New Rules: How to Implement and Communicate Climate Strategy for Companies
2023 was a big year for climate action. We saw major announcements of new global governance and regulations across the world:
- In the US, California passed SB-253 Climate Corporate Data Accountability Act and AB-1305 Voluntary carbon market disclosures.
- In Europe, the European Commission released its Proposal for a Directive on Green Claims.
- Globally, new rules for the quality and use of carbon credits were issued ICVCM (The Integrity Council for the Voluntary Carbon Market) and VCMI (The Voluntary Carbon Markets Integrity Initiative), both receiving significant praise from global leaders at the most recent COP28.
At Terrapass, we’re excited by these developments. The world recognizes the need to significantly scale all climate solutions including voluntary carbon markets. For this we must have globally aligned standards. This came together on multiple fronts in 2023.
So, what does this mean for sustainability professionals and everyday consumers?
For everyday consumers this is great news. These regulations ensure that any climate accomplishments promoted by a business will be supported with details that clearly show how those claims were achieved. The rules also ensure that companies are actively working to reduce their own carbon emissions in addition to offsetting their remaining emissions. Please visit Terrapass for more information about your personal or small business carbon footprint.
For sustainability professionals the list of new rules and regulations might seem daunting, but it is also good news. This is a sign of a maturing industry. Policy and consumer experts are contributing their expertise to help make climate action impactful and understandable to both sustainability professionals and everyday customers.
Historically, professional sustainability terms like carbon neutral and net-zero often made their way into marketing and product messaging. Consumer advocates rightly recognized that everyday customers can’t evaluate these phrases on their own. Additionally, vague phrases like green, eco, and sustainable are often used to promote sustainability without any supporting information. Consumer advocates also recognized that customers must be able to see why a product is green. These new regulations in California and Europe ensure that climate communications are always factual and transparent. They ensure that companies can promote their sustainability accomplishments with confidence and that customers have information to evaluate those accomplishments.
New global governance, VCMI in particular, ensures that companies apply sustainability solutions in the most effective way. Terrapass has long promoted the principle of 1. Calculate, 2. Conserve, and 3. Offset in our sustainability guidance to customers. This approach prioritizes:
- First, understand where carbon emissions are in your business,
- Second, disclose your plan to reduce the carbon emissions of your business and regularly report progress, and
- Third, balance your remaining emissions with carbon credits that fund global emission reduction projects.
When companies describe their climate strategy, they sometimes combine these different elements into one term like “carbon neutral.” Phrases like this do reflect an important environmental achievement. However, they hide the distinction between your company’s emission reductions vs. global emission reductions funded through carbon credits. Emission reduction and offsetting must be separate elements of your sustainability strategy and they should also be separate elements of your climate communications. Key elements for your climate communications include:
Steps and priorities:
- Measure your carbon emissions, reduce emissions on a science-based trajectory, and disclose your progress publicly.
- Address your remaining emissions by funding high-quality carbon credits that help reduce greenhouse gases globally.
Tell two different stories in your climate communications:
- Business Emission Reduction: Our carbon footprint was 5,000 mT in 2023, a reduction of 500 mT vs. 2021 and 5% ahead of plan.
- Global Climate Contribution: We purchased 5,000 mT of carbon credits in 2023 to fund global carbon reductions equal to our remaining emissions.
Other considerations:
- Climate communications should be factual, specific and detailed; provide evidence of all environmental claims made.
- Talk about carbon credits as a way to balance your remaining emissions by funding global carbon reduction.
- Talk about carbon credits as a way to support other global sustainability goals (UN SDGs) when applicable.
- Avoid using vague, generic terms like green, eco, climate friendly, sustainable, etc. that are not substantiated.
- Avoid terms that combine your company’s emission reduction and carbon offsetting into one phrase like carbon neutral, climate neutral, etc.
Highlights from each of the new rules and regulations are provided below. Please contact a Terrapass sustainability advisor to help your company navigate its specific needs.
