life by decades.7 The paradox is glaring: we are spending billions of dollars to capture carbon, only to use that carbon to extract more oil, which will then be burned to create more carbon.

Beyond that paradox, skeptics also argue that CCS is unproven and economically disastrous. Despite decades of research and development, many flagship carbon capture projects have failed to meet their capture targets. A study by the Institute for Energy Economics and Financial Analysis (IEEFA) reviewed 13 global carbon capture projects, which amounts to about 55% of worldwide operational capacity. What they found was that only two projects could be called successful in the gas processing industry, (both in Norway), seven underperformed, and the power sector has yet to have any successful projects.8

From an economic perspective, many scholars argue that CCS makes little sense.9 Research out of Oxford estimates that a low-CCS pathway to net-zero by 2050 is expected to save at least $1 trillion when compared to a high-CCS route.10 The study argues that this is likely an underestimation as it supposes the low-end of the cost ranges estimated in literature, and doesn’t account for things like underperformance of CO2 capture or the cost of upstream methane emissions from mining and extraction associated with CCS. It also points out that over a span of 40 years, there haven’t been any reductions in the cost estimations associated with CCS.11

There are also considerable environmental justice concerns. The transportation of highly pressurized CO2 requires expansive pipeline networks run are overwhelmingly routed through low-income and marginalized communities.12 If a CO2 pipeline ruptures, as one did in Satartia, Mississippi, in 2020, it releases an asphyxiating cloud that displaces oxygen and stalls combustion engines, preventing emergency vehicles from responding effectively.13

For these advocates, investing in carbon capture provides a social license for oil and gas companies to keep polluting under the guise of future technological fixes, delaying the inevitable phase-out of fossil fuels. Why, critics ask, should taxpayers subsidize a technology with a spotty track record when that same money could be deployed to build proven, cheap renewable energy infrastructure like wind and solar?

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The Core Tension: Technology vs. Systemic Change

The debate over carbon capture ultimately exposes a deeper philosophical divide within the sustainability movement as a whole: the tension between technological innovation and systemic change.

Almost nobody seriously argues CCS should replace renewables for electricity generation. And almost nobody argues industrial sectors like cement and steel have a clear non-CCS decarbonization path today.

If we lean entirely into technological fixes like CCS, we risk falling victim to “moral hazard.” This is the idea that the promise of a future technological miracle reduces our incentive to make difficult behavioral and systemic changes today. If we believe we can just pull CO2 straight out of the sky and all will be well, what would that do to the political will to shut down a coal plant, or rethink our current economic models, or resign our cities to be more pedestrian and public transport oriented?

However, insisting only on systemic change carries its own risks. Rebuilding the entire global economic and energy system takes time and will. Based on the current state of things, it’s clear we don’t have enough of either. Dismissing technological innovations out of ideological purity could mean allowing heavy industries to spew unchecked emissions into the atmosphere for the next three decades while we wait for perfect green alternatives to arrive.

Can we have both? Can we scale up carbon capture for the industries that truly need it, without letting it become a crutch for those that don’t? What a tricky question. What do you think?

Finding the Balance: Looking Ahead

Carbon capture at the end of the day is neither a silver bullet nor necessarily pure greenwash. It’s an innovative technology with a legitimate, though narrow, role. For industries like cement and steel, it could provide the time needed to develop greener processing and production methods, but it should not be taken for granted and used as an excuse to continue with business as usual.

The more useful question for sustainability professionals probably isn’t “is carbon capture good or bad,” but “good or bad for what, exactly, and are the incentives around it pointed at systemic change or at buying fossil infrastructure more time?”

It’s important to look at emerging “green” technologies through a critical lens. CCS technology has a role to play in addressing emissions from sectors where no other solutions exist, but it must be developed responsibly, at scale, and without crowding out more immediate and effective climate actions. The real risk is not that CCS will fail, but that it will be used as an excuse to avoid the hard work of systemic change.

As the debate rages on, one thing is clear: The clock is ticking. Whether carbon capture becomes a meaningful part of the solution or a costly distraction depends on how we balance its potential with the urgency of the climate crisis.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

What differences would that make to business-as-usual? How would that impact outcomes? How might we all benefit from Nature’s collective interest?

For some, this may be a hard concept to grasp. It may feel intangible, unrealistic, or all-together impossible. But, with a little reimagination of business norms and clever legal innovation, a movement to put Nature on the company board has been gaining momentum worldwide.

This week’s Brightest newsletter will break down what this means in practice, what legal instruments can be used, and the impact that this recognition of the Rights of Nature could have on our planet.

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What Does Nature on the Board Mean?

The concept of putting Nature on the Board (NOTB) of a company is the active reimagination of the corporate governance structure. This reimagination comes at a time where our world’s natural resources, biodiversity, and climate stability is under imminent threat.

This is not a metaphor; the idea of NOTB of a company means literally that. This can be done via a formal representative that represents Nature’s rights, interests, and decision-making capacities. The goal here is to incorporate Nature’s interests into standard business practice in corporate settings, so the environmental impacts of conducting business are systematically considered.1

As businesses can be as powerful as nations themselves, the corporate governance structures that they follow have just as much, and in some cases more, effect on the planet than laws do. Such corporate governance structures have long prioritized shareholder profit over all else, especially the environment. This comes as no surprise. Shareholder profit dominates business-interests, we all know that. Many businesses claim to prioritize sustainability, and while it’s trendy for an organization to be ‘green’, it often lacks substance. When a business actually puts Nature on its board, there is a legal obligation to consider the environment in decision-making. That accountability mechanism is a substantial shift, and it is not made at the cost of profit or other traditional gains. It rather is aimed to promote a win-win scenario for business and planet alike moving forward.

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The Broader Context of the Rights of Nature

Using NOTB as a way to safeguard Nature’s interests falls into the broader Rights of Nature movement, also referred to as Earth Jurisprudence, Eco-Jurisprudence, and Earth Law.

Rights of Nature is the philosophical shift of our legal and governance systems from being anthropocentric, or human-centered, to ecocentric, or Nature-centered, encompassing all life on the planet. It acknowledges all life on Earth as sacred and worthy of rights in the context of a current system that prioritizes humans over all other species of plants and animals to a fault.

In practice, the Rights of Nature movement advocates for the extension of legal rights to Nature, whether that be a specific ecosystem, species, or area as a whole. This is done through legal representation, whether that is direct (a specific person or group is appointed) or indirect (those within a given jurisdiction are all empowered to raise a claim on Nature’s behalf).

This extension of legal rights is already seen all over our legal systems, with examples ranging from businesses and corporations, to trusts, to ships. Representation is also a common tactic, take minors or those mentally handicapped, for instance. The novelty here in modern society is extending these legal rights to Nature and natural objects, though indigenous people have long understood this concept.

Some may confuse this concept, Earth law, with environmental law. However, they follow quite distinctly in their approach to the law. Simply explained, environmental law regulates how the environment may be exploited; Earth law is the idea that the environment should be granted a legal personality so that its rights can be enforced.

As vague as that may sound to someone who is only hearing of this concept for the first time, there have been various successes over the past decade. The Eco-Jurisprudence monitor has recorded 701 initiatives across 67 countries to date.2

Some notable cases of Nature being granted legal rights include:

→ 2008: Ecuador’s Constitution is amended to include the Rights of Nature, enforceable across the entire country (Article 71). This is the first case of the Rights of Nature in a national constitution.3

→ 2022: Panama passed a national Right of Nature law, including a “in dubio pro natura” clause, which translates to “In doubt, in favor of Nature”.4

→ 2024: Spain’s Mar Menor Act granted legal rights to the Mar Menor Lagoon and its basin (19/22). This is the first national law in Europe that recognizes the rights of an ecosystem.5

“Over the last decade, Earth Jurisprudence can be seen as the fastest growing legal movement of the twenty-first century”

- António Guterres, Secretary General of the UN6

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Legal Pathways to Nature on the Board

The most direct way to structurally embed Nature into corporate governance is to appoint a formal legal “Nature proxy” to represent Nature on the board of directors. This entails designating a carefully chosen human representative, who can be anyone with the right interests and background; some strong candidates might be an Earth law practitioner, a Indigenous ecological knowledge holder, scientists, and/or community members.7 The Nature proxy role comes with specific duties and fiduciary responsibilities to truly represent the interests of the natural environment when company decisions are being considered and made.8

This method has been tried and tested by several companies, with the first one putting Nature on the board being Faith in Nature. Faith in Nature is a UK-based household and beauty product brand that worked with the Earth Law Center and Lawyers for Nature to give Nature a seat on its board of directors via a representative (also referred to as a Guardian) with the support of a committee of environmental experts to be consulted or delegated responsibilities when necessary. To do this, Nature was given the right to vote as a director on the Board and two amendments to its Articles of Association were made:

1. Obligation “to have a positive impact on Nature as a whole and to minimise the prospect of any harmful impact of the business and operations on Nature” included into the objects clause

2. The board was given authority to designate a Non-Executive Director to serve as Nature’s representative and assign authority to one or more guardians to act in Nature’s best interests

Faith in Nature made this official in 2022, and have since become an active voice in the advocacy for other companies to follow suit in including Nature’s voice in the business discussion. Other examples of companies that have made similar moves are Patagonia, who made Nature their sole shareholder back in 2022, and Tony’s Chocolonely, who used a method of granting a “golden share” (a non-economic stake) to the independent foundation “Tony’s Mission Lock” that has the explicit task to uphold the ethical mission of the company.9

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Another pathway is to recognize the Rights of Nature in corporate documents. This is done by amending documents like the bylaws, operating agreements, and/or corporate charters to reflect the organization’s commitment to respecting and protecting Nature that is impacted by its existence. Enforceable legal obligations are not always established through this method, yet including these references in corporate documents sets a foundation and guideline nonetheless.10

Furthermore, an organization may opt for alternative pathways less intrusive on company structure, though less effective, like the routine use of Ecological Impact Assessments (EIA) or education.11 These techniques are best used alongside more legally binding approaches rather than standalone. EIA’s work to identify, evaluate, and manage those ecological risks that are associated with the conducting of business activities, and are crucial to understand the impact of a company’s operations. Education via training, guidance, and facilitation work to embed the cultural and philosophical shift necessary to truly drive effective shifts to include Nature’s vice in corporate governance.

Looking Ahead

Legal innovation is a powerful mechanism to fight the climate crisis and reflect the due respect for the environment as we advance as a society. By combining legal tools that already exist and reimagining how we allocate rights across our systems, powerful and enforceable change can be made.

Earth law, and the Rights of Nature movement, including mechanisms like NOTB, has immense potential to transform our legal systems’ ability to protect the Earth. Language is powerful, and it determines the way we see and interpret obligations in a rights-based system. Where we can see the intrinsic and unbreakable relationship between humans and the Earth, our legal system should reflect this understanding through extending rights the same way rights have been extended to inanimate objects like corporations and trusts. Even where something is complicated, or feels new or even uncomfortable, novelty must start somewhere; precedents must be set; foundations must be established.

Regulations and standards are powerful mechanisms to hold companies to new standards, but governments alone are not enough to drive the magnitude of change necessary to combat climate change. We need to see companies themselves taking voluntary action to hold themselves to higher standards, and putting Nature on the board is a compelling movement in this space. It will be interesting to keep an eye out for more innovative ways that companies can take this sort of initiative upon themselves, as the possibilities are truly endless!

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

We’ve all heard or felt this sentiment in recent years as products seem to be breaking faster or becoming increasingly expensive to maintain. This reality has led to the rise of a global movement based on a simple yet transformative concept: the Right to Repair.

This week’s newsletter provides a baseline overview of the Right to Repair: what it entails, why it is important, the current state of global legislation, and the implications it holds for consumers and businesses as we navigate the path towards the circular economy.

What is the Right to Repair?

The right to repair is the legal principle that owners of a piece of equipment should be able to repair, upgrade, or modify that equipment on their own, rather than being forced to rely on the manufacturer to fix it or having to buy a replacement.1 In practice, this means access to spare parts, repair manuals, diagnostic software, and tools on fair terms that actually enable individuals to repair their equipment.

The concept of the right to repair is gaining relevance for consumers as specialized equipment, from every-day electronics to industrial machinery, are becoming increasingly complicated to repair for a number of reasons. This ranges from complications surrounding access to the necessary materials or critical information about the product needed for its repair, to a limited number of service providers, to excessive pricing that makes it more economical to buy a new product altogether.

Compounded by the phenomenon of planned obsolescence, the method of designing products to be intentionally short-lived so that consumers will buy new products more frequently, the Right to Repair movement has been gaining traction globally as consumers demand more transparent and fair behavior from manufacturers.2 This is both in response to the hefty economical and environmental impact that such short-lived products have on consumers’ wallets and the impacts of excessive resource use.

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Why is it important?

From a sustainability perspective, the Right to Repair is an indispensable mechanism for combating the e-waste crisis and the impacts that excessive resource extraction has on our planet.

E-waste is among the fastest growing waste streams in the world. If we continue at the same rate we’re at now, it is forecasted that we will generate 82 million metric tons of e-waste in 2030.3

As consumers are driven to discard devices prematurely, the already immense environmental toll of extracting raw materials like lithium or cobalt is compounded. Where the vast majority of the carbon footprint of a smartphone or laptop comes from its manufacturing, the extension of the device’s lifespan from two to four years, for example, can meaningfully decrease its ecological footprint.4

Yet several of the stated difficulties surrounding repairs amidst the phenomenon of planned obsolescence largely takes this choice away from consumers.

Beyond environmental stewardship, the Right to Repair has significant economic and social implications. It empowers consumers by lowering the cost of ownership and freeing them from manufacturer-controlled repair monopolies that incentivize buying a new product over fixing an old one. Furthermore, it fosters local economic resilience by supporting small, independent repair businesses, creating local jobs, and closing the digital divide by keeping essential technology functional and affordable for a longer period.

For sustainability teams, right to repair increasingly intersects with circular economy strategy, product durability disclosures, and Ecodesign compliance.

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The State of the Right to Repair

The legislative landscape for the Right to Repair is evolving rapidly, moving from grassroots advocacy to codified law predominately across the European Union and the United States.

The European Union

The EU has developed the most comprehensive framework on the Right to Repair to date with the Right to Repair Directive (EU 2024/1799).

Having just come into application on July 31st 2026, it aims to promote “more sustainable consumption by increasing repair both with and outside the legal guarantee”.5 A number of measures have been introduced to promote repair.

The Directive obliges manufacturers of products listed in Annex II (currently including washing machines, dishwashers, fridges, TVs, smartphones, tablets, servers, e-bikes and welders) to repair those goods within a reasonable time and at a reasonable price. It also introduced a ban to any contractual or software barriers to repair unless there is an objective justification. Manufacturers are also required to provide information on repair services and their prices to consumers in an easily accessible manner.

Consumers who choose repair over replacement during the legal guarantee period get an extra 12 months of coverage, and a new European Repair Platform is meant to help people find registered repairers.6 The Directive sits alongside and depends on the separate Ecodesign framework, which sets the actual repairability requirements (spare parts, disassembly, software support) product category by product category.

This framework comes with its own limits, however. Right to Repair Europe, the advocacy coalition that pushed for the Directive, points out that coverage is still narrow: full protection currently applies to only a handful of product groups, with categories like laptops, vacuum cleaners and garden tools not yet covered by comparable obligations.7 It also flags that, as of the 31 July 2026 application date, only a handful of member states had formally notified the Commission of complete transposition, meaning the practical strength of the “right to repair” still depends heavily on where in the EU a consumer lives.

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The United States

In the US, the Right to Repair has progressed through a patchwork of state-level victories and targeted federal actions, championed by advocacy groups like US PIRG (Public Interest Research Group). While a comprehensive federal Right to Repair act remains elusive, the Federal Trade Commission (FTC) has ramped up enforcement against illegal warranty-voiding practices.

At the state level, momentum is undeniable. California’s Right to Repair Act (SB 244), effective as of 2024, requires manufacturers of electronics and appliances to supply parts, tools and documentation for up to seven years.8

Right to Repair bills in Oregon (effective March 2024) and Colorado (effective January 2026) goes further, banning “parts pairing”, referring to software-locking replacement parts to a specific device.9 Colorado has passed three separate laws on the topic, including for wheelchairs, agricultural equipment, and, with the January 2026 law being considered the strongest in the country.10

These laws, among others in states like New York and Minnesota, are creating a de facto national standard, as manufacturers find it logistically simpler to apply these compliance standards nationwide.

Other Jurisdictions

Other regions are making incremental progress but still lack comprehensive frameworks.

The United Kingdom has required repair-information access for vehicles since 2015 as a part of the Consumer Rights Act, and added Ecodesign-style spare-parts rules for certain appliances in 2021, though its regime is narrower than the EU’s post-2026 framework.11

In Australia, the Productivity Commission has explored frameworks, and there is an ongoing push for national legislation. The Right to Repair is limited to a mandatory vehicle-data-sharing scheme, actively enforced by its competition regulator, to make repairs more affordable and available.12

India has a Right to Repair portal and a government committee developing a national framework, covering: farming equipment, mobile and electronic products, consumer durables, and automobiles.13

Other countries have tried unsuccessfully to pass such legislation.

Brazil, for example, introduced a Right to Repair Bill in 2024 that included prohibiting planned obsolescence and protecting consumers’ access to parts, tools, and information, but it failed to go anywhere.14 New Zealand also recently introduced a Right to Repair bill that was ultimately withdrawn.15

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What This Means for Consumers

For consumers, legal protections for the Right to Repair represent an important shift: the right to request repair over replacement, an extended guarantee for choosing repair, clearer pricing, and easier access to independent repairers. This shift gives power back to the consumer to make their own decisions rather than being fully at the whim of the manufacturer.

