Other Notable Developments

EU’s 2035 Emissions Reduction Target: The EU has published a statement of intent indicating it will submit its Nationally Determined Contribution under the Paris Agreement ahead of COP30 in November. According to the statement, the EU expects to commit to a greenhouse gas emissions reduction target of between 66.25% to 72.5% by 2035, compared to 1990 levels.

Singapore’s Nature-Based Carbon Credits: Singapore’s Climate Change Secretariat and Ministry of Trade and Industry announced that they will contract high-quality nature-based carbon credits from four projects in Ghana, Peru and Paraguay. The credits will contribute to Singapore’s target of net zero emissions by 2050.

Global: United Nations “High Seas Treaty” Reaches Ratification Threshold

On September 19, 2025, Morocco and Sierra Leone ratified the Agreement on Marine Biological Diversity of Areas Beyond National Jurisdiction (the “BBNJ Agreement”), becoming the 60th and 61st ratifying parties, respectively, thus meeting the threshold for the BBNJ Agreement to enter into force.

The BBNJ Agreement was adopted in June 2023 under the umbrella of the UN Convention on the Law of the Sea. It applies to the high seas and the seabed beyond national jurisdiction, which make up two-thirds of the ocean. Its stated aim is to “ensure the conservation and sustainable use of marine biological diversity … for the present and in the long term.”

The BBNJ Agreement introduces a number of rights and obligations on contracting parties, including:

• states’ obligation to share any marine genetic resources, which may be used in scientific research, with other states;

• states’ obligation to conduct environmental impact assessments prior to conducting certain activities that may adversely impact the high seas or seabed; and

• states’ power to designate certain areas as “marine protected areas,” which would limit certain activities within the designated area for conservation and sustainable use purposes.

The BBNJ Agreement will enter into force on January 17, 2026.

Links:

Press Release

On September 23, 2025, the European Commissioner for the Environment confirmed that the Commission was considering further delaying the implementation of the Regulation on Deforestation-free Products (the “EUDR”) to December 2026. 

The EUDR imposes supply chain due diligence requirements on qualifying businesses trading in cattle, cocoa, coffee, palm oil, soya, rubber and wood. The requirements also apply to a wide-ranging list of products derived from these goods, including paper, chocolate, leather and meat products. Broadly, the EUDR requires in-scope businesses to ensure that their supply of goods does not cause deforestation or forest degradation in the European Union and globally.

Initially scheduled to take effect in late 2024, the implementation of the EUDR was postponed for 12 months in October 2024 due to concerns that businesses would be unable to comply with its requirements (for more information regarding this initial delay, see our previous ESG Update here). Separately, in April 2025, the Commission proposed reducing the scope of the EUDR by removing certain products, including waste, secondhand and used products, together with packing materials suitable for multiple uses and used to protect other products, from its scope.

This most recent postponement is due to IT system inadequacies, which could result in businesses being “unable to register as economic operators, introduce their Due Diligence Statements […] or provide the necessary information for customs purposes where relevant.”

The additional postponement must be approved by the Council of the European Union and the European Parliament through the ordinary legislative process.

Link:
Letter of Jessika Roswall, dated September 23, 2025


China: China Announces First Absolute Emissions Reduction Goal

On September 24, 2025, President Xi Jinping announced China’s first emissions reduction target via video at the United Nations Climate Summit, taking place in New York. As part of China’s new Nationally Determined Contribution (“NDC”) under the Paris Agreement, Xi declared that, by 2035, China will “reduce economy-wide net greenhouse gas emissions by 7% to 10% from peak levels.” In addition, Xi said China will commit to:

• increase the percentage of non-fossil fuels in China’s total energy consumption to more than 30%;

• expand China’s wind and solar power capacity to more than six times the country’s 2020 levels;

• increase China’s total forest stock volume to over 24 billion cubic meters;

• make electric vehicles the prevailing choice in new car sales; and

• expand the National Carbon Emissions Trading Market to cover major high-emission sectors.

This is the first time that China has committed to reduce, rather than simply limit, its greenhouse gas emissions. China’s target, however, is significantly below that of other countries, including Australia (62% and 70% reduction below 2005 levels) and Switzerland (65% reduction below 1990 levels).

Link:
Text of Xi’s UN Climate Summit Speech


U.S.: CARB Releases Preliminary List of Covered Entities Under California’s Climate Disclosure Laws

On September 24, 2025, the California Air Resources Board (“CARB”) published a preliminary list of covered entities under California’s Climate Corporate Data Accountability Act (“SB 253”) and Climate-Related Financial Risk Act (“SB 261”).

CARB created the preliminary list, which includes more than 4,000 entities, by matching a proprietary dataset to the California Secretary of State’s registered business data. The list is comprised of United States-based entities doing business in California that meet SB 261’s annual revenue threshold of at least $500 million. The preliminary list is intended to support the development of the fee regulation under the disclosure laws. (For additional background on California’s climate disclosure laws, see our Debevoise Update and ESG Updates here and here.)

CARB indicated that the list is provisional in nature, noting that (i) the Secretary of State’s dataset lists only active filers through March 2022 and may be missing companies and (ii) the preliminary list does not consider potential exemptions discussed at CARB’s August 21, 2025 public workshop. (For more on CARB’s August 21 public workshop, see our ESG Update.)

CARB encourages potentially covered entities to conduct an independent assessment regarding their compliance requirements and, regardless of whether they are included on the preliminary list, they will be responsible for their compliance with statutory requirements. CARB further encourages entities that believe they are subject to the reporting requirements, or believe they qualify for an exemption, to complete CARB’s preliminary list feedback survey. (For more on CARB’s preliminary list, please see our Debevoise Debrief.)

Links:
Announcement: Preliminary List of Reporting
Preliminary List Feedback Survey

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