FAR Council Delivers Last-Minute Holiday Gift by Extending the Comment Period on Proposed Rule Imposing Mandatory Climate Disclosures for Federal Contractors
Client Alert | 1 min read | 12.23.22
On December 23, 2022, the Department of Defense (“DoD”), General Services Administration (“GSA”), and National Aeronautics and Space Administration (“NASA”) extended the comment period on the proposed rule, “Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk,” from January 13, 2023 to February 13, 2023. As we summarized previously, the proposed rule would, if finalized, require thousands of federal contractors to inventory and publicly disclose their Scope 1 and Scope 2 greenhouse gas (“GHG”) emissions, while further requiring “major” contractors to also establish and validate GHG emission-reduction targets tailored to the goals of the Paris Agreement.
The 30-day extension should be a welcome surprise to a wide range of contractors still attempting to unwrap the impact of this largely unprecedented proposal. Crowell’s team stands ready to assist in evaluating the implications and identifying issues worthy of comment.
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Client Alert | 6 min read | 11.25.25
Brussels Court Clarifies the EU’s SPC Manufacturing Waiver Regulation Rules
On November 13, 2025, the president of the French-speaking Brussels Enterprise Court ruled in the long-running battle between Sandoz and Regeneron about the correct interpretation of the EU’s Supplementary Protection Certificate (SPC) Manufacturing Waiver Regulation regarding exports to a non-EU market. The Brussels Court dismissed Regeneron’s claim that Sandoz had provided a defective notification and agreed with Sandoz’s interpretation of the Regulation.
Client Alert | 3 min read | 11.24.25
Client Alert | 7 min read | 11.24.25
Draft Executive Order Seeks to Short-Circuit AI State Regulation
Client Alert | 5 min read | 11.24.25
Qatar Enacts Law No. (22) of 2025 on Persons with Disabilities