As the Right to Repair expands in scope, consumers will benefit from greater choice and competition in the repair market, driving down maintenance costs. Initiatives like the EU’s standardized repair information forms and mandatory repairability indices (already seen in countries like France) will empower buyers to make informed purchasing decisions based on the expected longevity of a product. Ultimately, this means keeping devices longer, spending less money on forced upgrades, and participating in the transition to the circular economy.

What this means for businesses

For manufacturers and retailers, compliance with Right to Repair rules is becoming multi-jurisdictional.

Businesses in the scope of the EU directive will need to check which products fall under Annex II or the relevant Ecodesign regulation, review contractual and software practices that could count as repair barriers, and prepare for spare-parts pricing transparency.

US-facing businesses need a state-by-state view, since thresholds, exemptions and anti-parts-pairing rules vary widely.

More broadly, reparability is becoming a durability and circularity metric that sustainability and compliance teams should expect to see folded into product disclosure and ESG reporting, rather than treated as a standalone legal question. The shift is happening for the better, and businesses should embrace it rather than fight back through loopholes or other legal mechanisms.

Looking Ahead

As we look toward the end of the 2020s, the Right to Repair is transitioning from a legislative battleground to an implementation phase. The primary focus for sustainability professionals and policymakers over the next few years will center on three key areas:

Enforcement and Compliance: The true test of laws like the EU’s directive and California’s SB 244 will be enforcement. Regulators must ensure that spare part prices remain “fair and reasonable” and that OEMs do not exploit loopholes to technically comply while practically discouraging repair.

The Battle Over Software: As physical barriers fall, software locks (cryptographic parts pairing) remain an uncertainty. Ensuring that cybersecurity laws are not weaponized to prevent repair will be a critical legal challenge.

Expansion of Scope: Future legislative pushes will likely expand Right to Repair mandates beyond consumer electronics and white goods into more complex categories, including medical devices, commercial electric vehicles, and renewable energy infrastructure like solar inverters.

The Right to Repair is more than a consumer protection issue; it is a vital prerequisite for a circular economy. By democratizing maintenance, we can begin to decouple economic prosperity from resource extraction, ensuring the products we rely on serve us longer and leave a lighter footprint on the planet.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

The fashion industry has long relied on the open secret that where supply exceeds demand, surplus is destroyed. This is done through techniques like incineration and landfilling in efforts to protect brand equity and avoid storage costs. But as of this week, that era is over for those in the European Union.

From 19 July 2026 onwards, large companies operating in the EU are prohibited from destroying unsold clothing, clothing accessories and footwear, with medium-sized companies following in 2030.1 It is the first product-specific rule to take effect under the much broader Ecodesign for Sustainable Products Regulation (ESPR), and it comes bundled with disclosure obligations that will make destruction practices visible to regulators and, eventually, the public.

This week’s newsletter will break down why this ban was enacted, what it covers, and what businesses in scope need to know going forward.

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Why is this important?

The sheer amount of waste in the fashion industry is shocking. Despite this being an open-secret, few understand the true scale of this waste and how it can be avoided altogether.

According to the European Environment Agency, approximately 4-9% of textiles put on the European market are destroyed before ever being used, and 264,000 to 594,000 tones of textiles are destroyed annually.2 The average return rate for items purchased online is about 1 in 5 (about 3x higher than in-store purchases), and an average of 1 out of 3 returned clothing items from online retailers are destroyed.3 Data on unsold textiles is less clear, but research points to about 1 out of 5 items of unsold clothing being destroyed.4

When new, usable goods are discarded, the raw materials, water, energy and labour invested in their production are lost, while their disposal generates avoidable greenhouse gas emissions. By encouraging reuse, repair and more resource-efficient business practices, the new rules support the transition to a more circular and competitive European economy.

- EU Commission Directorate-General for Environment5

For businesses, the shift is as much reputational and financial as it is regulatory. Destruction has historically been treated as a private operational decision, up to the discretion of the company. But under the new rules, it becomes something regulators can inspect, businesses must justify in writing, and increasingly something the public can see through annual disclosures.

What Does the Ban Cover?

In simple terms, the ban in effect from July 19th, 2026 makes it illegal for large companies operating in the EU to destroy or discard their unsold clothing, clothing accessories and footwear, with its legal basis lying in the ESPR. From July 19th, 2030 onwards, this ban will extend to medium-sized companies. Micro and small businesses are exempt from both the ban and its reporting requirements.

EU law defines a large company as one that has more than 250 employees and an annual net turnover of over €50 million.6 If you fall into this category, you must start complying now.

EU law defines a medium-company as one that has 50 to 249 employees, with a turnover above €10 million and up to €50 million.7 If you fall into this category, you must be compliant starting July 19th, 2030.

The ESPR entered into force in 2024 as a part of the 2020 Circular Economy Action Plan, and gives the European Commission power to set product-specific requirements on durability, repairability, recyclability and resource use.8 Textiles are the first product category to get a destruction ban under this framework, chosen because of how frequently unsold apparel and footwear are discarded rather than resold or reused. The ban transforms inventory mismanagement from a financial write-off into a direct compliance liability.

Annex VII of the ESPR gives a detailed outline of the products within scope of the July 19th ban.

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Exemptions to the Ban

There are limited scenarios that allow a company to destroy unsold clothing and shoes, outlined in Article 25(5). These include:9

• Health, hygiene, and safety reasons

• Damage caused to products as a result of their handling, or detected after products have been returned, which cannot be repaired in a cost-effective manner

• Unfitness of products for the purpose for which they are intended, taking into account, where applicable, Union and national law and technical standards

• Non-acceptance of products offered for donation

• Unsuitability of products for preparing for reuse or manufacturing

• Unsaleability of products due to infringement of intellectual property rights, including counterfeit products

• Destruction is the option with the least negative environmental impact

Companies relying on an exemption must retain proof, such as inspection records or test results, and file annual disclosures covering the volume of products discarded, the reason for discarding them, and any measures taken to prevent destruction going forward.

What are the Compliance Obligations?

Chapter VI of the ESPR gives an outline of the compliance obligations of the destruction of unsold consumer products.

Foremost, there is a general principle of the prevention of destruction, meaning there must be measures taken that can be reasonably expected to prevent the need to destroy such unsold products in the first place.

Companies in scope who have destroyed such consumer products (directly or indirectly) are also required to disclose:10

• The number and weight of these unsold products annually, categorized by product type

• The reasons for discarding the products, and if applicable, the relevant derogation under Article 25(5)

• The rate of products delivered (directly or indirectly) to undergo each of the following: preparing for reuse, including refurbishment, recycling, other recovery like energy recovery, and disposal operations in accordance with waste hierarchy (defined by Article 4 of Directive 2008/98/EC)

Starting July 19th, 2027, the Commission will publish a report on the state of destruction of unsold consumer products every 36 months based on these disclosures, highlighting the prevalence of specific groups of unsold consumer products being destroyed and their comparative environmental impacts.

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What this Means for Companies

The core shift is that destruction moves from a private, discretionary write-off to a documented compliance obligation with a paper trail. Companies that could once quietly incinerate excess stock at season’s end now need a policy for preventing that outcome in the first place, and a file ready to justify any exception.

Large companies (250+ employees, turnover above €50 million) are already in scope. If destruction has ever been part of your inventory strategy, even occasionally, you must act now. You need prevention measures in place, documentation for any Article 25(5) exemption you rely on, and a system for tracking the annual disclosure data: volume, weight, product type, reason for discarding, and the share routed to reuse, recycling, recovery or disposal.

Medium-sized companies (50–249 employees, turnover between €10 million and €50 million) have until 19 July 2030. That timeline shouldn’t mean waiting. Building the tracking infrastructure, supplier agreements and donation partnerships now costs less than retrofitting them under deadline pressure later.

Micro and small businesses remain exempt from the ban and its reporting duties. But exemption from the letter of the law isn’t exemption from the market pressure it creates. Retail partners, marketplaces and larger supply chain counterparts are likely to start asking smaller vendors for the same visibility, informally, well before any legal requirement arrives.

The bigger change is in the range of options companies now have to actively choose between, rather than defaulting to disposal:

• Reselling through outlet channels, discount markets or resale platforms

• Donating to charities or social enterprises, with the requirement to show the donation was genuinely offered and declined

• Preparing for reuse through repair, refurbishment or remanufacturing

• Recycling, including fibre-to-fibre recycling, when reuse isn’t feasible

• Destruction, only where an Article 25(5) exemption applies and can be evidenced

Prevention is the strongest strategy of them all. The ESPR’s general principle isn’t “destroy responsibly,” it’s “don’t generate the surplus you’d need to destroy.” That pushes the conversation upstream, into forecasting, buying and production planning, rather than treating this as a waste-management problem to solve at the end of the line.

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Looking Ahead

Two things are worth watching beyond the dates themselves.

First, textiles are the first type of many consumer products to be targeted. The ESPR was built to be extended product by product, and the Commission has signalled more categories are coming. Whatever processes get built for apparel and footwear will likely need to flex to cover other product groups in the next few years.

Second, the 36-month reporting cycle means destruction data stops being internal. Once the Commission starts publishing sector-wide figures, individual company disclosures become the raw material for public comparison, and eventually, for the kind of naming that changes how a brand is talked about. This is an important shift that companies will want to stay on top of.

How Brightest Can Help

Tracking prevention measures, exemption documentation and annual disclosure data across product lines is exactly the kind of fragmented reporting work that gets messy fast. Brightest centralizes that evidence trail, so when the Commission’s next report cycle comes around, you’re pulling from one system rather than reconstructing the story from spreadsheets. Want to chat? Reach out to our reporting experts today.

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But as the world’s most-watched sporting event packs up its gear, a different kind of post-game analysis is taking place. This one isn’t about football strategy or penalty shootouts. It’s about carbon.

A fascinating new study from the University of Cambridge, published in Nature, exposed the true climate cost of global mega-events. It turns out that the 2026 World Cup is the ultimate, real-world case study in the modern corporate sustainability dilemma: the agonizing frustration of Scope 3 emissions.2

Whether you’re running a global supply chain, a tech startup, or the world’s largest sporting event, the lessons from this year’s World Cup are incredibly relevant. Here is a look at what FIFA got right, where they failed spectacularly, and how the path forward requires borrowing a page not from other sports leagues, but from pop superstars.

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The Green Illusion: Winning on Scope 1 and 2

In some ways, the 2026 FIFA World Cup organizers did an impressive job with the physical infrastructure of the tournament.

Mega-events like the World Cup and the Olympics have been notorious for building “white elephants” to host their events in the past. These are massive, multi-billion-dollar stadiums constructed for the use of a single competition, often left to sit empty and decaying for decades thereafter.3 This time around, FIFA and the host nations took a different route as all of the matches were played in pre-existing, state-of-the-art stadiums.

The majority of these stadiums are LEED-certified, featuring over 11,500 solar panels across stadiums capable of powering the entire matchday experience.4 Some venues implemented their own green initiatives to optimize water usage, source food from local vendors, and recycle and compost through waste sorting where possible.5

In the language of corporate sustainability, FIFA virtually perfected its Scope 1 (direct emissions from owned or controlled sources) and Scope 2 (indirect emissions from the generation of purchased energy) emissions. If you only looked at the stadiums themselves, the 2026 World Cup was an example of climate-conscious event planning.

Yet, the New Weather Institute, alongside the Scientists for Global Responsibility, the Environmental Defense Fund, and Cool Down, predicted that the 2026 World Cup will be the most polluting one ever, emitting approximately 9.02 million tCO2e, more than double the historical average.6 And the reason is clear: air travel.

The 97% Reality

The Cambridge University research shows that a staggering 97% of the total carbon footprint of the 2026 World Cup came entirely from fan travel.

When you zoom out, the logistics of this tournament were a climate nightmare. By hosting the event across three of the largest countries on Earth, FIFA created a geographic web that practically forced fans to fly. A fan following their team might have had to fly from Vancouver to Mexico City, and then up to Miami, all within a span of two weeks. Add in the millions of fans flying in from Europe, South America, Asia, Africa, and Australia, and the carbon emitted by the physical stadiums becomes miniscule compared to the millions of metric tons of jet fuel burned to get the fans to the venues.

This is the ultimate embodiment of Scope 3 emissions, those emissions that you are indirectly responsible for up and down your value chain. For most companies, Scope 3 accounts for 70% to 90% of their total carbon footprint. For the 2026 FIFA World Cup, it was 97%.7

This is the agonizing frustration of sustainability. It proves that cleaning up your own house is no longer enough if your business model inherently forces your guests to track mud everywhere.

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FIFA’s Climate Blind Spot: A Call for Accountability

This brings us to a broader, more critical problem: FIFA’s continued lack of accountability.

While the Cambridge study provides the stark data, environmental watchdogs like the New Weather Institute have been sounding the alarm for years regarding FIFA’s “climate blind spot.” Historically, FIFA has relied on highly controversial carbon offset programs to claim their tournaments are “carbon neutral.”8 But as the 2026 tournament proves, you cannot offset your way out of a fundamentally high-carbon business model.

By choosing a continent-wide format, FIFA played an active role in designing this massive Scope-3 carbon footprint. Because of this design, they cannot simply place the blame on fans for flying. If their team is playing in Los Angeles one week and Kansas City the next, how else are fans supposed to traverse the 2,605 kilometers in a country without a well-connected railway? When a corporation designs a product or an event that requires massive emissions to consume or attend, they own a share of that environmental cost.

It is far overdue for FIFA to take accountability for all of their carbon emissions. Sustainability can no longer be a mere PR exercise for stadium operations, especially not for the largest sporting event in the world put on by a mutli-billion dollar company. Sustainability and accountability must become embedded into the foundational design of the tournament, touching upon all relevant aspects.

Important questions need to be asked ahead of such mega-events: How can the tournament be regionally organized to avoid excess air travel? How can scheduling be optimized to prevent teams and fans from bouncing across time zones? These are the hard questions FIFA avoided in 2026. For future events like this, accountability must mean taking ownership of Scope 3 emissions.

The Coldplay Playbook: Gamifying Green Travel

So, how do we address this? How do you maintain the global, unifying magic of a mega-event while dramatically decreasing the Scope 3 emissions of fan travel?

The University of Cambridge researchers didn’t just point out the problem; they offered a roadmap, suggesting that FIFA and other sports leagues need to look to the music industry for inspiration.

Over the last few years, bands like Coldplay have fundamentally rewritten the rules of sustainability for tours. During their massive Music of the Spheres world tour, Coldplay realized that, much like FIFA, their biggest climate impact was fan travel.

Instead of ignoring the reality of their tour’s environmental impact, they tackled it head-on. Coldplay partnered with transit authorities and created a dedicated app that allowed fans to track their journey to the concert.9 If fans proved they took public transit, carpooled, or rode bikes to the venue, they were rewarded. The band offered exclusive merchandise discounts, VIP upgrades, and special access codes to those who chose green travel. They essentially gamified sustainability, turning a logistical headache into an engaging, rewarding experience for their community.

The Cambridge study suggests FIFA must adopt this model.10 Imagine a World Cup where your match ticket is heavily discounted if you bundle it with a train pass. Imagine an official FIFA app where fans log their low-carbon travel to earn exclusive access to player meet-and-greets, limited-edition jerseys, or priority access to future ticket lotteries.

FIFA generates billions of dollars in revenue and possesses a massive, global digital ecosystem. They have the resources to subsidize green travel and incentivize their fans. If a pop band can successfully shift the travel habits of millions of fans, the most powerful sporting body in the world can certainly do the same.

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The Bottom Line: Takeaways for Every Leader

You don’t have to be organizing a global sporting event to learn from the 2026 World Cup. The tension between FIFA’s green stadiums and the massive carbon footprint of fan travel offers crucial lessons for any organization navigating the transition to a sustainable future:

Scope 1 and 2 are Just the Beginning: Making your internal operations green (like FIFA’s stadiums) is highly commendable and entirely necessary, but it is no longer the finish line.

Scope 3 Must be Addressed: Your biggest environmental impact is likely outside your direct control. How your suppliers operate and how your customers use your product dictates your true footprint. You must measure it, acknowledge it, and actively work to reduce it.

Design Determines Impact: You cannot build a fundamentally high-carbon business model and try to offset it later. FIFA’s continent-spanning format guaranteed a massive carbon footprint. True sustainability must be factored into the foundational design of your products, services, and operations.

Gamify and Incentivize: You can’t force your customers to be perfectly green, but you can heavily incentivize them. Borrowing from Coldplay’s playbook, use discounts, rewards, and gamification to nudge your community’s behavior in a sustainable direction.

The 2026 World Cup gave us an incredible month of football, culminating a historic victory for Spain. Many felt a sense of unity with others around the world, all watching this tournament from different countries. But it also left us with massive emissions that our planet cannot afford. It is time for organizations like FIFA to stop hiding behind the green facade of their climate goals and start taking real accountability for their immense environmental impact.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

From beavers fixing city infrastructure to a massive boom in baby whales, here are five positive sustainability stories from recent months guaranteed to put a smile on your face.

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1. A Spectacular Whale Baby Boom

The ocean is singing a happier tune this summer, thanks to a remarkable uptick in newborn whale sightings across the globe.

In the United States, conservationists are celebrating a historic milestone for the critically endangered North Atlantic right whale. North Atlantic right whales are among the most endangered large whales on the planet, but this year’s calving season yielded 23 documented calves, the highest number since 2009.1

Critically, scientists noted that mothers are giving birth at shorter intervals (three to four years, compared to the stressed-out seven to ten years of the past decade), indicating they are healthier and finding better feeding grounds.2

Sightings were also up sharply, with 500 sightings of 129 whales migrating south, a 29% increase on the prior season.3 Decades of protective work, slower shipping lanes, gear modifications, habitat protections, appear to be paying off at once.