California SB-253 Climate Corporate Data Accountability Act
- For entities with total annual revenues in excess of $1,000,000,000 that do business in California:
- Starting in 2026: Report Scope 1 and Scope 2 greenhouse gas emissions
- Starting in 2027: Report Scope 3 greenhouse gas emissions
- Other requirements:
- For the reporting entity’s prior fiscal year
- Reporting is due annually on a date to be determined by the state board.
- Reporting follows the Greenhouse Gas Protocol
- Reporting entity must obtain an assurance engagement, performed by an independent third-party assurance provider, of the entity’s public disclosure as provided.
California AB-1305 Voluntary Carbon Market Disclosures
- Entities operating in California and making climate-related claims:
- Must publicly disclose information documenting how the claim was determined to be accurate or accomplished, and the measurement of interim progress.
- Applies to claims of net-zero emissions, carbon neutrality or similar, as well as claims of significant reductions in greenhouse gas (“GHG”) emissions,
- Entities operating in California and using voluntary carbon credits to support a climate-related claim.
- Must publicly disclose detailed information related to the credits purchased, the underlying offset projects and any independent verification of the climate-related claims made.
EU Green Claims Directive
- Applies to EU companies and non-EU companies making environmental claims aimed at EU consumers.
- Aims to eliminate greenwashing across EU markets by setting out detailed rules for how companies should market their environmental impacts and performance. It targets “vague, misleading or unfounded information on products’ environmental characteristics. “
- The current list of commercial practices that are banned in the EU is updated to include generic environmental claims – such as ‘environmentally friendly’, ‘natural’, ‘biodegradable’, ‘climate neutral’ or ‘eco’ – unless they can be properly evidenced.
- On the use of carbon credits specifically, the Green Claims Directive allows companies to make “carbon neutral” claims supported by carbon credits, but only if the carbon credits are disclosed correctly:
- Clearly state that carbon credits are being used to offset emissions.
- Disclose sources of emissions and amounts addressed with carbon credits.
- Identify carbon offset project types and distinguish between Reduction and removal offsets (requested, not required)
ICVCM (The Integrity Council for the Voluntary Carbon Market)
- New global quality standards for voluntary carbon credit projects; “regulatory-like”
- Program will be fully implemented over the course of 2023-2024.
- Rules for each carbon credit Category (Methodology/Project Type) were released in June 2023
- CCP-Eligible Programs (Registries) and CCP-Approved Categories (Project Types) will be announced in 2024.
- Not a one-time rule, standards will continuously evolve.
- First revision process for the CCPs in 2025, aimed at implementation starting in 2026.
- ICVCM points to VCMI for guidance on how businesses should use carbon credits.
VCMI (The Voluntary Carbon Markets Integrity Initiative)
- VCMI was established in 2021 to help ensure that voluntary carbon markets make a significant, measurable, and positive contribution to achieving the Paris Agreement goals.
- The VCMI Claims Code addresses market integrity on the demand side by guiding companies on:
- How they can credibly make voluntary use of carbon credits as part of their climate commitments, and
- The associated claims they can make regarding the use of those credits.
- The VCMI program should be followed together with ICVCM rules for high-integrity carbon credits.
Note: The above article provides introductory information only. Every organization must independently evaluate these rules and regulations, and determine specific actions needed for its own compliance.
Brought to you by terrapass.com
Written by Sam Tellen
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Carbon Footprint
Pentagon’s $1B Mineral Stockpile Boosts U.S. Independence from China
The Financial Times reported that the Pentagon plans to spend up to $1 billion on critical minerals. This move aims to cut U.S. reliance on China for essential metals in defense, clean energy, and advanced tech. Led by the Defense Logistics Agency (DLA), this program is the largest U.S. strategic mineral acquisition since the Cold War.
Significantly, the Pentagon’s plan is part of Trump’s broader “One Big Beautiful Bill Act” (OBBA) to enhance domestic and allied resources. Under OBBA, the DLA will use a $7.5 billion allocation to:
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Expand the U.S. stockpile by 2027 ($2 billion)
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Invest in mineral and processing supply chains ($5 billion)
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Launch a Pentagon credit program to support private mining and refining projects ($500 million)
Washington’s Strategic Push: From Market Reliance to State Control
China’s control over global mineral supply chains has raised national security concerns. The country refines 80–90% of rare earths and dominates other key metals, such as cobalt and nickel.
