Fragmentation, expansion, new risks: how EHS regulation is being redrawn in 2026

EHS and sustainability professionals are managing a regulatory environment that is pulling in fundamentally different directions at the same time. Washington, D.C. is rolling back federal environmental obligations. States are rushing to fill the gap with their own rules. Globally, new obligations are expanding faster than most compliance programs can absorb them. And a category of workplace risk – psychosocial harm – that was once treated as a soft HR concern, is now showing up in hard law across multiple jurisdictions. 

Enhesa’s Expert Services Lead, Taylor Murphy, laid out this picture at Dakota Discover! 2026 in Fort Worth, Texas (15–17 April), and the conclusions are worth sitting with. The trends she identified are not isolated developments. They reinforce each other – and together, they have significant implications for how compliance programs need to be structured going forward. 

Federal rollback doesn't mean less compliance. It means more complexity.

The EPA’s rescission of the 2009 Endangerment Finding, effective 20 April 2026, is a genuine and significant federal rollback – it strips the agency of its statutory authority to regulate greenhouse gas emissions from vehicles and sets the stage for broader GHG deregulation. The proposed end of the Greenhouse Gas Reporting Program points in the same direction. 

For most multinational businesses, neither development reduces the compliance workload. They redistribute it – from a single federal standard that compliance teams could track centrally, to a growing patchwork of state-level requirements that each demand individual attention. Several states are already moving to fill the regulatory vacuum: state climate action bills (e.g. Pennsylvania, and Indiana) – each directing agencies to study climate impacts and identify harm-reduction measures in ways that closely mirror what the Endangerment Finding and GHG Reporting Program were designed to do at the federal level. 

A parallel shift is underway on sustainability reporting. California’s SB 253 is already in effect. New York, New Jersey, and Illinois are all advancing GHG disclosure bills of their own. Meanwhile, the federal SEC climate disclosure rule sits in legal limbo – neither enforced nor formally withdrawn – adding a layer of uncertainty on top of everything else. Here too, the federal-to-state redistribution of compliance complexity is the dominant story.Here too, the federal-to-state redistribution of compliance complexity is the dominant story. 

This is the structural shift that matters: compliance programs designed around a relatively stable federal framework are now operating in an environment where the action is happening at the state level, across multiple jurisdictions, on different timelines, with different thresholds. That requires a different kind of capability – not just more resources, but a fundamentally different approach to horizon scanning and regulatory monitoring. 

Producer responsibility is becoming the global default

If the US picture is one of fragmentation, the global picture is one of expansion. And what is striking about that expansion is how coherent its underlying logic is, even across very different regulatory systems. 

Take Extended Producer Responsibility. The EU, China, Brazil, and Uruguay have all moved – or are moving – to make companies responsible for what happens to their products at end of life. The EU’s amended Waste Framework Directive does it for textiles and footwear. Brazil’s Decree 12.688 does it for plastic packaging. Uruguay’s Decree 227/025 does it for batteries. China’s draft Ecological and Environmental Protection Law looks set to expand the principle further still. The specific rules differ. The direction does not. 

For compliance teams, the implication is not just that there are more rules to track. It is that a principle that was once confined to a handful of product categories in a handful of markets is becoming a default expectation globally. Companies that are still thinking about EPR as a Europe-specific issue are already behind. 

The same logic applies to climate disclosure. The EU continues to set ambitious targets – a proposed binding 90% reduction in net GHG emissions by 2040 – while adjusting the administrative machinery around CSRD and CSDDD to reduce burden without retreating from ambition. The direction of travel is clear, even where the implementation timelines are shifting. 

Producer responsibility is becoming the global default

If the US picture is one of fragmentation, the global picture is one of expansion. And what is striking about that expansion is how coherent its underlying logic is, even across very different regulatory systems. 

Take Extended Producer Responsibility. The EU, China, Brazil, and Uruguay have all moved – or are moving – to make companies responsible for what happens to their products at end of life. The EU’s amended Waste Framework Directive does it for textiles and footwear. Brazil’s Decree 12.688 does it for plastic packaging. Uruguay’s Decree 227/025 does it for batteries. China’s draft Ecological and Environmental Protection Law looks set to expand the principle further still. The specific rules differ. The direction does not. 

For compliance teams, the implication is not just that there are more rules to track. It is that a principle that was once confined to a handful of product categories in a handful of markets is becoming a default expectation globally. Companies that are still thinking about EPR as a Europe-specific issue are already behind. 

The same logic applies to climate disclosure. The EU continues to set ambitious targets – a proposed binding 90% reduction in net GHG emissions by 2040 – while adjusting the administrative machinery around CSRD and CSDDD to reduce burden without retreating from ambition. The direction of travel is clear, even where the implementation timelines are shifting. 

The risks hiding in plain sight

Perhaps the most telling indicator of how compliance is changing is what is happening in health and safety law – specifically, the rapid formalization of psychosocial risk as a legal obligation rather than a management aspiration. 

Norway, Japan, Singapore, Australia, Quebec, Brazil: across very different legal systems and cultures, regulators are arriving at the same conclusion – that stress, excessive workload, harassment, and burnout are workplace safety issues that require the same structured approach as physical hazards. Formal risk assessments. Documented prevention plans. In some cases, mandatory reporting. Norway moved first among this wave, requiring employers to assess psychosocial factors from 1 January 2026. Others are following quickly. 

In the US, OSHA’s federal heat rulemaking  is ongoing, though it could be halted if H.R. 6213 passes – a bill that would block the U.S. Secretary of Labor from finalizing, implementing, or enforcing the proposed federal heat illness standard. Meanwhile, states including Arizona, New Mexico, Massachusetts, Vermont, and Connecticut advance their own standards. The right-to-disconnect and shorter workweek bills moving through state legislatures in Kentucky, Maryland, Maine, New York, Massachusetts, and Pennsylvania tell a similar story: worker wellbeing is becoming a compliance issue, not just an HR one. 

For most compliance programs, this territory is genuinely new. Psychosocial risk does not fit neatly into existing frameworks. It requires different data, different expertise, and in many cases, different internal ownership. The companies building that capability now will be significantly better positioned than those waiting for the rules to fully crystallize. 

What this asks of compliance teams

Taken together, these three trends – US fragmentation, global EPR and disclosure expansion, and the formalization of psychosocial risk – point to a compliance landscape that is more complex, more dynamic, and more geographically dispersed than the one most programs were designed for. 

The traditional model – track the major federal and international frameworks, update when significant changes occur – is no longer sufficient. What is needed, instead, is the ability to monitor regulatory change continuously and at a granular level, across jurisdictions that are moving at different speeds; to identify the signal in a very noisy environment; and to translate emerging requirements into operational action before they become urgent deadlines. 

This is not simply a question of having more analysts or more software. It is a question of how compliance is positioned within the organization – whether it has the visibility, the resources, and the mandate to be genuinely anticipatory rather than reactive. As Taylor Murphy’s analysis at Dakota Discover! makes clear, the regulatory environment is not becoming less demanding. It demands something different. The programs that adapt to that will be the ones that hold up.