Meanwhile, on the East Coast of Australia, wildlife experts are bracing for the biggest humpback and southern right whale baby boom in over 50 years, with record numbers of mother-calf duos spotted migrating past Sydney!4

2. Courtroom Victory: Holding Big Oil Accountable in Paris

Now we head to Paris, where a landmark legal win is sending shockwaves through boardroom doors worldwide.

In a historic ruling, the Paris Judicial Court ordered French fossil fuel giant TotalEnergies to update its environmental vigilance plan within six months to specifically account for its “Scope 3” emissions.5 Scope 3 emissions, the carbon generated when customers actually burn the oil and gas a company produces, account for the vast majority of Total’s carbon footprint. The company now has six months to reissue that plan with concrete measures to address the harms its products cause to the environment and human rights, and the court has said it will review the new version once filed.6

This follows an earlier French ruling against the same company over misleading “energy transition” marketing, and ClientEarth, one of the NGOs behind the case, called it part of a growing body of decisions holding the companies most responsible for climate change accountable for their part in it.7 While this is a French court applying French due diligence law and not a global precedent, it adds real pressure nonetheless. If courts keep ruling that Scope 3 accounting isn’t optional, boardrooms elsewhere have reason to pay attention.

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3. Plastic-Free Beauty Hits Sephora

Here’s some big news just in time for Plastic Free July: luxury cosmetics brand AORA México has officially debuted at Sephora, making history as the retail giant’s very first 100% plastic-free beauty brand.8

The Mexico City-founded color cosmetics line launched by Nour Tayara and Rodrigo Peñafiel uses formulas built around native Mexican ingredients like chile, tepezcohuite, and cactus flower. Instead of the usual plastic tubes, Aora houses its products in sleek, recyclable packaging made of tin, aluminum, and sustainably sourced wood. To boot: Through certification with rePurpose global, every purchase from AORA funds the removal of 9x the product’s weight in plastic waste from nature.

This signals that sustainability and beauty can go hand in hand, and that AORA is setting a new precedent for other brands to follow to make plastic-free packaging the standard!

4. The Baltics’ first hybrid solar-and-battery plant

In the energy transition realm, Lithuania just got one of its first hybrid renewable energy sites. European Energy has connected a 25 MW / 65 MWh battery storage system to the grid in Anykščiai, paired with its existing 78.5 MW solar park at the same site, one of the largest solar facilities in the Baltic region.9

The pairing of the battery storage system and the solar park is quite intentional. Batteries next to solar smooth out the natural swings of a sunny afternoon, letting the grid draw on stored power when the sun dips. European Energy worked closely with Lithuania’s transmission operator, Litgrid, throughout the project and says the combination is expected to increase system flexibility and support balancing services as renewables scale up across the grid. The company already operates roughly 400 MW of renewable capacity in Lithuania and has around 800 MW more in development across solar, wind, and storage, including a second battery project due online by December.10 Big energy wins for a small country!

5. London’s New Beaver Engineers

For our last story, we head West London. For decades, commuters at Greenford Tube station routinely had to navigate ankle-deep floodwater after heavy rains. Local councils braced themselves for hefty engineering bills to fix the problem. That is, until they decided to bring in some highly specialized contractors.

In 2023, a family of five beavers was reintroduced to Paradise Fields, a nearby former golf course, as part of a rewilding initiative.11 Fast forward to this summer, and these fuzzy engineers have constructed a stunning network of seven dams.12 The dams act as a giant natural sponge, slowing down downstream flows. The result? Despite intense summer downpours, the Tube station and surrounding residential homes remained completely dry. Even better, the newly formed wetlands have sparked a biodiversity boom, welcoming back migrating birds, tadpoles, and rare butterflies.

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Final Thoughts

When you look around, strides in the right direction are being taken everywhere. Big media just doesn’t always cover them because they are ‘less exciting’ or won’t get the big views they are going after. But that doesn’t mean progress isn’t being made or that good people (and animals!) aren’t working everyday to create a positive impact.

These stories prove that. And they point to a bigger picture that small changes compound together to make a tangible impact.

Subscribe for more good sustainability news in the future!

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

Even as federal greenhouse gas standards face rollbacks and the EPA pushes Congress to dismantle longstanding vehicle emissions waivers, California regulators are pressing forward with corporate climate disclosure, packaging waste, and vehicle electrification initiatives, frequently in spite of active legal challenges. This ongoing momentum positions California as the true regulatory center of gravity in the U.S. for sustainability teams right now, rather than any individual federal policy. As the world’s 4th largest economy, California has the power to write its own environmental playbook that influences the other states and any company that wants to do business in this major market.1

In this week’s newsletter, we cover California’s environmental initiatives that you need to know, what’s changing, and what it means if your company touches California in any way.

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What Makes California Unique?

California is the world’s fourth largest economy, larger that of Japan, France, or the UK.2 That scale gives its regulators leverage no other state has. A rule written in Sacramento doesn’t just apply to companies operating in California, but it effectively becomes a national compliance requirement, since most businesses build one program rather than fifty. California has also been a first mover before. Its authority to set its own vehicle emissions standards predates the Clean Air Act itself, and other states have spent decades simply adopting whatever California decides.3 The same pattern is now playing out with corporate climate disclosure and packaging law, making California less a single state to watch and more a preview of where national policy is headed.

SB 253: The Climate Corporate Data Accountability Act

In 2023, California enacted the Climate Corporate Data Accountability Act (SB 253). To many, SB 253 is regarded as the most impactful climate law in the United States. It requires large companies doing business in California with revenues over $1 billion to publicly report Scope 1, 2, and eventually Scope 3 emissions and is administered by the California Air Resources Board (CARB).4 It is expected to impact approximately 5,000 companies.5

There are two key criteria that makes a company subject to SB 253:

1. Annual revenues exceed $1 billion

This is not California-specific revenue, but rather the total annual revenues of the reporting entity

2. The company “does business in California”

Under the California Revenue and Taxation Code, a corporation is considered to be doing business within the state if it is incorporated or commercially domiciled there, or if its sales, property, or payroll in California surpass specific threshold values. Consequently, any business maintaining a substantial commercial presence, such as utilizing sales operations, local distribution networks, or state-based personnel, will likely meet these criteria, irrespective of its corporate headquarters location.

What teams need to know right now is that the compliance calendar might have just moved. On June 24, 2026, CARB proposed pushing the initial Scope 1 and 2 reporting deadline from August 10 to November 10, 2026, giving CARB time to finalize a regulation it had already submitted for approval and then pulled back.6 The agency says the changes will be “limited,” aimed at clarifying requirements rather than adding new ones, and will go through a 15-day public comment period before resubmission.

CARB has also signaled it will use enforcement discretion for good-faith first-year filings, though its statements on what that covers have shifted enough that legal advisors are flagging real ambiguity for companies that weren’t already collecting emissions data as of December 2024. Whether insurance companies fall inside SB 253’s scope also remains open, pending CARB’s coordination with the state’s Department of Insurance.

Looking further out, CARB has said it will open a distinct rulemaking later in 2026 covering 2027-and-beyond requirements, including Scope 3 emissions and third-party assurance. A public workshop on that track is scheduled for July 21, 2026.

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SB 261: Climate-Related Financial Risk Disclosure Act

SB 261, the Climate-Related Financial Risk Act, requires many of the same companies to disclose climate-related financial risks and mitigation strategies, aligned loosely with TCFD-style frameworks. Specifically, it targets companies with over $500 million in annual revenue operating or doing business in California.

Unlike SB 253, SB 261 remains on hold as the U.S. Court of Appeals for the Ninth Circuit granted an injunction in late 2025 halting CARB’s ability to enforce it while an appeal proceeds.7 SB 253 is caught up in the same litigation, but has continued to remain in effect throughout.

Notably, the two laws were also amended and consolidated legislatively into a combined bill (SB 219) covering both climate corporate accountability and financial risk disclosure, which is now the technical vehicle carrying both programs forward.

SB 54: Plastic Pollution Prevention and Packaging Producer Responsibility Act

In 2022, the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) was signed into law as a step to reduce the negative impacts of packaging waste in the state, which makes up more than 50% of landfill contents.8 Upon the implementing regulations taking effect on May 1, 2026, SB 54 became one of the country’s most far-reaching extended producer responsibility programs. It regulates an estimated 5,741 producers and aims to shift the burden of plastic pollution from consumers to the producers of single-use plastic and packaging.9

There are several key obligations for producers under SB 54 in addition to the goal to reduce plastic packaging over time. Foremost, producers must pay $5 billion over 10 years, or $500 million annually, starting in 2027 to address the environmental impacts of their products and support those communities most impacted by the pollution caused by their products. Producers of single-use packaging and food-service ware must also fund and participate in an approved Producer Responsibility Organization, currently only being the Circular Action Alliance (CAA). Furthermore, producers must work toward binding recycling targets by 2032: cut single-use plastic by 25% compared to 2023, recycle 65% of single-use plastic, and ensure 100% of single-use packaging and food service ware is recyclable or compostable.10 CalRecycle, more formally known as the California Department of Resources Recycling and Recovery, must also adopt permanent regulations accordingly.

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Within a month of the May 2026 date, the regulations drew two lawsuits representing two very different concerns.

The first lawsuit was brought about by several environmental groups, including NRDC, Californians Against Waste, and Oceana, arguing that the final regulations were both inconsistent with SB 54 and several key provisions were arbitrary and/or without a rational basis.11 The concerns here are about the actual effectiveness of the regulations established to implement SB 54 in light of several gaps and loopholes across provisions.

Separately, Nebraska and sixteen other states, joined by the National Association of Wholesaler-Distributors (NAW), sued on Commerce Clause and First Amendment grounds, arguing the law reaches businesses far outside California. The concerns represent the broad regulatory reach that California has, where laws passed in California inevitably affect other states because of its vast market power and size.

Despite pending lawsuits, SB 54 is fully in force. Producers should still be assessing coverage, joining a PRO or pursuing individual compliance, and tracking packaging data, while monitoring both cases for anything that could shift deadlines.

Advanced Clean Cars II

California has long been a pioneer in demanding clean air standards in the US, with the state’s first clean car standards dating back to 1966.12 This leadership role was recognized nationally when the Air Quality Act of 1967 (the first rendition of what is known today as the Clean Air Act) explicitly authorized California to keep enacting more rigorous pollution limits for vehicles in order to fight the state’s chronic and dangerous air quality issues.13

As California continues to fight for more rigorous pollution standards, none of the state’s climate policies have taken more direct federal fire this year than the state’s vehicle emissions authority. The standards for the Advanced Clean Cars II, Advanced Clean Trucks, and Heavy-Duty Omnibus rules (recent air quality standards for vehicles) have been at the center of this battle. Congress used the Congressional Review Act last year to strip California’s waivers for these standards, despite the objection of the Senate Parliamentarian, who found the waivers weren’t the kind of rules the CRA was meant to cover.14 The EPA has now gone further, asking Congress to use the same mechanism against California’s foundational 2009 greenhouse gas vehicle standards and the 2013 Advanced Clean Cars program, rules that automakers have already fully complied with.15

In response, CARB has started an emergency rulemaking to keep 2025-level smog and greenhouse gas standards in force for cars and trucks until either new standards are adopted or a court reinstates ACC II. It is explicitly not enforcing the 2025 zero-emission vehicle sales requirement in the meantime.16

The stakes extend well past California’s borders. Because seventeen other states have adopted California’s vehicle standards under Section 177 of the Clean Air Act, prior modeling found that full adoption of ACC II across those states could cut nationwide transportation emissions by roughly 1.3 billion metric tons of CO2-equivalent through 2050, while saving households an average of over $200 a year and preventing tens of thousands of asthma attacks.17 Those projected gains are now in legal limbo.

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Looking Forward

The direction of California’s travel is clear. Whatever the courts and Congress may decide on any single rule, the broader shift toward mandatory climate disclosure, extended producer responsibility, and cleaner vehicle standards isn’t going away. California is simply the state moving first, the way it has on air quality for sixty years. Other states have historically followed its lead, and companies that build reporting and compliance infrastructure now, rather than waiting for every legal question to resolve, will be the ones ready when the next state, or the SEC, or a major customer’s supply chain requirements, catches up.

The real work ahead for sustainability teams is to develop a system that is both rigorous and flexible to comply with the moving parts in the California regulatory space. Brightest exists for exactly that kind of moving target, helping teams manage disclosure obligations across jurisdictions in one place instead of rebuilding their process every time a deadline shifts. Want to speak with one of our experts? Reach out.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

To understand how corporate leaders can adapt, we interviewed Brian Cahill, the founder and CEO of the Sustainability Reporting Institute. Previously operating as the CSRD Institute, his organization executed a major strategic pivot to mirror the changing realities of international corporate standards. Cahill provides an essential perspective about why that rebrand happened, what it reveals about how the field is evolving, and what it means for practitioners trying to navigate an increasingly complex landscape.

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From the CSRD Institute to the Sustainability Reporting Institute

For nearly two years, the Sustainability Reporting Institute operated under a different name. In May 2024, it launched as the CSRD Institute, with training focused on the EU’s CSRD and the ESRS. With over 50,000 individuals completing the ‘CSRD Fundamentals’ course, their approach clearly hit a market need. But, the name change in March 2026 signals that the global sustainability reporting landscape has matured enough that a single regulation (or regional focus) no longer defines the field.

This evolution was driven directly by structural changes in European policy, specifically the introduction of the omnibus one package. This legislative intervention scaled back the initial scope of the CSRD, introducing sudden market ambiguity. Recognizing that modern sustainability professionals must manage intersecting requirements rather than a single regulation, the institute expanded its curriculum to cover the global compliance ecosystem.

“It became clear to us that professionals weren’t working solely within one standard or one framework alone,” Cahill says. “But across a growing ecosystem of reporting frameworks.”

Today, the institute offers structured certification tracks integrating multiple international reporting methodologies. While maintaining its technical courses on European frameworks, its updated curriculum covers international baselines, carbon accounting standards, and simplified reporting structures for smaller entities. Taught by expert practitioners in the field, these range from training courses that blend theory and practice to master classes with a practical approach, available both in live or on demand formats.

Sustainability Reporting as a Core Business Operation

Sustainability reporting has become a core aspect of business operations. While political pushback against ESG frameworks fills headlines, the practical reality inside commercial capital markets tells a different story. Institutional lenders, commercial banks, and global insurance underwriters are rapidly accelerating requirements for structured, verifiable sustainability information before allocating capital. The market has settled into a dual system dynamic. In this environment, regional policy approaches may fluctuate globally, but practical market demands continue to converge on increasingly standardized, interoperable frameworks.

As it stands today, the sustainability reporting space remains young, and at this stage, professionals are coming to this work from everywhere.

Look at it this way: Finance and accounting teams are heavily involved because sustainability disclosure is entangled with financial oversight; legal and governance professionals are engaged because regulatory requirements keep shifting; supply chain managers care because they need to understand scope 3 emissions; HR teams are involved because social reporting is now material to investors; procurement is tracking supplier disclosures; compliance teams are mapping new obligations. Sustainability reporting affects all areas of business operations, and is becoming much more integrated with the financial reporting process.

“Sustainability reporting is becoming much more integrated with financial reporting processes,” Cahill explains. “It’s the wider reporting process across a team, across entire business operations.”

Sustainability reporting is no longer a specialist function. It’s becoming increasingly woven into core business operations. That means the training needs to serve not just ESG practitioners, but the finance directors, lawyers, and auditors who now work on these issues as part of their broader remit.

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How the Sustainability Reporting Institute Supports Professionals

There are a broad range of professionals engaging with the training at the Sustainability Reporting Institute, not only those from ESG teams. The institute designs its curriculum with this diversity in professional experience in mind. There are different pathways to meet the needs of unique audiences, both in terms of jurisdiction and technicality. In terms of jurisdiction, there are CSRD trainings that target large European companies or ISSB guidance serves practitioners in jurisdictions adopting those standards globally, for instance. There are also three levels ranging from fundamental knowledge, to a deep-dive into detailed framework and regulation knowledge, to extreme detail for report preparers who require granular guidance on specific disclosures.

Additionally, amidst the uncertainty in this new sustainability reporting space, many of us are struggling to keep up to date with all of the regulatory changes, different standards, and updates across the landscape. Direct member feedback drove the institute to build something more alongside its training: a members-only hub with curated weekly updates on regulatory developments. This is curated intelligence on what has changed each week, which frameworks are being updated, where there are open comment periods, and what’s relevant to your jurisdiction.

Looking Ahead: Visions for 2035

When Cahill thinks about 2035, he imagines sustainability information treated with the same rigor and decision-usefulness as financial reporting. He also reimagines the reference to ‘sustainability’, picturing that such reporting becomes embedded into the core functions of a business across every department.

For investors, regulators, and stakeholders, this means that everyone would be working from a consistent baseline centered around high quality disclosures, reliable capital allocation, and better risk assessments across the board. From an impact measurement perspective, this means aiming for improved data quality and comparability across key realms like GHG emissions, transition plans, exposure to risk, broad sustainability reporting risks, and equal treatment to social standards.

That shift is already beginning. The fact that finance teams validate disclosures, legal interprets requirements, and board committees oversee both financial and sustainability performance isn’t anomalous. It’s the field maturing.

The Sustainability Reporting Institute’s expansion is one visible sign of this maturation. Other signs include regulatory convergence around interoperable standards, market demand for comparable disclosures, and capital providers enforcing discipline on reporting quality.

For organizations navigating this landscape, the combination of training, regulatory intelligence, and community that the institute provides reflects what many practitioners need right now: clarity on which standards matter for your business, practical guidance on implementation, and connection to a community working through similar challenges.

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Final Thought

By 2035, environmental, social, and governance data may be fully absorbed into core business operations, standard risk management, and daily financial reporting cycles. Businesses that build deep technical capacity today will successfully eliminate information disparity and secure long-term efficiency. Be sure to check out the Sustainability Reporting Institute to learn more about how they can help prepare you and your team for the future of this evolving field.

