NWRA Sends Comments to SEC on Proposed Climate Change Disclosure Rule

NWRA Sends Comments to SEC on Proposed Climate Change Disclosure Rule

Arlington, VA – The National Waste & Recycling Association (NWRA) submitted comments to the U.S. Securities and Exchange Commission (SEC) regarding its proposed rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors. NWRA supported the intent of the proposed rule but noted certain circumstances could arise if left unaddressed.

“NWRA and its member companies are supportive and believe we play a critical role in the transition to a low carbon economy,” said NWRA President and CEO Darrell Smith. “We are not only doing our part to reduce greenhouse gas (GHG) emissions from our operations, but we also provide products and services that help our customers achieve their GHG reduction goals. We appreciate the opportunity to provide comments on the proposed rule and look forward to engaging with SEC on this issue.”

Among its concerns with the proposed rule, NWRA noted that there is not an accepted method to measure Scope 1 landfill GHG emissions as included in the proposed rule. NWRA recommended that SEC provide a safe harbor to landfill operators from liability as the methodology and measurement of fugitive landfill gases continue to evolve. NWRA also recommended that SEC allow certain companies to report their climate-related disclosures later in the year separate from the Form10-K filing or to disclose data for a given year on the Form 10-K for the following year.

NWRA also commented that disclosing board members with climate expertise could impact board governance structures, and initial compliance dates may not allow enough time for collection, analysis and disclosure of GHG data.


The National Waste & Recycling Association (NWRA) represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that manage waste, recycling and medical waste, equipment manufacturers and distributors, and various other service providers. For more information about NWRA, please visit www.wasterecycling.org.

Brandon Wright
National Waste and Recycling Association