Recent Chinese export limits on rare earths have raised concerns in the U.S. Washington views these limits as an effort to weaponize mineral exports. The Pentagon’s stockpiling shows a move from market-driven sourcing to state-led resource security.
Trump Targets China with 100% Tariffs
As per the latest news, President Trump has confirmed plans to impose 100% tariffs on all Chinese imports starting on November 1. He labeled China’s export limits a “hostile act.” He noted the timeline might change, saying, “Right now it is. Let’s see what happens.”
On Truth Social, Trump accused Beijing of manipulating supply chains and warned of “100% tariffs… over and above any tariff they are currently paying.”
This tariff announcement follows China’s decision to limit rare earth exports. These actions link industrial policy more closely to national security.
Pentagon Boosts Stockpile with High-Value Minerals
According to the Financial Times, the Pentagon’s buying spree targets four key minerals vital for defense and clean energy:
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Cobalt – Up to $500 million. Used in batteries, superalloys, and medical implants.
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Antimony – About $245 million, partly sourced from U.S. Antimony Corp. Key for flame retardants, batteries, and defense components.
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Tantalum – Around $100 million. Essential for missile systems and aerospace parts.
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Scandium – A combined $45 million, reportedly from Rio Tinto and APL Engineered Materials. Used in aerospace alloys and electronics.
These purchases will expand the U.S. national stockpile, which already holds $1.3 billion in metals. The new acquisitions focus on materials critical for weapons production, energy systems, and high-tech manufacturing.
A defense official told the FT that several Pentagon offices are now “flush with cash” for mineral procurement. The government is also exploring offshore mineral resources in the Pacific Ocean, rich in nickel, cobalt, copper, and manganese.
Alaska’s Ambler Road Project Approval
President Trump approved the long-contested Ambler Road Project in Alaska. This 211-mile corridor will connect the Dalton Highway to vast mineral deposits in the northwest.
This decision reverses a Biden-era block and is seen as a vital step toward U.S. resource independence. It opens access to copper, zinc, and rare earth elements essential for clean energy and defense manufacturing.
Mineral Stockpiling: Shielding the Nation from Supply Shocks
The U.S. imports over 80% of its critical minerals and relies heavily on foreign refining, according to the U.S. Geological Survey (USGS). This dependence exposes the country to significant supply risks, especially amid rising geopolitical tensions.
The International Energy Agency (IEA) estimates that China controls 90% of rare earth refining and significant percentages of nickel and cobalt refining. Such dominance highlights the risk of relying on a single country for critical inputs.
Thus, to tackle these challenges, the U.S. is building a stockpile of critical minerals. This will reduce supply risks, maintain production of weapons and advanced technologies, and support domestic mining investment.
In short, this stockpile acts as strategic insurance, safeguarding industrial capabilities and boosting national security.
The U.S. aligns with a global trend in mineral stockpiling. The EU requires reserves under its Critical Raw Materials Act. India launched a National Mineral Security Strategy in 2025, while Japan maintains a months-long reserve of rare earths.
Minerals with Net Import Reliance on China

Market Impact and Industry Response
The Pentagon’s stockpiling effort has caught attention in mining and rare earth stocks. Companies like U.S. Antimony and MP Materials are gaining interest as Washington increases mineral procurement.
For example, the DLA’s plan for 3,000 tonnes of antimony—about one-eighth of U.S. annual demand—may stabilize the market for this volatile metal. Analysts expect similar effects for other targeted minerals as demand becomes clearer.
In conclusion, the Pentagon’s $1 billion mineral stockpile plan marks a clear shift. The U.S. government is no longer waiting for markets to secure resources. Instead, it is actively building reserves, funding domestic projects, and aligning economic policy with defense needs.