This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

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The reality in Frankfurt exposes a flaw in the plan.

Over 153 data centers now consume up to 40% of Frankfurt’s total power load.2 The city’s grid operator, Mainova, has already allocated all available electrical capacity through the 2030s. New operators requesting connections face the reality that no power is available for years. And when faced with energy bottlenecks, data centers do what makes financial sense: they use fossil fuels.3

This is not a local planning failure. It is a signal of a continental infrastructure constraint that may reshape Europe’s entire AI strategy. And it forces companies to make deliberate choices about where infrastructure is built, how it is powered, and what trade-offs are acceptable.

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The Scale of the Tension

The friction currently defining Frankfurt’s data center landscape warns Europe for a broader, high-stakes collision between AI development and energy capacity.

Globally, AI-specific data center electricity consumption is projected to rise 11-fold between 2023 and 2030, from 50 to 554 terawatt-hours annually.4 Within Europe, the scale of ambition is similarly steep. Germany alone, where Frankfurt concentrates nearly half the nation’s data center capacity, expects data center electricity demand to rise from 4% of gross power consumption in 2024 to 10% by 2037.5 And this is just the beginning. The EU’s stated commitment is to triple data center capacity in the next 5–7 years through the Cloud and AI Development Act (CADA).6 CADA is a key element of the EU’s broader AI Continent Plan, which is the bloc’s commitment to becoming a global AI leader.7

As Europe’s most densely wired financial hub, Frankfurt is the home of DE-CIX. This attracts a gravitational pull of data and connectivity called “data gravity”, making it an ideal location for data center construction as data can be transmitted extremely quickly as connectivity is already dense, where latency is minimal, and where customers are nearby.8 This gravitational pull has been irresistible, so Frankfurt has become Europe’s premier data center city with over 150 data centers.

Yet that concentration comes with its own set of problems, especially for a city whose grid has already allocated all available capacity through 2030.

This boom has had a visible impact on Frankfurt, demanding increasing levels of electricity, water, and land use to meet resource intensive needs of these data centers. City views from above show the stark reality of these constructions even among densely populated zones, where the easy-to-identify flat buildings are popping up and expanding urban areas.9 Data centers make up to 40% of the power demand of the entire city, causing a long bottleneck in the power-grid.10

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What Happens When Infrastructure Cannot Expand

This grid bottleneck raises concerns that the quest for AI-driven growth is increasingly forcing facilities to rely on fossil-fueled backup power. Take CyrusOne’s FRA7 facility, which was marketed explicitly as a sustainability-focused data center, when facing such grid capacity bottlenecks. To overcome the blockage and power its expansion from 84 MW to 126 MW, it announced a partnership with energy supplier EON to install gas-powered generators.11

While a rational move from an operational perspective, this is catastrophic from a sustainability lens. One facility at a time, the infrastructure underpinning Europe’s AI ambitions becomes fossil-backed. Multiply this across a continent facing grid shortages in every major metropolitan area, and decarbonization targets begin to fade.

This creates an uncomfortable question for procurement and compliance teams: Without explicit sustainability mandates in vendor selection, are you inadvertently funding infrastructure that locks in gas-powered backup systems? This matters for supply chain risk assessment (grid constraints become stranded assets). It matters for regulatory compliance (CSRD Omnibus, ESG reporting requirements). It matters for carbon accounting, because if your data center provider is running on backup fossil fuel, that carbon is in your Scope 3 footprint.

The EU has recognized this problem. The Cloud and AI Development Act (CADA), expected to finalize in late 2027, explicitly frames data center expansion around three objectives: RDI (development and adoption), autonomy (EU sovereignty in cloud provision), competitiveness (faster deployment, open markets).12 The Commission explicitly acknowledged the need to “balance AI ambitions with climate commitments,” recognizing that data centers require intensive fresh water and electricity.13

The proposed legislation introduces sustainability requirements and preference for brownfield over greenfield sites, alongside grid-connection conditions that will shape investment decisions.14 A complementary Data Center Energy Efficiency Package is being proposed to establish an EU rating scheme covering energy efficiency, water efficiency, clean energy use, waste heat reuse, and flexibility.15

The Geographic Reallocation

Frankfurt’s crisis is not unique to Frankfurt. It is simply the place where the constraint emerged first and most acutely. Other major European hubs like Dublin, Amsterdam, Paris, and London will likely face similar grid rationing in the coming years as AI demand accelerates.

What is happening as a result is structural reallocation as Europe’s data center map is being redrawn by grid access, power constraints, and permitting.16 Traditional hubs like Frankfurt will continue attracting latency-sensitive workloads (finance, enterprise cloud, inference tasks). But large-scale AI training, which is the computation-hungry work that defines frontier AI development, is migrating to regions with abundant renewable energy and available grid capacity.17

Spain and Italy are emerging as Europe’s strongest growth zones, supported by government incentives, newly developed subsea cable landing points, and faster approval timelines.18 Poland is identified as Eastern Europe’s standout contender, with sustained infrastructure investment and education-driven talent pools.19 Portugal, with its renewable energy surplus and coastal location, is also attracting attention as an emerging data center market.20

This represents a structural reallocation driven by finite electricity and the regulatory pressure to decarbonize. Smart procurement teams are already treating grid access as a primary site-selection criterion, rather than a secondary logistics consideration. Geography now matters more than price or brand recognition.

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The Uncomfortable Truth

Europe has good reason to be as ambitious as they are in their AI Continent Plan. The intention to triple data center capacity, establish 19 AI factories and 5 gigafactories, and mobilize €20 billion in private investment is necessary to compete globally, especially if the goal is to be a global leader and achieve technological sovereignty. This is especially the case to keep data sovereignty and protect national security, especially when looking at new powerful tools like Fable 5 from Claude (which was unavailable for about 18 days after being banned by the US Government).21

But Frankfurt shows the constraint that no policy document can wish away: you cannot have unrestricted AI infrastructure growth and genuine climate progress at the same time, not when grids are already strained and backup power systems run on fossil fuel.

The choice Europe is making, intentional or not, is to allow that constraint to be resolved by geography and price signals rather than by deliberate strategy. Some infrastructure will be built in constrained hubs with fossil backup. Some will be built in secondary markets with renewable energy surplus. And others will sit in queues, delayed by years.

For procurement and compliance teams, the message is clear: the teams treating data center location as a commodity decision will find themselves funding fossil-backed infrastructure. The teams treating it as an infrastructure and regulatory constraint will diversify geographically, build sustainability into vendor requirements, and position themselves favorably when regulations tighten.

Frankfurt’s grid is full. The question now is whether your supply chain strategy will be determined by that constraint, or whether you will let it be determined for you.

What Teams Should Do Now

Start with these immediate actions:

Map your data center footprint by region and grid constraint level. Identify which partnerships are in Frankfurt, Dublin, Amsterdam (facing imminent rationing) versus secondary markets with available capacity. Request explicit disclosure of grid connection status and backup power systems (is it fossil fuel or battery?). Build sustainability commitments into vendor RFPs now, before CADA becomes mandatory, specifying minimum renewable energy percentages by year and hour of generation, not just annual matching. Model what happens to your Scope 3 footprint and CSRD reporting (if applicable) if a major data center partner shifts to fossil backup due to grid constraints and use this scenario analysis to inform diversification strategy across regions.

The operators moving early will command preferential access to public procurement opportunities; those that delay will face retroactive compliance costs. Need some support? Brightest is here to help.

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Final Thoughts

Frankfurt’s grid crisis is a preview of a continent-wide choice that will unfold over the next 18–24 months. As CADA moves toward finalization and EU member states begin implementing complementary energy efficiency packages, data center operators will face a choice: invest in constrained hubs with fossil backup systems, or diversify to secondary markets with renewable energy surplus and available grid capacity.

The uncomfortable truth is that Europe’s AI ambitions are not a sustainability problem to be solved through technology or policy alone. They are a resource allocation problem constrained by, among other factors, finite energy, land, and time. The EU has made a real commitment to triple data center capacity in 5–7 years. It has also set itself the goal to be the first climate neutral continent by 2050.22 Both cannot be achieved simultaneously without making deliberate choices about where infrastructure is built, how it is powered, and what trade-offs are acceptable. Frankfurt shows what happens when those choices are left to market forces and individual operator decisions. The question for sustainability professionals is not whether a trade-off exists. It is whether your organization will be complicit in the default allocation, or whether you will shape it proactively. The approach to that decision will determine your carbon footprint, regulatory risk, and competitive position moving forwards.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

That’s the terrain Prof. Wayne Visser has been mapping for decades. Amidst senior roles at KPMG and Capgemini, Visser has always used academia as a way to distance himself from his corporate work to not only deepen his knowledge, but to refresh his perspectives and rejuvenate his spirit. He calls himself a “pracademic”, navigating the boundary between academia and business practice, precisely because he realized that proximity to business limits how critical he could be about their impact. This approach has enabled him to develop a systematic way of approaching problems and solutions that challenges businesses to be more ambitious in driving the transformational changes our world so needs.

Now, as Director of the Católica Centre for Thriving Futures and Galp Chair and Professor of Practice in Regenerative Business, Innovation and Technology at Católica Porto Business School, and Fellow at the University of Cambridge Institute for Sustainability Leadership, Visser is releasing his new book, Technologies of Hope, which makes a case that planetary restoration isn’t just necessary. It’s already underway, and there are eight transformational technologies scaling solutions right now.

We spoke with him about why this matters now, what AI’s real role is in sustainability, and why the conversation about “hope” isn’t naive optimism, but rather informed realism.

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What Disruptive Technologies Actually Make Possible

Here’s the problem with most technology adoption in business: it increases our power without changing our intention. We keep producing and consuming at accelerating rates.

Cars let us travel further. Computers let us process more data. Tractors let us farm more land. But as Visser points out, the net result has been to ramp up production and consumption, which in turn depletes resources and devastates ecosystems. We’ve become more efficient at the wrong things.

This is why the standard sustainability playbook of doing more with less, improving efficiency, and optimizing your footprint can become a trap. It keeps organizations operating within the existing system rather than reimagining it.

Visser argues that emerging disruptive technologies may give us the opportunity to reverse this trend, instead speeding up and scaling regenerative practices and nature restoration.

In his new book, Technologies of Hope, Visser examines how innovation can, and is already, scaling solutions to our environmental crises. Eight transformational technologies are put under the spotlight: solar, wind, batteries, EVs, next-generation materials, next-generation foods, earth information systems, and robotics/AI. Building on his previous bestseller Thriving, Visser explores several key questions about these technologies throughout the chapters:

• How have they evolved from invention to commercialisation?

• How fast are they scaling in terms of market growth and falling cost curves?

• What are their positive and negative social and environmental impacts?

• Who are the key players?

• What are the likely future trends?

These technologies may not be silver bullets, but collectively, they’re showing that a net zero and nature-positive future is both economically viable and commercially attractive right now.

The Mindset Shift: From Responsible to Regenerative

Visser emphasizes that the core mindset shift required for business leaders is to move from the perspective of being responsible or sustainable to being regenerative or thriving. This shift isn’t complicated, but it is profound, and getting there is both essential and entirely possible.

Essential because the earth systems we depend on are in crisis. Possible because the market opportunity is real and accelerating. He points to China, which has positioned itself as the world’s first “electrostate” (as opposed to petrostate) and clean tech giant. They are betting its current and future success on the regenerative economy and are winning significantly. But the opportunities aren’t zero-sum. There are enough market openings for businesses of all sizes and sectors to benefit from regeneration.

For compliance teams, regulatory pressure is moving beyond carbon neutrality toward nature positivity. For supply chain professionals, your vendors are making bets on regenerative technologies right now, and understanding where cost curves are moving is increasingly critical to managing supply chain resilience. For sustainability managers and executives, the question isn’t whether your organization believes in regeneration. It’s whether you have a roadmap for actually building it into your operations, product lines, and partnerships.

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AI: Widest and Wisest, Not Just Fastest

If regeneration is the destination, AI is one of the most powerful tools for getting there, if we just use it the right way.

The conversation about AI in sustainability tends to focus on efficiency: using machine learning to optimize routes, predict maintenance, reduce energy consumption. Those applications matter. But Visser makes a sharper point: AI’s real power is in democratizing access to solutions and discovering new ones we haven’t found yet.

Take AlphaFold, Google DeepMind’s AI system that accelerated the discovery of plastic-eating enzymes. Or Blue River Technologies, working with John Deere, which uses AI-guided precision agriculture to cut chemical herbicide use by nearly 50%. These are regenerative breakthroughs at scale, and they’re already profitable.

The mindset shift regarding AI he advocates is moving from “fastest” to “widest and wisest.” Can AI help us scale existing environmental solutions more cheaply and quickly? Yes. Can it help us discover solutions we haven’t had the time or resources to find? Increasingly, yes.

This is directly relevant to your team if you’re thinking about how to integrate AI into your sustainability work. The question isn’t whether AI will replace human judgment, rather whether you’ll use it to optimize harm reduction or to accelerate regeneration.

Will Technology Free Us?

Visser raises a harder question that doesn’t have a guaranteed answer: Will AI free us by automating 3-D jobs (dull, dirty, and dangerous work) so we can spend time on what gives life meaning? Or will they simply make us more efficient at the same exhausting pace?

He points out that AI has already allowed many of us to be more creative through producing our “own” art, music and graphics. Researchers and entrepreneurs that are experimenting with creative solutions in ways they couldn’t before.

More crucially, Visser raises the question of whether automating the 3-D jobs can give us time to nurture our human relationships, be creative, and turn our passions into vocations, and whether AI will teach us to value human traits like empathy and compassion? Yet, there is no way to guarantee this. Previous technologies have already made us more productive without necessarily releasing us from the demands of paid work. AI could change that equation. It has the potential to actually let us nurture our human traits. But, Visser advises that this is only if we couple technological innovation with major reforms of our political and economic systems.

For sustainability leaders, this is crucial framing. The regenerative transition isn’t just about swapping coal for solar. It’s about whether we’ll use these technologies to build systems that value human flourishing and ecological restoration, or whether we’ll simply scale the same extractive logic.

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Looking Ahead

Technologies of Hope arrives at a crucial moment. As the climate crisis intensifies, global climate and biodiversity targets are tightening, investor pressure on net-zero claims is escalating, and the technologies that make regeneration possible are accelerating faster than most can anticipate.

The book makes a case for informed optimism rather than blind hope, grounded in understanding how these technologies are already scaling, where the market is moving, and what a regenerative future actually looks like economically.

For those interested in going deeper on how to actually integrate AI into your sustainability strategy, Nina Benoit is convening a cohort specifically built around “Understanding AI’s Footprint & Using It for your Sustainability Work,” with Prof. Wayne Visser giving the introductory speech. It’s designed for practitioners navigating exactly this terrain. Learn more about the course here and save your spot today!

Get a 10% discount on the course

The shift from responsible to regenerative isn’t a future conversation. It’s happening now, at scale, in markets and technologies that are reshaping how business creates value. Understanding where that shift is heading and where your organization sits within it is a crucial next step to take. Be sure to check out Technologies of Hope when it comes out!

About Prof. Wayne Visser

Wayne Visser is Director of the Católica Centre for Thriving Futures and Galp Chair and Professor of Practice in Regenerative Business, Innovation and Technology at Católica Porto Business School, and Fellow at the University of Cambridge Institute for Sustainability Leadership. His new book, Technologies of Hope, builds on his previous bestseller Thriving to make the case that eight transformational technologies are already scaling solutions to our environmental crises.

This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

For many, this means managing fragmented tools, multiple vendors, and disconnected processes. The result: inefficiency, higher costs, and increased risk of data inconsistencies or compliance gaps

These are the challenges the new Brightest and TÜV SÜD global partnership sets out to address.

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A Single Ecosystem for Data and Assurance

Brightest has partnered with TÜV SÜD, a global leader in independent testing, auditing, certification, and assurance. The integration connects three distinct but complementary capabilities within one platform:

1. Supplier Auditing

Supplier audits are conducted on-site by TÜV SÜD experts to assess actual conditions and performance across ESG topics (e.g. labor practices, environment, governance). Through the Brightest platform, organizations can:

• Identify high-risk suppliers based on data and screening

• Trigger audits (e.g. SMETA or tailored ESG audits)

• Access audit findings and insights directly in the system

This ensures that audits are targeted where they add most value, enabling effective risk mitigation and deeper visibility into supplier practices.

2. Sustainability Reporting Assurance

Sustainability assurance is a formal, independent third-party process that verifies the accuracy, completeness, and reliability of disclosed ESG data. With TÜV SÜD verification steps embedded into Brightest:

• Sustainability data flows directly from the platform into the assurance process

• Organizations can request independent verification without manual data transfer

• Assurance is performed impartially by TÜV SÜD as an external assurance provider

This reinforces credibility, transparency, and trust with regulators and stakeholders especially when voluntary reporting standards like VSME, GRI are used.

3. Integrated Digital Workflow

The platform connects:

• Data management

• Supplier auditing

• Independent assurance

into one seamless workflow.

The result: no duplication, no data silos, and full alignment between operational insights (audits) and reported disclosures (assurance).

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What does this mean for you?

Organizations can now manage sustainability data, conduct supply chain audits, and prepare for independent verification all within the Brightest platform, without having to juggle a multitude of vendor relationships, tools, and processes.

“This partnership brings together advanced sustainability software with globally recognized expertise in assurance and auditing,” said Chris Bolman, Co-Founder and CEO of Brightest. “By combining these capabilities, we enable organizations to manage their sustainability data, strengthen supply chain oversight, and access independent verification and auditing in a single, streamlined platform. For our customers the result is greater efficiency, improved data credibility, and stronger decision-making.”

Responding to Global Challenges

The regulatory environment has transformed auditable data from a “nice-to-have” CSR highlight into an absolute business necessity. From the strict realities of CSRD requirements to global ISSB standards, regulators are drawing a hard line: sustainability claims are more reliable with third-party assurance. Investors, customers, and supply chain partners are also increasingly demanding proof that sustainability data is not just collected, but verified by credible, independent parties.

