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BIS Contemplates Export Restrictions on "Electronic Waste" to Combat Supply Chain Concerns

Client Alert | less than 1 min read | 10.23.18

On October 23, 2018, the Department of Commerce Bureau of Industry and Security (BIS) published a notice seeking comments on imposing export control restrictions on electronic waste in response to concerns that unregulated recycling of electronic waste is a source of counterfeit goods. BIS has proposed to define electronic waste, prohibit electronic waste export, establish electronic waste exemptions, and require an export license to ship exempted electronic waste abroad. The Bureau is seeking public comment until December 24, 2018 on all aspects of the proposal including the definition, methods of tracking exported electronic waste, costs, and the likely effectiveness of the regulations.

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Client Alert | 3 min read | 02.26.26

FERC Requires Refunds for Late QF Recertification

On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners. ...