The Environmental Protection Agency has repealed a landmark ruling that dates back 17 years and had asserted that carbon dioxide and other greenhouse gases are a danger to public health. This 2009 “endangerment finding” was an underpinning of the “Clean Air Act,” which allowed the government to place limits on the emissions that released by some of the most air-polluting industries.
- President Donald Trump called the repeal “the single largest deregulatory action in American history” and has referred to climate change as a “hoax” and a “scam.”
- Recent efforts to repeal the endangerment finding on scientific merits have come up short with the EPA defending it in 2021 and the Supreme Court denying to hear a case challenging it in 2023 after lower courts called arguments against the endangerment finding “flawed” and “without merit.”
- But EPA Administrator Lee Zeldin, who took the position in 2025, said Thursday that the repeal will end a “left-wing wish list of costly climate policies, electric vehicle mandates and other requirements that assaulted consumer choice and affordability.”
Where does this leave regulations going forward for industries such as branded merch? And how will the industry react?
- The most immediate impact will be seen on the automative industry where emissions restrictions are expected to be lifted.
- However, legal scholars have posited that the legal reasoning used to revoke the endangerment findings sets a clear precedent that will make it potentially futile for future EPA regimes to regulate CO2 emissions across most industries.
An important distinction to make when it comes to this conversation, and branded merch’s place within it, is that within advertising channels, merch is among the lowest carbon impact with a carbon footprint actually much smaller than digital. This was revealed in a global study conducted in collaboration between PPAI and ASI earlier this year.
There is plenty of context to these findings, but they reveal two key points by way of explanation:
- First, promo, by virtue of its lasting impact over time, can be inherently low impact from a carbon perspective.
- Second, there are many people and companies within the industry that have made it a priority to operate sustainably and lower their carbon footprint.
As covered in PPAI Magazine’s recent “Promo’s Sustainability Journey” article, this is the first presidential administration in a number of decades that is actively discouraging sustainable measures from businesses. This recent EPA repeal is larger evidence of that fact. It is not entirely unfair to question whether a scaling back in regulations will mean companies in branded merch shift their sustainability policies as a result.
PPAI Media reached out to a number of branded merch leaders for instant reaction to the EPA repeal of the endangerment finding and how they felt it affected the status of their company and the industry’s position on sustainability going forward.
Almost unanimously, the response was clear: The gains that branded merch has made in sustainability are unfinished. The momentum is too strong to be undone by policy.
‘Serious Companies Don’t Calibrate Their Sustainability Strategy Around Short-Term Political Shifts‘
Generally speaking, real momentum is not abstract. It is the product of building blocks, interactions and collisions within a space. One of the reasons that more companies in the industry have found progress in sustainability measures is because they are learning from each other, whether through actual sharing or from simply watching each other’s victories.
“Even with shifts in federal policy, many companies in our industry remain deeply committed to sustainability,” says Laura Smith, director of sustainability and compliance at Storm Creek, PPAI 100’s No. 33 supplier. “What I’m seeing is that the momentum toward lower‑impact materials, transparency and responsible supply chains is coming from within the industry itself. That focus isn’t slowing down. If anything, it’s becoming more strategic and solutions‑oriented.”
Laura Smith
Director of Sustainability & Compliance, Storm Creek
Joseph Sommer, CEO of Whitestone, PPAI 100’s No. 34 distributor, says that that there are more tools and resources than ever for companies to be able to make a measurable impact and contribute to a combined industry impact. Once companies start accomplishing goals they have set, they are less likely to pick up and abandon those goals on a whim.
“Sustainability shouldn’t depend on who’s in office,” says Sommer, a member of the PPAI Board of Directors. “With today’s tools and partners, even small and mid-size businesses can measure, reduce and offset their impact, making responsible action more accessible than ever. Whitestone’s SBTi validation reflects our belief that doing the right thing for the planet is ultimately a business decision that forward-thinking companies will continue to make regardless of policy shifts.
“And if each of us does our part, the collective impact can move entire industries forward, proving that a rising tide truly can lift all ships.”
