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DoD Proposes Significant Amendments to the DFARS Data Rights Scheme

Client Alert | 1 min read | 06.27.16

On June 16, 2016, DoD issued a proposed rule to amend the DFARS to implement section 815 of the National Defense Authorization Act for FY 2012, which made significant changes to the data rights scheme for DoD contracts. Among other things, the proposed rule permits the release of “segregation and reintegration” technical data and computer software outside of the government (subject to restrictions), even when the item, component, or process to which that data pertains or the computer software was developed exclusively at private expense; expands DoD’s ability to order technical data and computer software post-award; doubles the time period in which DoD may challenge asserted data rights restrictions; and expressly imposes no time limit on DoD’s right to challenge fraudulently asserted restrictions.

Insights

Client Alert | 7 min read | 03.06.25

European Commission’s Proposed Omnibus Simplification Package: What Are the Main Changes for Importers of CBAM Goods?

On 26 February 2025, the Commission proposed a sustainability simplifications package, commonly referred to as the Omnibus package. Among the sustainability reporting and due diligence provisions, the Omnibus package would also bring about changes to the EU’s unilateral environmental measure, the carbon border adjustment mechanism (CBAM). CBAM entered into application in its transitional phase in October 2023 and is now halfway towards its definitive implementation. The proposed deregulation brings about improvements in several CBAM areas, including scope, and reporting and procedural requirements. In this alert, we outline those suggested amendments that are likely to be of most importance to businesses involved in trading in CBAM goods....