As competition for minerals increases, the Pentagon’s stockpiling is a defensive strategy and a clear signal. It shows that the next big race among global powers will be for critical minerals. These are vital for future technologies, not oil.
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Carbon Footprint
U.S. Green Hydrogen Cuts Give China an Edge in the Clean Energy Race
The United States’ push to lead in green hydrogen, once a centerpiece of its clean energy strategy, is slowing down. Recent policy changes by the Trump administration cut funding for hydrogen hubs. They also reduced tax credits for large-scale projects. Analysts say this slowdown could open the door for China to dominate the emerging market for low-carbon hydrogen technology.
The cuts mark a major shift from the previous administration’s investment-heavy approach. Under the Biden-era Inflation Reduction Act (IRA), the U.S. planned to spend billions to make hydrogen from renewable electricity. The goal was to decarbonize industries such as steel, cement, and chemicals, which are hard to electrify.
Now, with federal incentives being reduced or delayed, several projects are being reassessed. Developers worry that without consistent support, production costs will remain too high to compete globally.
Funding Cuts Stall the Hydrogen Hub Dream
In mid-2025, the U.S. Department of Energy began reviewing funding for several regional hydrogen hubs. These hubs were meant to create networks linking producers, users, and transport systems. Seven hubs were approved in 2023, backed by more than $7 billion in federal funding, but four are now facing cuts or slowdowns.
Industry groups warn that this could affect projects worth tens of billions of dollars. “Policy certainty is crucial for investors,” said one energy analyst cited in the Bloomberg report. “Every delay or rollback increases the cost of capital and slows deployment.”
The U.S. also faces uncertainty about the Section 45V hydrogen tax credit. This credit offers up to $3 per kilogram for hydrogen produced with near-zero emissions. The credit helped close the gap between costly green hydrogen and cheaper fossil-based hydrogen. Without it, the cost of producing green hydrogen in the U.S. could rise from $3 to $5 per kilogram to over $7, according to BloombergNEF estimates.
China Powers Ahead in the Hydrogen Race
While U.S. funding stalls, China is moving fast. The country already leads the world in electrolyzer manufacturing — the core technology used to make hydrogen from water. In 2024, Chinese companies supplied more than 65% of global electrolyzer capacity, up from just 40% in 2022.

China’s domestic market is also growing. The government has set a goal to produce 200,000 tonnes of green hydrogen per year by 2025 and up to 5 million tonnes by 2030. To support this, provinces such as Inner Mongolia and Hebei have started big solar-powered hydrogen plants.
China’s advantage lies in scale and cost. Electrolyser units made in China cost $600–$1,200 per kilowatt, far lower than the $2,000–$2,600 range typical in the U.S. and Europe. If current trends continue, the price difference might make Chinese-made equipment the top choice for global projects.
Rising Costs and Shrinking Margins
Hydrogen production costs remain the biggest obstacle to global growth. The International Energy Agency (IEA) estimates that low-carbon hydrogen made with renewables costs two to four times more than conventional hydrogen from natural gas.
Producing one kilogram of green hydrogen costs between $4 and $12. This varies based on electricity prices and how efficient the electrolyzer is. Grey hydrogen, made from natural gas, costs $1–3 per kilogram. Analysts say costs must fall below $2 per kilogram to compete in most industries.
Scaling up manufacturing and securing cheap renewable power are key. The IEA projects that with large-scale deployment, electrolyzer costs could fall by 60% by 2030. But this requires steady investment and policy support — something the U.S. may now struggle to sustain.
According to BloombergNEF, global investment in hydrogen production and infrastructure reached $24 billion in 2024, up 50% from 2023. China accounted for nearly half of that total, while U.S. spending slowed after federal policy reviews.
Companies Pivot Amid Uncertainty
Despite the funding cuts, some U.S. companies are pressing ahead. Plug Power, a leading hydrogen firm, recently secured a $1.7 billion loan guarantee to expand production. The company plans to build several U.S. facilities that will supply green hydrogen to logistics and industrial customers.