Supply chain oversight faces similar pressures. If your organization operates globally, you must demonstrate real control over supplier sustainability performance such as labor practices, emissions, resource use, and compliance with local regulations.

Auditing should be seen as a targeted value-added activity, applied selectively to suppliers based on their level of criticality. To maximize impact, it must be driven by data-supported risk analysis—ensuring that on-site audits are performed where they matter most and effectively connected to underlying risk insights. The feedback from the audit on site will again help to re-evaluate the risk of the supplier and prove a robust due diligence system.

By combining TÜV SÜD’s global expertise with Brightest’s digital platform, we are directly addressing this divide. Organizations can now benefit from a comprehensive approach to sustainability management from data collection and analysis through to independent verification and auditing within a single system. This integration addresses the challenge of managing regulatory requirements and stakeholder demand for high-quality, verifiable sustainability data all while maintaining absolute oversight of your supply chain’s integrity.

“This collaboration reflects a strong market need for integrated, end-to-end solutions that connect digital sustainability management with independent assurance and auditing,” said Sara Brandimarti, Global Head of Sustainability of Business Assurance Division at TÜV SÜD. “By embedding our audit and assurance services directly into the sustainability platform, we enable organizations to strengthen both their supply chain performance and the credibility of their sustainability disclosures while maintaining the impartiality and independent role as assurance and auditing provider. This approach enhances efficiency while ensuring that data and processes meet the highest standards of transparency and trust.”

What the Partnership Delivers to your Day-to-Day

To eliminate the coordination friction that typically decelerates the process of sustainability reporting assurance and supply chain auditing, this integration introduces two fully embedded workflows right inside your Brightest dashboard:

Integrated Supplier Audit Workflow: You can instantly identify which suppliers require independent assessment, trigger official audit requests directly within the Brightest platform, and view TÜV SÜD’s live audit results and findings in that same shared environment. This eliminates the complication of separate vendor coordination and brings independent supplier auditing straight into your core sustainability process to take next steps decisions.

Sustainability Assurance Workflow: Move seamlessly from compiling your sustainability disclosures inside Brightest to requesting formal third-party assurance from TÜV SÜD. Because your underlying data flows directly into the assurance pipeline, you secure consistency, transparency, and continuous verification readiness without any manual data-handoff.

This integration leverages TÜV SÜD’s reputation as a leading international testing, inspection, and certification (TIC) provider with nearly 30,000 employees worldwide, alongside Brightest’s all-in-one platform for carbon accounting and regulatory reporting, which natively supports over 40 global frameworks.

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Looking Ahead

The regulatory landscape is shifting, but your administrative burden doesn’t have to grow with it. We believe that auditable data shouldn’t be a stressful scramble at the end of the year but rather should be a natural consequence of a healthy, automated workflow.

This partnership reflects our vision for what modern sustainability management looks like. Organizations shouldn’t have to choose between operational efficiency and credibility, or between data management and independent verification. By embedding TÜV SÜD’s assurance capabilities directly into the Brightest platform, we’re demonstrating that these functions work better together.

As regulatory expectations and stakeholder demands continue to evolve, we’re committed to building a platform where auditable data isn’t an afterthought—it’s built into every workflow from the start. If you’re ready to see how our unified platform can simplify your day-to-day, we’d love to show you around.

Want to learn more? Join us on July 7th 2026 for a live webinar with TÜV SÜD Brightest & TÜV SÜD: A New Global Partnership for Integrated ESG Auditing. Save your spot here!

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

This isn’t uniform regulation. The world isn’t adopting a single AI rulebook. Instead, a more complex reality is emerging: diverse regional approaches anchored by shared principles, with risk-based frameworks and human-centric safeguards becoming the face of AI policy. For businesses and governance bodies, this creates both opportunity and complexity.

This edition offers a global map of where AI regulation stands today, the base foundation for future, deeper regional dives in future editions of the This Week in Sustainability Newsletter.

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The Regulatory Landscape

The global AI regulatory maturity has gone through a period of acceleration. Where once only Europe had comprehensive horizontal legislation, we now see binding laws either enacted or in advanced drafting across Asia, the Americas, Africa, and the MENA region. This reflects a hard-won consensus: AI’s power to harm is too significant to leave to industry alone, despite the innovation it creates.

The European Union

The EU’s AI Act, which entered force in August 2024 and becomes fully operational on August 2, 2026, represents the most mature framework to date.1 Following a risk-based approach, it bans eight specific AI practices deemed as unacceptable risk, sets strict compliance obligations for high-risk systems (those affecting fundamental rights, safety, or critical infrastructure), and requires transparency disclosures for systems that interact with people or generate synthetic content.2

Providers of general-purpose AI models, which are the foundation models underpinning many applications, now face rules on systemic risk assessment and training data transparency as of August 2025. Non-EU companies selling into the European market must comply with the same standards as EU-based competitors, making the Act a de facto global standard-setter.

The wider package of AI policy measures in the EU also includes initiatives like the AI Continent Plan, the AI Innovation Package, and the launching of AI factories. The goal of these initiatives are:

AI Continent Plan: to (1) increase competitiveness and productivity in AI-driven processes; and (2) to ensure a sovereign, secure, and democratic bloc.3

AI Innovation Package: to support AI startups and small-medium enterprises (SMEs).4

Launching AI Factories: to develop AI models that are both trustworthy and cutting-edge.5

On a state-level, countries like Italy and Germany have also made tangible strides in the regulation of AI and related activities.

Italy was the first country in the EU to pass a national law complementing the EU AI Act back in September 2025.6 The law addresses among the most crucial matters that Italy is up against in regards to the imminent rise of AI technologies, including the use of AI by minors and how it affects sectors like justice, work, and health.

In Germany, the Energy Efficiency Act (Energieeffizienzgesetz, or ‘EnEfG’) was brought into force in November 2023 with data centers explicitly included in the scope (Articles 11-15).7 These articles target data centers with specific conditions that have been devised to reduce energy consumption and improve operational efficiency at both new and existing facilities.8

North America

North America presents a more fractured picture. Both the United States and Canada seem to be prioritizing rapid innovation and competitive positioning over precautionary restrictions.

There is no existing Federal AI law in the US to date. Instead, governance is derived from a slew of agency enforcement, executive orders, and pending legislation.9 In turn, combined with the polarized political sphere, the current state of governance in the AI space is quite murky in the US.

In March 2026, The Trump Administration released a National Policy Framework for Artificial Intelligence, signaling a federal preference for unified national standards and federal preemption of state laws.10 In Congress, Republican Sen. Blackburn’s proposed Trump America AI Act (also March 2026) outlines proposed safeguards regarding AI, but also pushes federal preemption of AI laws for the next three years. The Democrats have enacted the Guardrails Act to block it, citing the need to ensure that states can enact their own, stricter baseline protections.11 This partisan divide virtually guarantees continued state-level activity, defeating the federal goal of uniformity.

Yet while federal action remains uncertain, individual states are legislating rapidly. California, New York, Maryland, and Washington (among others) have enacted or are enacting laws on companion chatbots, surveillance pricing, frontier model transparency, and deepfakes.

Canada maintains a more limited approach as they find themselves in the transitional phase. Where the comprehensive ‘Artificial Intelligence and Data Act’ law was proposed on the federal level, it has since been halted. The new national standard is found in the ‘National AI Strategy: AI for All’. In terms of hard law, Canada maintains a more limited approach with Treasury Board directives on automated decision-making in federal agencies only.12 Like the US, Canada’s AI regulations are led by the provinces. For instance, in Quebec, Law 25 enforces disclosure requirements for when employers make decisions exclusively through automated processes.13 However, considering Canada’s prior proposed federal law, it will be interesting to keep an eye on where the country is headed in the AI regulatory landscape in the coming years.

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East Asia

Taiwan’s new basic law, passed in December 2025, signals Asia’s shift from aspirational strategies to binding governance. The statute is built on seven core principles (sustainability, human autonomy, privacy, safety, transparency, fairness, and accountability) and codifies mechanisms for risk classification, verification, and accountability in high-risk applications.14

Critically, Taiwan balances innovation support (grants, regulatory sandboxes, tax incentives) with rights protection, reflecting a pro-growth-with-guardrails model increasingly common in the region. The aim of the bill is in part to support the positioning of Taiwan as an ‘Island of Artificial Intelligence’ that takes a responsible approach to AI development.15

China is currently undergoing a shift from a fragmented approach to AI regulation to a new, comprehensive law.16 Existing AI governance is divided into three central pillars: algorithm governance, content security, and data governance.17

A comprehensive law is still in the drafting stages by the State Council, but several other frameworks are already in place.

Effective since 2022, the Algorithm Recommendation Regulations Any algorithm that influences the information landscape must adhere to mandatory registration, labeling requirements, and user control features.18 In 2025, China rolled out new AI labeling rules (officially Administrative Measures for the Labeling of AI-Generated Content), requiring that AI-generated content be clearly identified via visible and technical identifiers when distributed on Chinese platforms.19 Back in April, the ‘Interim Measures for the Administration of Artificial Intelligence Anthropomorphic Interaction Services’ was introduced to govern human-like AI platforms (like chatboxes, virtual companions, and emotionally responsive digital assistants.20 These regulations are complemented by a list of others, including the Generative AI Measures and the Data Security Law.21

South America

Governments across South America have also made significant strides in the regulation space, many inspired by the EU model but tailored to regional development priorities and existing data protection frameworks.

Peru enacted the first AI law (Supreme Decree N.º 115-2025-PCM) in the region and is developing secondary regulations.22 Brazil’s Bill No. 2,338/2023 is the region’s most advanced proposal, establishing a risk-based framework and creating a national AI governance system coordinated by the Data Protection Authority.23 Chile has submitted a comprehensive AI bill to Congress.24 Argentina and Colombia have multiple proposals under review.25

All proposals share a human-rights-centered approach grounded in OECD AI Principles and UNESCO recommendations, emphasize innovation support through regulatory sandboxes and SME provisions, and rely on existing data protection laws as foundational.26 Regional variation reflects different policy priorities: Argentina explicitly positions AI as an economic opportunity; Brazil focuses on fundamental rights protection; Chile emphasizes democratic principles. The trajectory signals Latin America’s commitment to regulation that balances growth with rights protection, though institutional capacity and enforcement remain open questions.

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Sub-Saharan Africa

Africa is also strategically positioning itself as an active architect in the AI regulatory space. The April 2025 Global AI Summit in Kigali resulted in the Africa Declaration on AI (endorsed by 49 countries), creation of a $60 billion Africa AI Fund, and establishment of the Africa AI Council.27 The African Union’s Continental AI Strategy (2024) serves as the anchor framework, emphasizing seven priorities: talent, data, infrastructure, market, investment, governance, and institutional cooperation.28

By mid-2026, the regulatory landscape has shifted decisively. At least 17 Sub-Saharan African countries have published national AI strategies as of June 2026.29 Nigeria has had the most substantial shift in trajectory among the Big 4.30 Senate Bill 731, which will establish the National Artificial Intelligence Commission, has passed through to committee, and the proposed National Digital Economy and E-Governance Bill is said to be pushed through this year.31 Namibia is also advancing comprehensive AI legislation through draft bills on AI, data protection, and cybersecurity.32

The overarching approach across the region: leverage AI for digital transformation and socioeconomic development while building indigenous AI capabilities. A critical emphasis is developing AI in local languages. Nigeria is training multilingual LLMs in five indigenous languages. Kenya, Côte d’Ivoire, and Senegal are prioritizing linguistic preservation, recognizing that Western-trained models don’t reflect African contexts.33 Countries are adopting risk-based frameworks grounded in OECD, UNESCO, and NIST principles, prioritizing algorithmic bias mitigation, data sovereignty, transparency, and inclusion of underrepresented populations.

Also, a Cassava-Nvidia partnership will invest $720 million in an Africa AI Factory across five countries, signaling growing momentum but also highlighting reliance on external partnerships for critical infrastructure.34

MENA

The MENA region is rapidly emerging as a significant AI player, characterized by highly strategic, top-down approaches aligned with national visions like Saudi Vision 2030 and UAE Centennial 2071.

The regulatory model blends ‘soft law’ (ethical principles, guidelines, charters) with foundational hard law in data protection and cybersecurity.35 The UAE and Saudi Arabia lead with dedicated AI authorities (known as the UAE AI Office and SDAIA, respectively) and sophisticated governance frameworks. Israel has adopted a decentralized, sectoral approach. Iran prioritizes AI sovereignty and state control over content and misinformation.

Most countries are adopting risk-based frameworks inspired by the EU and OECD, though adapted locally.36 A defining emphasis across the region is data sovereignty, national security, and cultural alignment. The regulatory trajectory is clearly moving from soft law toward binding AI legislation. This phased approach allows governments to maintain agility while building formal legal foundations for high-risk applications and critical infrastructure.

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Looking ahead

What emerges from this global snapshot is not convergence toward a single rulebook, but rather a hardening consensus on how to regulate without convergence on what that regulation looks like. Risk-based frameworks and human-centric principles are now the core of AI policy. Yet the EU’s comprehensive approach, North America’s state-level patchwork, Africa’s development focus, and MENA’s strategic sovereignty emphasis point to a durable reality: AI governance will remain regionally distinct, tailored to local values and priorities.

This fragmentation creates immediate compliance complexity. A foundation model provider must now navigate the EU’s systemic risk requirements, Nigeria’s licensing regime, California’s frontier model transparency rules, Taiwan’s seven-principle framework, and MENA’s data sovereignty mandates, often simultaneously, for the same product. There is no global standard-setter that makes this work clear. The EU comes closest, but even its influence is selective: adopted where convenient, adapted where necessary, ignored where politically feasible.

For now, the baseline is clear: AI regulation is no longer aspirational. It is increasingly enforceable and regionally distinct. While it is a daunting challenge to regulate AI as quickly as its advancing, its a necessary step to protect people and the planet alike. Innovation and sustainability can and should be mutually enforcing.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

The issue isn’t that ESG rating is difficult. It’s that it has been entirely unregulated. Providers have been free to define their own methodologies, choose their own data sources, decide what counts as “environmental” or “social,” and, critically, issue ratings without disclosing how they got there. Investors have been making multi-billion-euro decisions on the basis of scores that are, in effect, proprietary black boxes.

That changes on 2 July 2026, when Regulation (EU) 2024/3005, the EU’s first dedicated framework for ESG rating activities, moves from being law on paper to law in practice.

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A Note on How EU Law Works: Regulations vs Directives

For those less familiar with EU legislative mechanics, this discretion is important. A directive sets a goal but leaves it to each member state to pass its own national law to achieve it, meaning timelines, enforcement, and detail can vary across the EU’s 27 members.

A regulation, by contrast, is directly binding across all member states the moment it applies, without any national transposition needed. No local parliament has to pass an implementing bill. It applies uniformly, everywhere in the EU, on the same date. Regulation 2024/3005 is just that: a regulation. On 2 July 2026, it applies in Frankfurt, Paris, Warsaw, and Dublin simultaneously, with no national opt-outs on scope or definition.

What Is Regulation (EU) 2024/3005?

Regulation (EU) 2024/3005, or the Regulation on the transparency and integrity of ESG rating activities, was adopted by the European Parliament and the Council on 27 November 2024 and published in the Official Journal on 12 December 2024. It entered into force on 1 January 2025 and becomes fully applicable on 2 July 2026.2

The regulation establishes a common framework to improve the transparency, integrity, independence, and governance of ESG rating activities across the EU. It places any ESG rating provider serving EU investors or companies under mandatory ESMA(European Securities and Markets Authority) authorisation and ongoing supervision.

The regulation also amends Article 13 of the Sustainable Finance Disclosure Regulation (SFDR, Regulation (EU) 2019/2088), requiring financial market participants and financial advisers that disclose an ESG rating to third parties as part of their marketing communications to publish the corresponding rating information on their website.3

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Why Does This Regulation Matter?

ESG ratings underpin much of the EU’s sustainable finance architecture. They feed into investment mandates under SFDR, inform asset managers building Article 8 and Article 9 products, and sit at the foundation of decisions worth hundreds of billions in capital allocation every year. When those ratings are produced without transparency or independence requirements, the entire edifice is built on unreliable data.

The regulation directly targets two systemic risks: greenwashing and social washing. By requiring disclosure of what is being assessed and how, it makes it harder for providers to issue favourable ratings without methodological accountability. For investors, it addresses a long-standing complaint about comparability. For rated companies, it creates a right to know the basis on which they are being assessed.

Key Definitions

The regulation is precise about what it covers. Here are key definitions on the terms heavily referenced throughout the regulation:4

ESG Rating: An ‘ESG rating’ is an opinion or score evaluating an item’s characteristics, risks, or impacts regarding environmental, social (including human rights), or governance factors. It is based on an established methodology and ranking system, regardless of the specific label (rating, opinion, or score) used.

ESG Opinion: An assessment based on a rule-based methodology and ranking system that directly involves a rating analyst in the evaluation process.

ESG Score: A data-driven metric generated purely by a statistical or algorithmic model, without significant input from a rating analyst.

ESG Rating Provider: A legal person that professionally issues, publishes, or distributes ESG ratings.

What Is the Scope?

The regulation applies to ESG rating providers issuing and distributing ESG ratings in the EU through subscriptions or other contractual relationships to regulated financial undertakings, regardless of where they are established.

EU-established providers must apply directly to ESMA for authorisation under Article 6 before offering services in the Union. Once authorised, they are subject to ongoing ESMA supervision, including its powers to investigate, require information, and impose sanctions.56

If non-EU providers wish to serve EU clients, they must access the market through one of three routes set out in Article 4, and cannot apply for ESMA authorisation directly:

• Equivalence (Article 10): the European Commission issues a decision confirming that the provider’s home jurisdiction meets standards equivalent to this regulation, after which the provider remains supervised by its home regulator rather than ESMA.

