Current Status Updates & Regulatory Developments
The US environmental regulatory landscape is undergoing significant transformation in 2026, characterized by federal deregulatory actions and increased state-level environmental protection efforts. Major policy shifts are reshaping climate regulation, environmental review processes, and enforcement priorities.
February 18, 2026
The Environmental Protection Agency published a final rule that revoked the agency's interpretation of the Clean Air Act that found that greenhouse gases could be regulated as pollutants. The EPA first made the interpretation of the Act, known as the 'endangerment finding,' in 2009.
Because the 2009 endangerment finding served as the legal basis for federal greenhouse gas standards for vehicles, rescinding it reshapes the federal government's approach to climate regulation under the Clean Air Act.
Legal Challenges: On Feb. 18, the American Public Health Association and 16 other groups filed a lawsuit in the U.S. Court of Appeals for the District of Columbia challenging the final rule. Environmental organizations have already filed lawsuits arguing that rescinding the scientific basis for climate regulation under the Clean Air Act undermines federal authority to regulate greenhouse gases at all.
January 8, 2026
The Council on Environmental Quality (CEQ) published a final rule removing the CEQ regulations implementing the National Environmental Policy Act (NEPA) from the Code of Federal Regulations. The Trump administration finalized a plan to roll back regulations implementing a landmark environmental law, rescinding regulations related to the National Environmental Policy Act, which requires federal agencies to consider a project's possible environmental impacts before it is approved.
Republicans and many Democrats believe the 56-year-old law has become mired in red tape that routinely results in yearslong delays for major projects. The law requires detailed analysis for such projects and allows for public comments before approvals are issued.
Ongoing - 2026
The EPA is prioritizing rolling back emission rules for cars and trucks, planning on reconsidering two Biden-era vehicle emission rules in 2026—one that called for tighter emission restrictions on light- and medium-duty vehicles and one, also called the Clean Trucks Plan, that required cuts to the emissions of nitrogen oxides from heavy-duty engines and vehicles. Both rules apply to vehicles of model years 2027 and later.
January 2026
The EPA will no longer consider the economic cost of harm to human health from fine particles and ozone, two air pollutants that are known to affect human health. The change was written into a new rule recently published by the agency. The EPA writes in its regulatory impact analysis for the new rule that, for now, the agency will not consider the dollar value of health benefits from its regulations on fine particles and ozone because there is too much uncertainty in estimates of those economic impacts.
March 2026
For the fourth time in the last ten years, the US Environmental Protection Agency (EPA) has proposed to modify its Risk Management Program (RMP) regulations. EPA will hold a public hearing on the proposed modifications on March 10, 2026, and is accepting written public comment on the proposal through April 10, 2026.
The stated purpose of the proposed changes is to reduce regulatory burdens, avoid duplicative requirements, eliminate unnecessary burdens placed on facilities where there is not specific data supporting the efficacy of current RMP requirements to reduce accidental releases, and bolster economic growth.
March 5, 2026
The U.S. Environmental Protection Agency (EPA) published a proposed rule to amend the hazardous waste manifest regulations to establish a sunset date for phasing out the use of paper manifests and requiring electronic versions. The EPA believes that switching from paper manifests to only electronic versions will save up to an estimated $28.5 million annually, resulting from the decreased burden to manifest users.
Trump administration finalizes plan to roll back NEPA regulations, ending what it calls the "regulatory reign of terror."
CEQ final rule removing NEPA implementing regulations becomes effective, requiring agencies to develop their own procedures.
EPA publishes final rule rescinding the 2009 greenhouse gas endangerment finding. Legal challenges filed immediately.
Department of Interior NEPA implementing regulations take effect, establishing new DOI NEPA Handbook procedures.
EPA extends greenhouse gas reporting deadline from March 31 to October 30, 2026, for reporting year 2025.
EPA proposes hazardous waste electronic manifest rule and delays Clean Water Act Facility Response Plan requirements until 2030.
EPA scheduled to hold public hearing on proposed Risk Management Program modifications.
U.S. climate policy in 2026 is defined by federal regulatory reversals and assertive state action. Federal rollback of climate regulations has increased the importance of state-level policies. Many states and local jurisdictions are pursuing their own independent, ambitious clean energy and emissions goals.
California is widely expected to continue shaping environmental policy in 2026 through its regulatory authority over vehicle emissions, energy systems, and industrial standards.
California enacted a wide-ranging slate of environmental and climate legislation in 2025 and in prior years, with many of the resulting requirements taking effect in 2026 that will impact companies operating in or doing business with the state. These developments span climate disclosure and financial reporting, greenhouse gas regulation, energy and fuel markets, California Environmental Quality Act (CEQA) reform, and public health and safety standards.
Key California Initiatives:
Multiple states have enacted legislation to address environmental regulation in the absence of federal leadership:
The chemical industry itself has pushed back on this move. Industry leaders have argued that after years of investing in compliance infrastructure and adjusting operations to meet emissions requirements, they prefer regulatory stability over another round of uncertainty. Companies that initially opposed the finding have since incorporated the required changes and don't want the disruption of yet another reversal.
Despite regulatory upsets at the federal level, demand for climate policy expertise remains robust, particularly in roles involving compliance, regulatory design, litigation, and state policy development. Climate policy jobs are found in law firms, consulting practices, non-governmental organizations, and corporate sustainability teams. The shift toward state-driven initiatives further diversifies the opportunities available.
As 2026 begins, the legal and regulatory outlook for per- and polyfluoroalkyl substances is defined less by sweeping federal initiatives and more by incremental adjustments, judicial guardrails and state-driven regulations — an environment in which proactive risk management and close monitoring of policy developments will be essential.
Recent Supreme Court decisions have fundamentally reshaped environmental regulation. The overturning of Chevron deference means federal agencies no longer receive judicial deference when interpreting their enabling legislation, creating significant uncertainty for existing regulations.
Environmental groups, public health organizations, and state attorneys general are actively challenging federal rollbacks through the courts. Litigation is expected to determine the ultimate scope and implementation of many 2026 regulatory changes.
Courts and administrative law will shape environmental governance and climate careers. Lawyers, policymakers, environmental professionals, and students studying climate law must navigate overlapping regulatory priorities, litigation, and shifting authority.
Understanding current developments requires knowledge of the foundational environmental laws being affected:
Federal law regulating air emissions from stationary and mobile sources, overseen by the EPA. The endangerment finding rescission directly impacts CAA implementation.
Establishes the structure for regulating discharges of pollutants into U.S. waters and quality standards for surface waters.
A cornerstone of environmental law in the United States, enacted to ensure that federal agencies consider the environmental impacts of their actions. This landmark legislation requires federal agencies to prepare detailed Environmental Impact Statements (EIS) for major projects that could significantly affect the environment.
Governs the disposal of solid and hazardous waste, including the e-manifest system being expanded in 2026.
Gives EPA authority to require reporting, record-keeping, testing requirements, and restrictions relating to chemical substances.
Environmental law and policy in 2026 is highly dynamic. Stakeholders should closely monitor Federal Register notices, court dockets, state legislative sessions, and EPA announcements for the latest developments. Professional organizations and legal resources provide ongoing analysis of regulatory changes and their implications.