Meanwhile, developers are adjusting strategies to reduce costs. Some plan to co-locate hydrogen plants near wind or solar farms to secure cheap power. Others are exploring blending hydrogen with natural gas in pipelines to reduce emissions without full conversion.
Industry leaders also call for cooperation with allies. The European Union, for example, continues to fund green hydrogen projects through its Hydrogen Bank initiative. They argue that closer cooperation across the Atlantic could help Western producers compete with China’s growing supply chain.
The Global Hydrogen Race
The race for leadership in green hydrogen is as much about geopolitics as it is about technology. Countries view hydrogen as a way to cut oil imports, boost industry, and ensure energy independence.
In 2024, global hydrogen demand reached about 97 million tonnes, according to the IEA. Only a small share — less than 1% — came from low-carbon production. To meet the world’s climate targets, that share must grow to at least 20% by 2030.
BloombergNEF expects the global hydrogen market to surpass $500 billion each year by 2050. This includes production, storage, and transport. But success depends on which countries can bring down costs first and scale up faster.
If the U.S. loses momentum now, analysts warn, it may have to rely on imported technology later — particularly from China. The following table compares the costs, market share, and 2030 planned output between the two nations.
Can America Catch Up?
Green hydrogen is central to decarbonizing heavy industry and transport. It also supports renewable integration by storing excess power from wind and solar. Without continued investment, the U.S. risks missing key climate targets.
According to the Department of Energy’s earlier projections, hydrogen could cut up to 10% of U.S. greenhouse gas emissions by 2050 if widely adopted. That potential could shrink if projects slow or shift overseas.
At the same time, China’s expansion means more global supply, which could help reduce costs worldwide. Some analysts see this as an opportunity for global cooperation — if the U.S. can focus on innovation, efficiency, and regulation rather than pure scale.
The chart from Bloomberg below shows the potential changes under Trump’s current policy moves.

Experts say the U.S. can still recover its position with the right mix of policy and private investment. Restoring tax credits, simplifying permits, and investing in electrolyzer manufacturing can help create a fairer market.
For now, China appears to have the upper hand. Its rapid manufacturing growth and strong state support have created momentum that the U.S. may struggle to match. However, as clean energy technologies mature, global demand will likely outstrip any single country’s supply.
The coming years will decide whether the U.S. remains a key player or becomes a buyer in the green hydrogen market it once hoped to lead.
- FURTHER READING: Element Resources to Build America’s Largest $1.85B Green Hydrogen Plant in California
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Carbon Footprint
Fentanyl Threats, AI, and National Security – ARMR Sciences’ Unified Approach
* Disseminated on behalf of ARMR Sciences Inc.
* For Accredited Investors Only. Offered pursuant to Rule 506(c). Reasonable steps to verify accreditation will be taken before any sale.
PAID ADVERTISEMENT – SPONSORED CONTENT
Fentanyl is devastating American communities at a record pace, with more than 220 deaths every day. Synthetic opioids accounted for over 70,000 U.S. fatalities in 2023, and their impact now extends beyond public health into national security.
At the same time, artificial intelligence (AI) is advancing in ways that could allow adversaries to design new synthetic drugs or bioweapons faster than regulators and security agencies can respond. Coupled with the political weight fentanyl carries in Washington, the U.S. faces a multidimensional challenge.
ARMR Sciences underscores why prevention, innovation, and leadership can align to shield America from this emerging and evolving threat.
Escalating National Security Concerns
Fentanyl’s extraordinary potency – up to 50 times stronger than heroin – makes even trace exposure lethal. Its supply chains cross borders, complicating law enforcement and fueling instability at home.
ARMR Sciences emphasizes that enforcement alone cannot resolve the crisis. Without proactive prevention strategies, the nation risks a deepening cycle of addiction, death, and weakened resilience.
Technology at the Crossroads
AI has the potential to transform healthcare and logistics, but also carries risks of misuse. Researchers showed that advanced AI models could generate tens of thousands of psychoactive compound blueprints in just hours – a dangerous acceleration of synthetic chemistry.
