Audit, Compliance and Risk Blog

On February 26, the European Union’s (EU’s) European Commission issued its “Omnibus I” proposal to “recalibrate” the EU’s Corporate Sustainability Reporting Directive (CSRD), by reducing reporting requirements and excluding smaller entities.  The CSRD was adopted in November 2022 and took effect in January 2023 (I wrote about it HERE), providing reporting requirements that are being phased in during 2024-2028. CSRD superseded and narrowed the EU’s previous Non-Financial Reporting Directive (NFRD; which I discussed HERE). The remainder of this note discusses the proposed changes. 

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Lead and lead-containing materials are among the longest-used materials in construction and industry. Lead has been used in commercial, residential, and ceramic paint; in electric batteries and other devices; as a gasoline additive; for weighting; and other purposes. It also has been recognized as toxic to human health and the environment at least since the Romans, although understanding of the extent and severity of lead hazards has improved greatly in recent decades. Accordingly, environmental, occupational and public health agencies have progressively tightened standards to reduce lead exposures. On August 1, 2023, the Environmental Protection Agency (EPA) proposed to tighten post-remediation clearance levels as low as “non-detect.” The rest of this note discusses EPA’s latest proposal, and provides some context and background.

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