• Endorsement (Article 11): a non-EU provider within a corporate group that has an EU presence can have its ratings endorsed by the EU-authorised entity in that group, which then bears responsibility to ESMA for compliance. This route is only available to providers with an existing EU group structure.

• Recognition (Article 12): ESMA can directly recognise standalone non-EU providers without an EU affiliate, provided they appoint an EU legal representative to serve as ESMA’s point of contact.

Certain entities are excluded from scope, including regulated financial undertakings issuing ESG ratings as part of their existing regulated activities, providers whose ratings are used exclusively for internal purposes, and ESG ratings that form part of a purely private commercial transaction without wider distribution.

The regulation’s obligations span four areas: methodology transparency (Article 15 and Annex III), data source disclosure (Article 15), governance and conflicts of interest (Articles 19–22), and the rights of rated entities to access and contest the data used to assess them (Article 18).

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What Are the Core Obligations?

Once authorised, providers are subject to four substantive sets of requirements.

Methodology transparency. Providers must publicly disclose the methods, models, and key assumptions underlying each of their rating products, including which dimension of double materiality the rating addresses (whether it captures financial risk to the rated entity, the entity’s impact on environment and society, or both) and the weighting given to each E, S, and G factor (Recital 33; Annex III).7

Conflicts of interest. Providers must avoid situations of conflict of interest and manage them where unavoidable. Certain activities are prohibited from being offered within the same legal entity as ESG rating activities, including consulting, credit rating, and auditing. For other activities such as benchmarking, ESMA assesses whether the provider’s safeguards are sufficient. Providers must disclose conflicts of interest in a timely manner and maintain records of all significant threats to their independence.8

Governance and independence. Providers must employ adequate systems, resources, and written procedures to ensure their ratings are based on thorough analysis of all available relevant information, applied consistently and in accordance with their stated methodologies.9

Rights of rated entities. Providers must notify a rated entity before the first issuance of its rating. The rated entity can then request access to the dataset used and flag factual errors before publication. This is explicitly a fact-checking mechanism only; rated entities cannot influence methodology or rating outcomes.10

One obligation also extends beyond authorised providers to any regulated financial undertaking that discloses an ESG rating in its marketing communications. Where that happens, the undertaking must publish on its website the information set out in point 1 of Annex III, covering the methodologies used, data sources, limitations, the scope of E, S, and G factors assessed and their weighting, conflicts of interest, and reference to the Paris Agreement objective, among others.11

What Should Businesses Do?

ESG rating providers established in the EU face the most immediate compliance burden. Authorisation applications to ESMA require documented governance structures, methodology disclosures, and conflict of interest frameworks to be in place before submission. With the 2 July 2026 application date arriving quickly, providers already operating in the Union must notify ESMA by 2 August 2026 of their intention to continue, and submit a full authorisation application by 2 November 2026 at the latest. That window is shorter than it looks given the internal preparation required.

Non-EU providers serving EU clients need to determine now which of the three access routes applies to their structure. Providers within a corporate group that has an EU presence should assess whether endorsement under Article 11 is available. Standalone providers without an EU affiliate should begin the ESMA recognition process under Article 12, which requires appointing an EU legal representative. Providers relying on a future equivalence decision from the European Commission should be aware that no such decision has been issued for any jurisdiction to date, making this the least certain route to plan around.

Institutional investors and asset managers using ESG ratings to support SFDR-compliant product disclosures should audit their provider relationships against the authorisation register ESMA is building. From 2 July 2026, relying on an unauthorised provider’s ratings to substantiate a sustainable investment claim carries regulatory exposure. Checking provider status should become a standard element of due diligence.

Corporate sustainability and investor relations teams should be aware that the regulation gives rated entities the right to request the dataset behind their score and flag factual errors before publication.12

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Looking Ahead

The 2 July 2026 date is the very start of implementation. ESMA is still developing the regulatory technical standards that will fill in operational detail on disclosure formats, authorisation application content, and supervisory fee structures. Those standards will matter significantly for how the regulation functions in practice, and providers should monitor ESMA’s consultation schedule closely.

The equivalence regime remains entirely open. No Commission decision has been issued for any third country, which means the framework for how major non-EU markets like the US, UK, Japan will interface with this regulation is still unresolved. For global providers and their EU clients, that uncertainty is itself a compliance risk worth tracking.

Longer term, this regulation sits within a broader EU effort to make sustainable finance data trustworthy end to end. CSRD is reshaping what companies report. The Taxonomy Regulation defines what counts as sustainable. SFDR governs how financial products disclose sustainability claims. The ESG ratings regulation now adds oversight of the intermediaries who interpret all of that data and translate it into investment signals. The architecture is starting to become coherent, and for organisations still managing sustainability data across disconnected systems, that coherence is arriving faster than many anticipated.

The organisations that will navigate this landscape with least friction are those that have already consolidated their sustainability data into a single, audit-ready system. That’s exactly what Brightest is built for.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

Find Regulation (EU) 2024/3005 in full here: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024R3005

In this week’s newsletter, we cover five inspiring yet complex stories from around the world worth paying attention to.

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1. Clean Energy Takes the Global Lead

The Global Tipping Point

According to Ember’s Global Electricity Review 2026, renewables generated more than a third of global electricity in 2025, overtaking coal for the first time in over 100 years.1 The precise figures: renewables at 33.8%, coal at 33.0%. Solar alone met more than a quarter of the growth in global energy demand, the first time on record that a single modern renewable source contributed the largest share of energy demand growth in a given year.2

The trend behind the milestone is a decade in the making. Over the past ten years, the global share of renewables climbed steadily from 23% to nearly 34%, while coal slid down to 33%.3

The momentum is only accelerating. The International Energy Agency (IEA) projects that clean energy and nuclear power will combine to generate half of all global electricity by 2030.4

Country Scale: Italy

April 2026 marked a structural threshold for Italy: photovoltaics became the country’s largest renewable electricity source for the first time. Solar generation exceeded 5 billion kWh for the month, marking a 23.7% increase compared to April 2025.5 Renewables covered 49.5% of national electricity demand for the month. Italy’s total installed renewable capacity now stands at 85,928 MW, with solar accounting for 45,674 MW of that total.6

The Contested Landscape: United States

In the United States, the picture is more contested but the momentum holds. Despite significant federal policy headwinds, the US is on track to add 86 gigawatts of new power plant capacity in 2026 (more than any previous year) with clean energy comprising the overwhelming majority.7

More than half of the 20 largest clean manufacturing projects announced since August 2022 are on track for completion before the end of the year.8 Whatever policy turbulence follows, the grid will face it with considerably more clean capacity than it had two years ago.

2. The UN General Assembly Makes Climate a Legal Duty

On 20 May 2026, the UN General Assembly adopted a resolution endorsing the International Court of Justice’s (ICJ) landmark July 2025 ruling: that states have a legal obligation to protect the environment from greenhouse gas emissions.9

The ICJ’s advisory opinion, while not formally binding under international law, carries significant legal and moral authority. It clarifies that states which breach their climate obligations may be required to halt the wrongful conduct, offer guarantees against repetition, and make full reparation. The General Assembly resolution builds on that foundation, calling on all member states to implement emission reductions, follow through on Paris Agreement commitments, transition away from fossil fuels in energy systems, and phase out inefficient fossil fuel subsidies.10

For climate litigation globally, the practical significance is substantial. The advisory opinion is already likely to be cited across the thousands of climate-related cases working through national and international courts. As Joie Chowdhury of the Center for International Environmental Law observed, the resolution’s power comes from its “strong majority”, sending a clear signal that “governments remain committed to the rule of law, and to collective action to protect the climate.”11

• The Vote: 141 in favour, 8 against, 28 abstentions.

• The Opposition: Those opposing included the United States, Russia, Saudi Arabia, Iran, Belarus, Israel, Liberia, and Yemen.12

The opposition represents some of the world’s largest emitters and energy producers, and their absence from consensus matters for implementation. However, the international legal architecture has fundamentally shifted with a new, action-oriented precedent.

3. South Africa Turns Wastewater Into Green Methanol

In Gauteng Province, the Vaal region is the site of what will become South Africa’s first wastewater-to-green-methanol facility and an instructive model for circular industrial design. Climate Investor Three has committed up to $4 million in development funding to Green eFuels Producers to advance the project, with an expected start to commercial operations in 2029.13

The facility will be designed to process around 90,000 tonnes of municipal sewage sludge annually from the Sebokeng Wastewater Treatment Works. Nearby solar panels and wind turbines will power a massive machine that extracts clean hydrogen from water. This hydrogen is then used to create eco-friendly methanol fuel.

The projected output is approximately 14,300 tonnes of green methanol per year, avoiding an estimated 118,950 tonnes of CO-2-equivalent emissions annually.14 Each year, the plant will return up to 60 million liters (24 Olympic-sized swimming pools worth) of recycled industrial water to the local utility, providing a critical boost to a region suffering from water shortages.

Worth noting: Green methanol is increasingly viewed as a viable low-carbon fuel for maritime shipping, where hard-to-abate emissions have proven resistant to other decarbonisation pathways. A South African Green Methanol Corridor could place the country right at the intersection of waste management, green hydrogen infrastructure, and maritime fuel supply.15

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4. Croda Launches the “Beauty of Zero”

The beauty industry thrives off of vague buzzwords like “clean,” “pure,” and “natural.” But behind the scenes, the supply chains making your favorite skincare and cosmetics are notoriously complex.

Specialty chemicals giant Croda International is trying to push past the marketing fluff with “Beauty of Zero,” a new initiative designed to prove that zero-impact beauty manufacturing can be a commercial reality, not just a corporate aspiration.

Structured around six distinct pillars, the programme connects biotechnology-enabled ingredient innovation, renewable raw material sourcing, lifecycle data transparency, and biodegradable ingredient design into a single offer to the beauty market.16

The Six Pillars:

1. Net Zero

2. Zero Waste

3. Zero Biodiversity Loss

4. Zero Water Impact

5. Zero Exploitation

6. Zero Ambiguity

The “Zero Ambiguity” pillar deserves attention in its own right. In a market where sustainability claims frequently outrun measurable facts, a major global supplier committing to verifiable science and transparent lifecycle data forces a new level of accountability.

By mapping out the exact environmental footprint of their ingredients, Croda is giving beauty brands the hard data they need to back up their eco-claims.

“Customers are seeking high-performing ingredients that are backed by credible science, transparency, and measurable sustainability benefits,” says Sandra Breene, President of Consumer Care at Croda.17

Presented at the in-cosmetics global expo, this framework signals a shifting tide for consumer goods: the future of “clean beauty” is about supply chain transparency over aesthetic marketing.

5. Elephants Return to Eastern Zambia

Conservation wins rarely arrive without complication, and this one is no exception.

In 2022, the Malawian government, with support from African Parks and the International Fund for Animal Welfare (IFAW), relocated 263 elephants to Kasungu National Park, whose unfenced western boundary runs directly alongside farming communities in Zambia’s Chipangali and Lumezi districts.18 The elephants, absent from this landscape for more than 50 years after being hunted out in the 1970s, began crossing back over the border.

Mongabay tells the story that for local farmers, the return has been challenging. Two years ago, a herd broke through the wall of a family’s home to take nine bags of maize, a whole year’s supply. Other families face daily anxieties about their children walking to school unaccompanied.19

What makes this a success story is the scale of the response to balance conservation with community safety.

IFAW has fitted satellite collars to 31 elephant matriarchs, enabling near-real-time monitoring as herds approach farming areas. Community volunteers called Primary Response Teams (PRTs) are now first on the ground, warning villages and buying time before rapid response units arrive to move herds along. Solar-powered electric fencing and reinforced cement granaries are being distributed to the most vulnerable households.20

The Malawi-Zambia Transfrontier Conservation Area, established in 2015, frames the long view: a wildlife corridor reconnecting national parks across a landscape that was once continuous. For PRT member Joshua Ngwira, the work is as much about people as animals. Many farmers were angry and wanted retribution when he joined in 2024, but attitudes are slowly shifting. “As time goes by, they’ll begin to understand the true meaning of coexistence.”21

That shift will not happen on its own. It requires sustained investment in community infrastructure, local employment, and the kind of slow trust-building that does not show up on conservation dashboards. But it is underway.

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Final Thought

At first glance, a historic shift in global energy grids has very little to do with tracking elephants in Zambia or processing sewage in South Africa. But look beneath the surface, and a single, powerful mindset connects them all: institutions, businesses, and communities choosing to move toward something, not just away from something. These aren’t stories about simply running away from a climate crisis; they are stories about communities and industries actively building what comes next.

The macro landscape is changing as the UN’s landmark ruling gives climate accountability actual legal weight. The infrastructure is locked in as clean energy permanently eclipses coal. And industrial supply chains are shifting through the brilliant design logic of circular projects like Croda and South Africa’s green methanol, proving that we can take the waste of today and redesign it into the resources of tomorrow.

Yet, the elephant coexistence work in Zambia remains the most honest story of the bunch. It is exhausting, expensive, friction-filled, and deeply imperfect. But it is also precisely what a healthier relationship between humanity and the natural world requires.

These stories are a grounding reminder that beneath the sweeping legal rulings and energy milestones, the real work of healing our relationship with the planet is quiet, local, and deeply human. It asks us to look past the desire for a perfect ending and instead embrace the slow, necessary work of learning how to coexist.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

What is unfolding in the Netherlands right now is not a single policy story. It is a convergence of municipal law, national nutrition science, offshore wind ambition, and grassroots civic action that has been building across decades and is now arriving in concentrated form. The country still overshoots its fair share of planetary resources every April. Its nitrogen emissions remain four times the European average. But the mechanisms being put in place to close that gap are, increasingly, worth studying.

In this week’s newsletter, we look at what those mechanisms are, how they connect, and what they might mean for the businesses and governments watching from a distance.

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Amsterdam Becomes the First Capital to Ban Meat and Fossil Fuel Advertising

Amsterdam city council voted 27–17 in January 2026 to approve a legally binding ban on advertising for high-carbon products across all public spaces, covering flights, cruises, petrol and diesel vehicles, gas heating contracts, and meat. The ban has been in force since May 1st, though fines will not be issued until 2027 to allow operators time to adapt. Corporate branding from high-carbon companies follows in April 2028, when Amsterdam’s contract with JCDecaux expires.1

The move builds on a longer local history. In 2020, Amsterdam voluntarily removed fossil fuel advertising from its subway stations following a campaign by the Reclame Fossielvrij movement and a joint petition from more than 50 regional groups.2 The new law goes further, enshrining the ban in Amsterdam’s APV (the municipal regulation governing public order) and extending it to meat for the first time, recognising the sector’s significant but often overlooked greenhouse gas footprint.

Politicians behind the move say it is about aligning Amsterdam’s public spaces with its own environmental targets of carbon neutrality by 2050 and halving local meat consumption over the same period.3 It received predictable pushback from associations representing meat and fossil fuel producers, as well as advertising companies like JCDecaux, which argued that revenue from these ads helps maintain public infrastructure.4

Amsterdam did not act in isolation. The Hague introduced a legally binding fossil fuel ad ban in 2024, with Utrecht and Bloemendaal following in 2025.5 Twelve Dutch municipalities now have some form of restriction in place, and globally over 50 cities have announced similar ambitions. Amsterdam’s significance is symbolic as much as legal: a Dutch court already upheld The Hague’s ban as compatible with EU law, removing the principal barrier to adoption elsewhere.6 For sustainability and communications teams in consumer-facing businesses, the question is no longer whether this model will spread, but how quickly.

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The Wheel of Five Gets a Plant-Forward Overhaul

Mere weeks before the advertising ban took effect, the Netherlands Nutrition Centre published its first update to the national dietary guide, the Schijf van Vijf, or Wheel of Five, in a decade.7 The changes are significant: weekly meat intake cut from 500 to 300 grams, red meat capped at 100 grams, daily cheese halved, and legumes nearly doubled to 250 grams per week.8

What makes the update structurally new is its methodology. For the first time, dietary patterns were assessed not only for health outcomes but for greenhouse gas emissions, water use, and exposure to substances including PFAS and heavy metals.9 This puts planetary limits and food safety fused into a single national recommendation. The Health Council framed this explicitly as a protein transition, in that a more plant-based and less animal-based diet is better for health and benefits the environment.10 Dutch meat consumption hit a record low in 2025.11 The advertising ban and the dietary guidelines did not arrive in isolation. They arrived together.

The Netherlands is not alone in this direction. Germany updated its dietary guidelines in 2024 to emphasise plant-based protein;12 Denmark’s food authority has embedded carbon footprint data into its recommendations.13 That methodological step of adding the explicit integration of food safety indicators could become a template for the EU’s forthcoming farm-to-fork dietary guidance, currently under development.14 Businesses tracking EU food policy should watch how member states’ updated guidelines feed into that process.

A Commitment to Renewables

The Netherlands has been a pioneer in wind energy for centuries. Windmills once powered its mustard mills, sawmills, and polder drainage systems. The modern version is happening offshore. As of early 2026, the country operates 4.7 gigawatts of offshore wind capacity across more than ten active farms in the North Sea.15 The target is 21 gigawatts by 2032, rising to 70 gigawatts by 2050.16 This is an ambition that would make the Netherlands one of Europe’s largest offshore wind producers. Since 2017, the national rail network has run entirely on wind-generated electricity.17 On solar, the country punches well above its size: the Netherlands has more solar panels per capita than any other country in Europe.18

The Dutch government revised its 2040 offshore wind target downward in July 2025, from 50 gigawatts to 30–40 gigawatts, citing slower-than-expected industrial electrification and rising construction costs.19 It is an honest acknowledgment of the gap between ambition and delivery, but the direction of travel is unchanged. In January 2026, nine North Sea nations including the Netherlands pledged to jointly develop 100 gigawatts of offshore capacity by 2050, committing to shared infrastructure and security coordination.20

Greening From the Ground Up: Local Initiatives Across the Netherlands

Not all sustainability policy is written in parliament. In March 2026, Almere became the sixth Dutch city to sign the Plant Based Treaty, committing to raise the share of plant-based proteins in its diet to 60% by 2030, joining Amsterdam, Nijmegen, Groningen, Arnhem, and Haarlem.21 The commitment is grounded in practice: the city hall canteen already serves locally sourced, plant-based meals under a programme called “Future of Food,” and kitchen garden schemes are embedded in schools across the city.