National security leaders, including AI pioneers, warn that adversaries could exploit these tools. ARMR Sciences argues for robust biodefense strategies that include strict controls on sensitive algorithms, enhanced detection systems, and proactive investment in prevention technologies.
Political Pressure and Policy Response
The fentanyl crisis has become a defining issue in U.S. politics, shaping debates on border security, healthcare, and law enforcement funding. Deaths have risen by more than 20% annually since 2019, amplifying public and political demands for action.
ARMR Sciences emphasizes that bipartisan cooperation and evidence-based policymaking are essential to prevent partisan gridlock. Recognizing fentanyl as both a health and security issue can unite leaders behind more effective prevention measures.
ARMR Sciences – A Prevention-Focused Framework
Across each dimension – fentanyl’s deadly toll, AI’s potential misuse, and the political battle for solutions – ARMR Sciences underscores a common theme: prevention is the most effective defense. This means deploying early warning systems, advancing detection capabilities, integrating data-driven tools, and strengthening community resilience before crises escalate.
It also means ensuring that AI innovation develops with responsible guardrails, while national security agencies adapt to evolving synthetic threats. Prevention is not passive; it requires deliberate action, investment, and leadership.
So, Why Should Investors Pay Attention to ARMR’s Solution?
For investors, ARMR represents an opportunity to back a company working to address the convergence of fentanyl’s deadly impact, AI’s potential misuse, and the urgent need for prevention.
Its platform is built on years of defense-backed research and is advancing innovative biotechnology programs:
- Seven years of DoD-supported science established the foundation of ARMR’s platform
- Lead candidate ARMR-100 blocked 92% of fentanyl from entering the brain in preclinical (animal) studies
- A $30M private raise is currently underway
- Plans for a targeted exchange listing in 2026 are in place, subject to market conditions
By investing in this round, investors have a chance to support ARMR as it works to build a potentially category-defining role in AI-powered biodefense.
* This is a paid advertisement for ARMR’s private offering. Please read the details of the offering at InvestARMR.com for additional information on the company and the risk factors related to the offering.
* For Accredited Investors Only. This offering is made pursuant to Rule 506(c) of Regulation D. All purchasers must be accredited investors, and the issuer will take reasonable steps to verify accredited status before any sale. Investing involves high risk, including the potential loss of your entire investment.
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CAUTIONARY STATEMENT: Certain statements in this presentation (the “Presentation”) may be deemed to be “forward-looking statements” within the meaning of Section 27A of the 1933 Securities Act and Section 21E of the Exchange Act of 1934, as amended, and are intended to be covered by the safe harbor provisions for forward-looking statements. Such forward-looking statements can be identified by the use of words such as ”should,” ”may,” ”intends,” ”anticipates,” ”believes,” ”estimates,” ”projects,” ”forecasts,” ”expects,” ”plans,” and ”proposes.” Forward-looking statements, which are based on the current plans, forecasts and expectations of management of ARMR Sciences Inc. (the “Company” or “ARMR Sciences”), are inherently less reliable than historical information. Forward-looking statements are subject to risks and uncertainties, including events and circumstances that may be outside our control.
Although management believes that the expectations reflected in these forward-looking statements are based on reasonable assumptions, there are a number of risks and uncertainties that could cause actual results to differ materially from such forward-looking statements. Risks and uncertainties that could cause actual results to differ materially include, without limitation, those risks identified in the Private Placement Memorandum. Forward-looking statements speak only as of the date of the document in which they are contained, and ARMR Sciences Inc. does not undertake any duty to update any forward-looking statements except as may be required by law.
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ARMR Sciences Inc. takes no responsibility for any forecasts contained within the Presentation. None of the information contained in any offering materials should be regarded as a representation by ARMR Sciences Inc. The Company’s forecasts have not been prepared with a view toward public disclosure or compliance with the guidelines of the SEC, the American Institute of Certified Public Accountants or the Public Company Accounting Oversight Board. Independent public accountants have not examined nor compiled any forecasts and have not expressed an opinion or assurance with respect to the figures.
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