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California Issues Notice of Enforcement Discretion for Climate Reports under SB 253

By Sheila Millar & Anushka R. Stein on December 19, 2024
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On December 5, 2024, the California Air Resources Board (CARB) published a notice of enforcement discretion under SB 253, the Climate Corporate Data Accountability Act, which requires U.S. companies that do business in California and that have total annual revenues in excess of $1 billion to report all of their Scope 1, Scope 2, and Scope 3 greenhouse gas emissions annually. CARB is mandated by the law to promulgate implementing regulations, and the initial Scope 1 and 2 emissions reports are due in 2026 on a date yet to be determined by CARB. 

The notice informs covered entities that CARB will exercise its enforcement discretion to allow reporting entities to submit Scope 1 and 2 emissions reports based on information the reporting entity “already possesses or is already collecting at the time this Notice was issued.” CARB notes that reporting companies may not have time to transition to new data collection and reporting practices for the first reporting cycle. Thus, the agency will not take enforcement action for incomplete reporting during the first reporting cycle, provided that the reporting entity demonstrates a good faith effort to comply with SB 253 and retains all data relevant to emissions reporting for the prior fiscal year.

CARB does, however, warn that the December 5 notice is intended only for the transition period, and the agency encourages businesses “to use this period to move toward full compliance as quickly as possible.” CARB plans to provide details on reporting for subsequent years through its rulemaking process.

Photo of Sheila Millar Sheila Millar

Sheila A. Millar is a partner at Keller and Heckman LLP, where she represents businesses and trade associations on a variety of public policy and regulatory issues, including privacy, data security, cybersecurity and advertising matters, as well as product safety issues. She has…

Sheila A. Millar is a partner at Keller and Heckman LLP, where she represents businesses and trade associations on a variety of public policy and regulatory issues, including privacy, data security, cybersecurity and advertising matters, as well as product safety issues. She has been involved in a variety of audit and compliance projects, including, among other issues, privacy and data security audits, and is experienced in providing crisis management legal support to a variety of national and international companies and associations.

Ms. Millar is a frequent speaker on regulatory and public policy matters, and has authored many articles. Ms. Millar is one of the vice chairs of the International Chamber of Commerce (ICC) Marketing and Advertising Commission, and chair of its Working Group on Sustainability, where she spearheaded the development of the ICC Framework Guides on Environmental Marketing Claims.

Ms. Millar is AV® PreeminentTM Rated by Martindale-Hubbell and for the eigth consecutive year was selected by her peers for inclusion in The Best Lawyers in America® 2018 for her work in practicing Advertising Law. She has also received the distinguished honor of Advertising Law “Lawyer of the Year” 2014 in Washington, DC by Best Lawyers®, and was awarded Advertising and Marketing Lawyer of the Year USA by Finance Monthly for their Finance Monthly Global Awards 2017.

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Photo of Anushka R. Stein Anushka R. Stein
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  • Posted in:
    Environmental and Climate
  • Blog:
    Consumer Protection Connection
  • Organization:
    Keller Heckman
  • Article: View Original Source

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