At street level, the tegelwippen movement, created by Amsterdam creative agency Frank Lee during the pandemic, has grown into a national competition involving nearly 200 municipalities, in which residents remove paving slabs and replace them with greenery.22 Every Dutch citizen is legally permitted to lift slabs up to 50 centimetres from their house wall without seeking permission, and removed tiles are collected free of charge by Tegeltaxis, which also delivers plants. Around 13 million tiles have been removed since 2020, with the equivalent of approximately 235 football pitches of sealed concrete turned green. The movement has since crossed borders into Germany and Flanders.

Across the country, the pattern repeats at different scales. Rotterdam and Utrecht have converted more than 300 bus stop rooftops into flowering bee habitats.23 Utrecht spent two decades converting 1,500 metres of urban highway back into its original medieval ring canal, now a climate-adaptive green corridor through the city centre.24 Eindhoven distributed free “Energy Boxes” to households, which are kits containing insulation strips, radiator foil, and energy-saving tools, to tackle consumption and energy poverty in a single intervention.25 Small moves, large ambition, and a civic culture that does not wait for permission.

The Netherlands has long been famous for its biking scene. Bicycles account for 27% of all trips nationwide and bikes outnumber people, with roughly 23 million bicycles for a population of 17.8 million.26 Utrecht now records 51% of all journeys made by bike, the highest modal share in the country, while Amsterdam follows at 48%, more than double the number of car trips taken in the city.27 Cycling to work rose 57% between March 2024 and March 2025, the fastest growth of any transport mode, driven partly by a return to office working and the continued rise of e-bikes for longer commutes.28

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The Bigger Picture

The European Environment Agency’s 2025 Netherlands profile describes a mixed picture: air quality and circular economy indicators largely on track, nature indicators off track, climate progress real but insufficient.29

The tension underneath that assessment is specific. Since a 2019 Council of State ruling found nitrogen emissions were blocking permits for farming, construction, and renewable energy infrastructure, the Netherlands has been caught in a policy knot it has yet to fully untangle. Nitrogen emissions per hectare run at more than four times the European average, and over 40% of the country’s food-related ecological footprint comes from meat and dairy.30

The commitments elsewhere are genuine: full circularity by 2050, €2.1 billion earmarked for cycling infrastructure through 2030, a 100% zero-emission public bus fleet target by the same year.31 But the ecological footprint remains far above what one planet can sustain. The advertising ban and the dietary guidelines are two instruments aimed, in part, at that arithmetic.

Final Thoughts

There is a version of this story that is simply encouraging: a small, densely populated country making serious moves on food, energy, transport, and urban design simultaneously. That version is true, and worth celebrating. But the more useful version is the one that asks what it takes to replicate.

The Dutch did not arrive here through a single landmark law or a charismatic political moment. They arrived through the slow accumulation of municipal decisions, civic campaigns, scientific updates, and infrastructure investments, many of them contested. The advertising ban grew from a grassroots movement that began in subway stations. The dietary guidelines took a decade to update. The tile competition started as a creative agency’s idea. Offshore wind ambition is being revised downward even as it scales upward.

What holds it together is not a masterplan. It is a civic culture that keeps pushing, and institutions willing, eventually, to follow. That combination cannot be imported wholesale. But the individual instruments (legal ad bans, planetary limits in nutrition policy, community-led greening with government backing) can. The Dutch precedent now exists. The harder question is who picks it up next.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

On 11 May 2026, EU Directive 2026/805 entered into force. It tightens controls on PFAS “forever chemicals,” adds microplastics and antimicrobial resistance to mandatory EU watchlists for the first time, and expands the list of regulated water pollutants to include pharmaceuticals, pesticides, and bisphenols.1 For businesses that discharge into, draw from, or depend on European waterways, the compliance horizon just shifted.

What Is Directive 2026/805?

Directive 2026/805 amends three cornerstone pieces of EU water law: the Water Framework Directive, the Groundwater Directive, and the Environmental Quality Standards Directive.2 The Commission proposed it in October 2022, the Council adopted it in March 2026, and it was published in the Official Journal on 20 April 2026.3 It sits within the architecture of the European Green Deal and the Zero Pollution Action Plan.

Member states have until 22 December 2027 to transpose the amendments into national law.4 At that point, the new substance standards cascade into discharge permits, site authorisations, and environmental impact assessments. Monitoring programmes for the newly regulated substances must be operational by that same deadline.5

The European Chemicals Agency has been given a formal standing role in preparing future revisions to the pollutant lists, on a six-year cycle aligned with the EU water management cycle, with watchlist substances reviewed every three years.6 This institutionalises the expansion of the regulated substance list.

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Why Does It Matter?

The numbers set the scene. Only around 29% of EU surface water bodies currently achieve good chemical status.7 Some 46% of surface waters and 24% of groundwater fail to meet existing environmental quality standards.8 These are not distant environmental targets, they are the degraded baseline against which the new, tighter thresholds will be applied, and against which the next generation of enforcement will be measured.

For business, the most immediate risk is liability. The directive retains the polluter pays principle as the reference framework for cost allocation.9 Industries that discharge PFAS compounds or pharmaceutical residues into waterways should expect scrutiny to intensify as national monitoring programmes come online under the new rules. Companies carrying historic contamination exposure from legacy PFAS use in fire suppression, surface coatings, or industrial processes face a narrowing window to assess and remediate before regulatory visibility improves.

There is also a supply chain dimension that many compliance teams have not yet mapped. As member states update their River Basin Management Plans under the new framework for 2028–2033, industrial sites with poor discharge profiles will increasingly surface as sourcing risks.

What’s Covered and How It Works

The expanded substance list now includes a group of 25 PFAS “forever chemicals,” among them trifluoroacetic acid (TFA), a highly persistent, highly mobile compound found in rainwater and drinking water across Europe, and a breakdown product of widely used industrial refrigerants and agricultural pesticides.10 Pharmaceuticals, pesticides, and bisphenols are added to the priority substance list for the first time, with Bisphenol-A designated a priority hazardous substance.11

Microplastics and indicators of antimicrobial resistance appear on the EU water watchlists for the first time.12 Watchlist status means mandatory, systematic monitoring rather than immediate binding standards, but it is the established regulatory pathway toward hard limits. The data generated over the next three-year review cycle will determine whether these substances graduate to priority status.

The directive also introduces effect-based monitoring, which assesses the combined impact of chemical mixtures rather than measuring individual substances in isolation.13 This is a material shift. Meeting the standard for each individual regulated substance no longer guarantees compliance with overall chemical quality obligations. For facilities with complex discharge streams, this change alone warrants a review of existing environmental permits.

Six substances previously classified as major EU-wide risks have been downgraded to national concern lists, following evidence that earlier restrictions and bans have been effective. This is a signal that the framework responds to evidence, and that today’s watchlist additions could follow a similar trajectory in either direction.14

What Should Businesses Do?

Manufacturing and industrial operators should audit discharge profiles against the expanded substance list now, prioritising PFAS (including TFA), bisphenols, and pharmaceutical intermediates. Facilities using PFAS in coatings, fire suppression, or cooling systems should map pathways to waterways before national enforcement programmes are formalised after December 2027.

Data centre operators using PFAS-based immersion or two-phase cooling fluids should conduct a dedicated water discharge review. This is particularly urgent in water-stressed EU member states where abstraction and discharge constraints will be tightest and where regulators are most likely to act early.

Pharmaceutical companies are directly named in the expanded priority substance lists for the first time. The directive creates a regulatory pathway toward enforceable EU-level discharge limits for pharmaceutical residues, an obligation that did not previously exist at this level and for which most facility environmental management plans will need updating.

Supply chain and procurement teams across all sectors should begin incorporating water pollutant exposure into supplier assessments. The Urban Wastewater Treatment Directive (EU) 2024/3019, running in parallel, requires monitoring of PFAS in treated wastewater discharged into drinking water catchment areas, meaning industrial operators whose effluent flows through municipal treatment systems carry an upstream liability that sits alongside Directive 2026/805.

Non-EU suppliers to EU buyers should begin treating water pollutant exposure as a procurement risk, not just an environmental one. The Corporate Sustainability Due Diligence Directive (CS3D) requires large EU companies to identify and address adverse environmental impacts across their full value chains, including suppliers in third countries. As EU buyers tighten their water-related due diligence frameworks in response to Directive 2026/805, non-EU manufacturers, chemical producers, and agri-food suppliers should expect new contractual requirements around PFAS disclosure, discharge documentation, and water risk assessments to appear in procurement processes.

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Looking Ahead

The December 2027 transposition deadline is the operational trigger, not the finish line. Full compliance with the new environmental quality standards is not required until 2039, with possible extensions to 2045.15 But monitoring must be in place by 2027, and the data it generates will drive permit reviews, enforcement actions, and the next revision of the substance lists.

Two parallel processes will define the regulatory pressure beyond 2027. ECHA’s rolling review of watchlist substances, beginning with microplastics and AMR indicators, will determine whether these graduate to binding standards. Separately, the REACH-based PFAS restriction process, where ECHA’s sector-specific recommendation is expected by late 2026, is building regulatory pressure on water-relevant chemicals across multiple instruments simultaneously.16

The carbon transition gave businesses a decade of visibility. The water transition is moving faster, with a substance list designed to expand and enforcement architecture built to scale. Directive 2026/805 is not a ceiling, but rather a new floor. Water resilience is becoming a licence-to-operate question, and the time to treat it as one is now.

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The EU’s Carbon Border Adjustment Mechanism (CBAM) is designed to close that gap. After a two-year transitional period, the definitive phase launched on 1 January 2026. For importers of certain carbon-intensive goods, what was once a reporting exercise is now a financial obligation.

In this week’s newsletter, we explain what CBAM is, which goods and businesses it affects, what compliance now looks like, and what organisations should be doing to prepare.

What is CBAM?

CBAM is the EU’s tool for putting a fair carbon price on certain imported goods that reflects the cost EU producers already face under the EU Emissions Trading System (EU ETS).1

Under the ETS, European manufacturers must purchase allowances to cover the carbon emissions from their production processes. CBAM essentially extends the same logic to imports: if a product entering the EU was made in a country with weaker or no carbon pricing, the importer must pay for the carbon embedded in its production.

The mechanism was established by Regulation (EU) 2023/956, adopted on 10 May 2023. It was subsequently simplified and strengthened by Regulation (EU) 2025/2083, which entered into force on 20 October 2025 as part of the EU’s broader Omnibus package.2

CBAM sits within the EU’s Fit for 55 climate framework, which is the package of policies designed to cut the bloc’s greenhouse gas emissions by at least 55% by 2030 and reach climate neutrality by 2050.

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Why Does It Matter?

The CBAM addresses the problem where EU producers bear the cost of decarbonising while importers from less-regulated countries face no equivalent burden.

This not only disadvantages European industry, but it also does nothing to reduce global emissions. Rather, it simply shifts where they occur.

By applying a carbon cost at the EU’s border, CBAM aims to level the playing field and, over time, encourage cleaner industrial production in non-EU countries. As the OECD has noted, CBAM is also intended to signal to trading partners that the EU’s carbon price will apply to their exports, creating an incentive for them to introduce equivalent carbon pricing mechanisms of their own.3

The stakes are significant. When fully phased in, CBAM is expected to cover more than 50% of emissions in ETS-covered sectors.4

Which Goods are Covered?

CBAM currently applies to six sectors, selected for their high greenhouse gas emissions intensity and their particular risk of carbon leakage:5

• Iron and steel

• Cement

• Aluminium

• Fertilisers

• Hydrogen

• Electricity

The European Commission has already signalled that this list will grow. A legislative proposal published in December 2025 aims to extend CBAM to selected downstream products (goods with high steel or aluminium content, for example) from as early as 2028. That proposal is still subject to negotiation, but the direction of travel is clear.6

How Does CBAM Work?

From 1 January 2026, EU importers, or their indirect customs representatives, bringing more than 50 tonnes of covered goods into the EU each year must:7

1. Register as an Authorised CBAM Declarant with the National Competent Authority in their EU Member State.

2. Report embedded emissions. This includes direct and indirect greenhouse gases produced during the manufacturing process. Importers may use verified supplier data or high-end Commission default values.

3. Have those emissions independently verified by an accredited third-party verifier.8

4. Purchase and surrender CBAM certificates corresponding to the embedded emissions in their imports. Pricing is tied to EU ETS allowance rates, using quarterly averages for 2026 and weekly averages thereafter.9

Importantly, there are no certificate purchases in 2026 itself. The financial obligation is retroactive: importers will purchase and surrender certificates in 2027 for goods imported throughout 2026. But, the data being collected right now determines what those certificates will cost.

The first annual CBAM declaration is due by 30 September 2027.10

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The De Minimis Rule: Who is Exempt?

The 2025 Omnibus amendments established a de minimis exemption. Importers of 50 tonnes or less of covered goods per calendar year across all categories in aggregate are exempt from CBAM registration, reporting, and financial obligations.11

Note that hydrogen and electricity are excluded from this exemption and are governed by separate rules.

European Commission data shows this threshold exempts approximately 90% of importers while covering 99% of emissions from regulated goods. This simplifies compliance for smaller firms, though those near the limit must monitor cumulative annual volumes closely.

The Phase-In: What Happens Between Now and 2034?

CBAM’s financial impact scales gradually, mirroring the EU ETS phase-out of free allowances from 2026 to 2034.12 During this transition, an adjustment factor ensures certificates initially cover only a portion of emissions, with that proportion increasing each year. By 2034, the mechanism will require 100% coverage of embedded carbon costs.

As the financial burden intensifies annually, organisations establishing precise, verifiable emissions data processes now will be better positioned to manage rising costs.

What About Non-EU Producers?

While CBAM obligations sit legally with EU importers, the practical demands extend deep into global supply chains.

Non-EU suppliers must provide verified, installation-level production emissions data upon request. Failure to provide this documentation may force EU importers to use costlier default emission values or seek alternative suppliers.13

EU importers are already embedding CBAM data requirements into supplier contracts. For many non-EU companies, CBAM will be their first encounter with a binding emissions disclosure requirement. It is also likely to set a precedent for broader sustainability reporting expectations from European buyers.

What This Means for Business

The transition period is over, and the central takeaway is clear: carbon cost is no longer an externality, but a core component of the EU’s trade value chain. For businesses within scope, these are the immediate priorities to secure that chain.

EU importers above the 50-tonne threshold should secure Authorised CBAM Declarant status immediately, then shift focus from default emission estimates to primary supplier data. Accurate figures aren’t just a compliance requirement; they directly determine your financial exposure from 2027 onwards.

Non-EU producers should expect the data request from EU customers if it hasn’t arrived already: production-level emissions figures, verified and on record. Getting ahead of that conversation protects existing commercial relationships before declaration deadlines hit.

And the current scope is just the start. With CBAM set to expand to downstream products by 2028, carbon accounting is becoming a long-term strategic requirement, not a one-time compliance exercise.

The signal from Brussels is clear: the carbon embedded in goods entering the EU will carry a price, and that price grows through 2034.

Final Thoughts

CBAM is more than a customs mechanism, it’s a preview of where global trade is heading. As more regions look to the EU’s model, the ability to account for and communicate the carbon in your products is becoming a baseline business competency.

If you’re looking to better understand how CBAM may impact your business or supply chain, reach out to Brightest learn more.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

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Recognizing that steel production accounts for around 7% of global emissions, Dr. Sparrer saw both the scale of the challenge and a window of opportunity. With Germany’s and Europe’s transformation agenda and the steel industry committed to decarbonization, he realized that the real lever wasn’t just better materials and technologies, but also defining how to strategically bring these innovations to a broad rollout with policy helping to create market demand for it. The result is a strategic market architecture: procurement frameworks that reward green materials, fleet regulations that create industrial demand for green steel, and the establishment of standards on how to define green steel, like the Low Emission Steel Standard (LESS).

Source: Yannik Sparrer

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Why Steel Gets Overlooked

Steel rarely captures public attention the way energy and transportation do. Dr. Sparrer explains this simply: basic materials like steel aren’t perceived as “sexy”, but are used in so many products like phones, cars, buildings, data centres, or wind towers. More importantly, consumers directly engage with energy and transport, areas where they see the price changes and feel the impact. With steel, the connection is indirect; most people do not recognise the material steel but only notice it through their final product’s price tag. This distance makes the issue harder to grasp and easier to overlook.

“Steel accounts for around 7% of global emissions. If you could reduce this, you would have a significant impact on climate change and climate protection. So I thought, okay, it’s a tough one. But I saw an opportunity to create and shape transformation on a large-scale. The question was then how to create demand for low-emission materials produced here in Europe. One instrument to achieve this is lead markets developed together with industry leaders, policy makers, and NGOs.”

The Battle to Define “Green Steel”

One of the central challenges in decarbonizing steel is deceptively simple: what does “green” actually mean for a material as complex and diverse as steel? And more importantly, how do you translate that definition into market demand?

Establishing shared European transparency frameworks for steel emissions has proven far more complex than anticipated. The process demands genuine technical expertise: balancing interests across an entire industry while resolving highly specific questions about scope and technical methodology. Where does the standard boundary sit, or what emissions are considered? How should alloy elements and varying chemical compositions be accounted for? And should a single universal threshold apply, or are tailored criteria needed for different product types and production routes?

Dr. Sparrer has been at the centre of these discussions - navigating between technical feasibility, industrial reality, and the policy frameworks needed to create market demand and investment security for green steel production rather than a niche choice.

“Distinguishing between different product groups, different alloy compositions, and varying production routes proved to be critical and contentious questions to resolve. Today, the market is evolving with several approaches in play: Environmental Product Declaration (EPD), Product Carbon Footprint (PCF), or the Low Emission Steel Standard (LESS). LESS has emerged as one option, gaining traction among several significant players in the German and European steel industry.”

Source: Pixabay

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How green steel is produced

Steel production today follows two fundamental routes, each with its own decarbonization trajectory. Primary steel is produced in blast furnaces using coal as a reducing agent and fed to the basic oxygen furnace. The transition pathway here runs through Direct Reduced Iron (DRI), where first natural gas, later green hydrogen, replaces coal, feeding electric arc furnaces (EAF) that can run on renewable energy. Secondary steel, by contrast, is produced by melting steel scrap in EAFs. This route is already significantly less emission-intensive and can be further decarbonized, primarily by switching to green electricity, as well as modernizing downstream processing equipment.

Both routes face real challenges. Primary producers must invest heavily in entirely new process technologies while remaining competitive. Secondary producers depend on scrap availability and quality, which vary considerably across markets. In any case, the transition depends on renewable energies. German steelmakers are actively navigating both pathways, with investments underway across the industry. Steel producers in Germany and across Europe are demonstrating commercial viability and substantially reducing carbon emissions compared to traditional steelmaking.

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What makes the future of steel particularly interesting is the convergence of these two routes. Modern EAFs can flexibly adjust the scrap-to-DRI ratio, allowing producers to gradually shift their input mix. The boundary between primary and secondary steel is dissolving, and with it, a new generation of flexible, low-emission production is emerging at the heart of Germany’s industrial transformation.

Labels and standards like LESS or EPD empower steel customers to drive their own climate and circular economy strategies by offering standardized information on decarbonization level, scrap ratio, and carbon intensity (1). This transparency allows policymakers and corporate teams to make informed sourcing decisions and track their decarbonization progress. And because steel is highly recyclable, using scrap in electric arc furnaces conserves natural resources and reduces mining impacts.

Source: Pixabay

The Price Premium: a real barrier, but solutions must be found

Studies show that using green steel in a final product like a car increases the overall price by only about 1%. For steel-heavy products like offshore wind, the increase is around 4-5% (2). So if the cost barrier is minimal in key sectors like automotive, why isn’t the market shifting faster?

The answer lies in market dynamics and economics. Downstream industries operate under intense competitive pressure. OEMs sourcing green steel face rivals using conventional material at a lower cost. Construction companies work on thin margins where percentage-point differences in input costs could directly affect project viability. End customers currently have less purchasing power or willingness to absorb green premiums for attributes they cannot directly observe. These arguments are often brought forward when talking about the uptake of green steel. Consequently, there must be a smart policy in place to overcome this barrier.

“The German steel industry is still committed to decarbonization. There are investments, and companies are building new plants. But the question isn’t about willingness, it’s about market and political framework conditions. There are different problems now: global overcapacity – with a particular concentration in Asia – high energy prices, and weak demand. That makes it very hard for them to be competitive on the market. One opportunity to improve conditions would be creating demand through lead markets in sectors where price increase is negligible, and emission saving potential is high. Policymakers can tip the scales toward low-emission steel without market distortion.”

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Policy as the Accelerant

This is where standards become transformative. They create transparency and comparability, which policymakers need to craft smart incentives.

Governments can use public procurement as a strategic instrument to take off locally produced low-emission steel as defined through established standards, for example, in infrastructure projects, public buildings, railways, or defence projects. Every tender is a choice: procure the cheapest global option, or use purchasing power to achieve climate goals, strengthen Europeans industry, and accelerate the uptake of low-emission products.

Source: Pixabay

Another example is the proposed EU fleet regulation that offers a model: companies can offset some emissions by purchasing low-emission steel from European producers, thus reducing possible fines. A clear example of creating cross-sectoral incentives and tackling the barrier of the green premium.

These approaches work in tandem: public procurement creates predictable demand as an anchor buyer, while fleet regulations incentivize private markets to follow.

“We should not support with European public money building up green steel capacities in other parts of the world, but should really get things done here in Europe, ensuring climate neutrality and better resilience in the future. There’s a dependency in many supply chains. Therefore, we try to make the industry transformation possible here in Europe.”

The Role of Ecosystems in Bridging the Gap

What standards like LESS accomplish, and what drew Yannik to this work in the first place, is bridging the gap between technical feasibility and market reality. But it also requires a particular kind of industry and policy leadership: willingness to work together on challenges like climate change and competitiveness.

When Dr. Sparrer joined the German Steel Association, he grappled with this question directly: Did he really stand behind the topic and want to push it, or was it the image that lobby associations usually have? What he discovered was a delicate balance within an ecosystem: industry providing data and perspective, policymakers making decisions, NGOs holding everyone accountable.

“We try to support policymakers with data, with ideas, and with the voice of the whole industry. For policymakers, it’s quite hard to know what the industry thinks about a specific policy or legal framework. So, we provide that information. We’re a partner to NGOs and policymakers in public debate, really trying to push the mission this sector has: clean steel made in the EU.”

Source: Pixabay

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A Blueprint for Industrial Transformation

Yannik Sparrer’s journey from materials engineer to industrial transformation strategist illustrates a fundamental truth: solving climate change isn’t just about breakthrough technologies. It’s about creating the standards, policies, and market conditions that make low-emission choices inevitable and doing so through genuine alignment between industry, government, and civil society.

Steel may never command the public attention that electric vehicles or renewable energy do. But by making green steel the standard rather than the exception, through clear definitions and smart policies, Europe can decarbonize one of its most critical industries while building industrial resilience and avoiding the dependencies that have left other sectors vulnerable.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

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That’s not a new problem. Since 1994, the EU’s Packaging and Packaging Waste Directive (PPWD) has set the baseline rules. Still, a directive allows for national interpretation, and over three decades, it accumulated amendments while the waste kept growing.(2) The result: fragmented standards, uneven enforcement, and targets that couldn’t keep up with the scale of the crisis. The EU didn’t need another patch. It needed a reset. That reset is the Packaging and Packaging Waste Regulation.(3)

Source: EU Parliament Think Tank

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What Is the PPWR?

The Packaging and Packaging Waste Regulation (Regulation EU 2025/40, or PPWR) is the EU’s new unified legal framework for all packaging placed on the EU market. It entered into force on February 11, 2025, and will become generally applicable from August 12, 2026.

A key distinction from its predecessor: the PPWR is a Regulation, not a Directive, and that legal difference matters.(4) As a Regulation, it is directly binding across all 27 EU Member States the moment it enters into force, with no need for each country to write it into national law first.(5) That means no more waiting for slow or inconsistent national transposition, no more room for Member States to water down requirements.

The scope is intentionally broad. It covers all packaging materials (plastic, glass, paper, metal, wood) and applies to both B2B and B2C packaging, across the entire lifecycle, from design and production through to waste management.(6) It also applies to any organisation placing packaged products on the EU market, meaning non-EU companies exporting into Europe are fully in scope, as we explain below.(7)

Source: Sustainability Business Blog

In practice, the PPWR introduces five structural shifts:

• Full recyclability by 2030: All packaging must be designed to be recyclable in an economically viable way, with increasing minimum recycled plastic content requirements phasing in through 2030 and 2040 (articles 6 and 7 PPWR + source 8)

• Bans on harmful materials: PFAS (Per- and polyfluoroalkyl substances) restrictions in food-contact packaging apply from August 2026. Certain single-use formats, condiment sachets, hotel cosmetic miniatures, and on-site food service packaging are banned from 2030. (9)

• Reuse and consumer rights: Take-away businesses must allow customers to use their own containers at no extra charge. All packaging must carry harmonised labels showing material composition and sorting or return instructions, mandatory from 2028. (8)

• No unnecessary packaging. E-commerce packaging must stay within 40% void space from August 2026, with bans on double walls and false bottoms from 2030 (10)

• Extended Producer Responsibility. Producers, manufacturers, importers, and online retailers are financially and legally responsible for the full lifecycle of their packaging. EPR fees are modulated; the harder your packaging is to recycle, the more you pay. (11)

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Why Does It Matter?

Because the problem is bigger than most people realize, and the clock is already running.

Packaging accounts for roughly a third of all municipal solid waste in the EU, and half of all marine litter is packaging. (8) The sector is one of the most fossil fuel-dependent in Europe, generating as much CO₂ as an entire small country. And despite the old Directive being in place for 30 years, recycling rates across Member States remained wildly inconsistent, because every country got to decide how to meet the targets in its own way.

Image: Eurostat

The PPWR closes that loophole. It sets binding, measurable targets with no room for national interpretation: waste reduction of 5% by 2030, 10% by 2035, and 15% by 2040 compared to 2018 levels. (6) All packaging must be designed for recycling by 2030, recyclable at scale by 2035, and plastic packaging must meet minimum recycled content thresholds from 2030 onwards, increasing again by 2040, as mentioned above.

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Who Is Affected and What Do They Have to Do?

The short answer: if your business touches packaging in the EU, you’re in scope.

The PPWR creates a chain of responsibility that runs from the company that designs the packaging all the way to the one that ships the final product.

The PPWR creates a chain of responsibility that runs from the company that designs the packaging all the way to the one that ships the final product. Extended Producer Responsibility (EPR) obligations are now harmonised across all 27 Member States for the first time, ending the patchwork of national schemes that created compliance gaps and uneven costs across borders. To learn more about Extended Producer Responsibility (EPR), see [our previous newsletter].

In practice, here’s what each actor in the chain must do:

• Producers must cover the full costs of collection, sorting, and recycling. Their EPR fees will be modulated, meaning companies using packaging that is harder to recycle will pay more.

• Manufacturers must conduct a conformity assessment, issue an EU Declaration of Conformity, and keep technical documentation on file for five years, or ten years for reusable packaging

• Importers must verify that the conformity assessment exists before placing any product on the EU market

• Distributors must check that packaging meets EU rules and that everyone upstream has done their part

• Fulfilment service providers, including warehouses and logistics operators, must ensure their processes don’t render compliant packaging noncompliant.(12)

Source: Threadinmotion

What Should Companies Do Now?

The regulation is already in force. August 2026 is the first hard deadline, when the core provisions become binding. From that point, the clock starts ticking on the 2028 labelling requirements, 2030 recyclability and reuse targets, and 2035 and 2040 milestones.

August 2026 is closer than it sounds, and the 2030 deadlines require packaging redesigns and supply chain changes that take time to implement.

Start with a packaging audit. Map every packaging type you place on the EU market, identify your role under the regulation (producer, importer, distributor) and flag what doesn’t currently meet recyclability or labelling requirements. Check your EPR registrations across relevant EU markets, as non-compliance can already result in sales restrictions and backdated fees under existing national rules. Build data systems now to track recycled content percentages and report accurately as mandatory thresholds kick in.

The businesses that treat PPWR as a design opportunity rather than a compliance exercise will be better positioned for the decade ahead. Redesigning for recyclability, moving toward reuse systems, and cutting unnecessary material aren’t just regulatory checkboxes; they reduce costs, open access to EU markets, and reduce exposure to EPR fee modulation that penalises non-recyclable materials.

If you need support mapping your PPWR obligations or building a compliance strategy, reach out to Brightest to learn more.

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1. https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20251022-1

2. https://packagingschool.com/lessons/the-evolution-of-the-eus-packaging-and-packaging-waste-directive-ppwd

3. https://eur-lex.europa.eu/EN/legal-content/summary/packaging-and-packaging-waste.html

4. https://assets.kpmg.com/content/dam/kpmgsites/es/pdf/2025/02/legal.alert-ingles-reglamento-2025-envases-residuos.pdf.coredownload.inline.pdf

5. https://www.gleisslutz.com/en/know-how/new-eu-packaging-regulation-key-requirements-august-2026

6. https://www.ppwr-guidebook.eu/about-the-ppwr/

7. https://www.fieldfisher.com/en/insights/new-eu-packaging-and-packaging-waste-rules-10-key-things-every-global-business-should-know

8. https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en

9. https://www.khlaw.com/insights/new-eu-packaging-and-packaging-waste-regulation-highlights-and-challenges-ahead

10. https://www.gtlaw.com/en/insights/2025/8/eu-packaging-and-packaging-waste-regulation-new-compliance-requirements-for-e-commerce

11. https://www.simon-kucher.com/en/insights/eu-ppwr-demands-commercial-strategy-reset

12. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM%3A4806724

13. https://impactbuying.com/packaging-and-packaging-waste-regulation/

Extended Producer Responsibility (EPR) aims to change that. By shifting accountability from consumers and municipalities back to producers, EPR introduces a more circular approach where materials are reused, recycled, and thoughtfully managed throughout their lifecycle.

In this week’s newsletter, we explore what EPR is, why it matters, how legislation is evolving globally, and what organizations can do now to prepare for changes ahead.

What is EPR?

Extended Producer Responsibility is an environmental policy approach in which producers are held physically or financially responsible for the entire lifecycle of their products. This responsibility spans from sourcing and production all the way through to disposal.

What makes EPR particularly significant is its focus on the post-consumer phase. Under these frameworks, producers are not only responsible for creating and selling products, but also for managing what happens after those products are used. This can include funding or operating systems for collection, recycling, and disposal1.

In effect, EPR shifts the burden of managing end-of-life products away from consumers and municipalities and places it back on the organizations that design and profit from them. The ultimate goal is simple: reduce waste and encourage more sustainable product design.

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Why is EPR Important?

Put simply, the world has a waste problem and it’s growing rapidly.

Globally, more than 2 billion metric tons of solid waste are produced each year, with that number expected to increase significantly by 20502. While some of this waste is managed responsibly, a significant portion is not.

According to the United Nations Environment Programme, only about 62% of global waste is collected in controlled facilities. The remainder is often dumped, burned, or otherwise improperly handled, leading to widespread environmental and health impacts3.

One of the most common disposal methods worldwide is open dumping. These sites frequently release harmful greenhouse gases such as methane, contribute to air and water pollution, and pose serious health risks to nearby communities. In addition to these environmental concerns, there is also a growing physical constraint: space.

In the United States (the trashiest nation - producing over 12% of the world’s solid waste, despite having only around 4.5% of its population4), landfill capacity is becoming an increasingly pressing issue. The Solid Waste Environmental Excellence Protocol estimates that the country could exceed its current landfill capacity within just 18 years if current trends continue5.

Reducing the amount of waste generated in the first place is therefore critical. By incentivizing better product design, material selection, and end-of-life management, EPR can play a key role in mitigating environmental damage, conserving resources, and protecting public health.

Legislation on EPR

EPR is no longer a niche policy concept; it is rapidly becoming a global regulatory standard.

In the European Union, the Revised Waste Framework Directive entered into force in 2025, expanding EPR requirements across multiple sectors6. The updated directive goes beyond traditional focus areas like packaging, electronics, and batteries to include textiles and binding food waste reduction targets7.

Across Asia, several countries, including Vietnam, Japan, the Philippines, and Singapore, have already implemented EPR legislation, particularly targeting plastic packaging and container waste. Others in the region are actively developing similar frameworks, signaling continued momentum8.

Latin America is also making strides, with 11 countries now having some form of EPR legislation in place9. Notably, Mexico enacted its General Law on Circular Economy (LGEC) in January 2026, introducing mandatory EPR requirements nationwide10.

In the United States, progress is happening at the state level. Seven states – Maryland, Washington, Minnesota, Colorado, California, Oregon, and Maine – have enacted packaging-related EPR laws11.

Meanwhile, countries in Africa are also stepping forward. Kenya, for example, has introduced EPR regulations focused on plastic packaging, further underscoring the global reach of this policy approach12.

Taken together, these developments make one thing clear: EPR is not a passing trend. It is a foundational element of future environmental regulation.

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Preparing for Increasingly Strict EPR Regulations

As EPR requirements expand, organizations must ensure they remain compliant and competitive.

A critical first step is conducting a comprehensive audit of packaging materials and product components. Understanding what materials are used and how recyclable or reusable they are provides a baseline for improvement.

From there, companies can begin redesigning products with circularity in mind. This may involve selecting more sustainable materials, reducing unnecessary packaging, or designing products for easier disassembly and recycling.

Data will also play a central role. Robust tracking systems are essential for monitoring material usage, calculating compliance fees, and meeting reporting requirements. Without accurate data, organizations risk both financial penalties and reputational damage.

In addition, companies can optimize packaging through strategies such as lightweighting (reducing material use), switching to more sustainable alternatives, and conducting supplier audits to ensure alignment across the value chain.

Ultimately, the organizations that succeed in meeting evolving EPR requirements will be those that proactively integrate sustainability into their operations rather than treating compliance as a reactive exercise.

Final Thoughts

Extended Producer Responsibility represents a fundamental shift in how we think about waste, responsibility, and the lifecycle of products. By placing accountability on producers, EPR encourages more sustainable design, reduces environmental impact, and supports the transition to a circular economy.

As regulations continue to evolve across regions and industries, staying informed will be essential. Organizations that take early action will not only be better positioned for compliance but will also gain a competitive advantage in an increasingly sustainability-focused market.

If you’re looking to better understand how EPR may impact your business or need support navigating compliance, reach out to Brightest to learn more.

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This Week in Sustainability is a weekly email from Brightest (and friends) about sustainability and climate strategy. If you’ve enjoyed this piece, please consider forwarding it to a friend or teammate. If you’re reading it for the first time, we hope you enjoyed it enough to consider subscribing. If we can be helpful to you or your organization’s sustainability journey, please be in touch.

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