Joseph Sommer
CEO, Whitestone
Indeed, according to Elizabeth Wimbush, CAS, PPAI’s director of sustainability and responsibility, while policy change like this has a significant material impact, it’s important not to conflate policy change with a shift in public opinion or steadily built ideological framework still accepted by the rest of the world. The U.S., for example, withdrew from The Paris Agreement in 2020 and then again earlier this year. These withdrawals, while dramatic, have not eliminated global goals for a carbon net zero future, which many U.S. businesses and consumers have committed to.
“Members are telling me they are still doing the work, some more quietly than before,” Wimbush says. “Research of other industries backs up the notion that there has been very little cutback on sustainability among businesses in the past year. [Two examples Wimbush provided are here and here]. Smart businesses require the transparency that comes with investigating efficiencies through carbon accounting and other standard frameworks and disclosures.”
Elizabeth Wimbush, CAS
Director of Sustainability & Responsibility, PPAI
Wimbush gets at an important factor: “smart business.” Many of the voices in this story may or may not have qualms with the administration’s decision and logic to repeal the EPA ruling from 2009, but their own sustainability policies have been tested against their company’s business strengths. They are policies that had already factored into all of their companies’ values and best interests.
“From a sustainability standpoint, repealing the EPA’s endangerment finding is a significant departure from well-established scientific consensus,” says Andrew Kelly, ESG compliance manager at Overture, PPAI 100’s No. 13 distributor. “That being said, serious companies don’t calibrate their sustainability strategy around short-term political shifts, and I don’t expect this to fundamentally change how industry leaders approach climate strategy.
“Many in our industry serve Fortune 500 brands with public climate commitments and Scope 3 reduction targets, so sustainability expectations in promo are more often flowing downstream from our clients, not upstream from federal policy. Large brands are accountable to global markets, investors and their consumers, who increasingly view greenhouse gas emissions as a long-term financial risk tied to resilience and value creation. Federal policy may influence the pace of change, but it can’t remove climate risk from the balance sheet.”
Andrew Kelly
ESG Compliance Manager, Overture
Sustainability is typically not a sector that yields a great deal of short-term results. To want to affect change means coming to terms with a long-term commitment. Heather Smartt, global head of Goldstar, PPAI 100’s No. 16 supplier, says her team doesn’t blink when the commitment is tested.
“While government policies may shift over time, our commitment to sustainability will not,” Smartt says. “Our focus on environmental responsibility is not a response to regulation or headlines, it’s part of how we support our industry and plan for the long term. We remain focused on reducing our operational impact and demonstrating our commitment to lowering our carbon footprint. This is rooted in responsible business practices, supporting customer expectations and simply doing our part as a team.
“As the branded merchandise industry evolves, we consistently see strong demand for responsibly sourced, lower-impact products, and we do not expect that to change. Sustainability is not a marketing trend or a buzzword for us. It is a choice, and the way we choose to do business.”
Heather Smartt
Global Head of Goldstar
The question of whether less regulation will mean less focus on sustainability is a misguided one in the case of HALO, PPAI 100’s No. 2 distributor, according to Terry McGuire, the company’s SVP and chief sustainability officer.
“HALO’s sustainability efforts are guided by the needs of our clients rather than politics,” says McGuire. “Our top clients are drawn to HALO because of the depth and vigor of our sustainability efforts, so this ruling will not change the focus and direction of our client-centric approach to sustainability.”
Terry McGuire
SVP & Chief Sustainability Officer, HALO
Robert Fiveash, co-founder and co-president of Brand Fuel, PPAI 100’s No. 29 distributor, elaborates on a similar point, suggesting that it’s not regulation but partners, clients and consumers that push sustainability onto businesses.
“I do not think this will change promo companies’ approach to sustainability,” Fiveash says. “Sure, some may feel like they can or should move away from sustainability because of these changes. But if you’re a supplier and you do this, know that the distributor marketplace will make its own choices. And if you’re a distributor and you do this, know that your clients will make their own choices. Today’s buyers care deeply about the health of the environment and our place in it. Decisions have consequences.
Robert Fiveash
Co-Founder & Co-President, Brand Fuel
PPAI Media also reached out to Mike Smith, CEO and founder of Aclymate, a PPAI-member business services provider that offers carbon accounting, reporting and certifications (Whitestone recently worked with Aclymate on some of its SBTi goals). In the big picture, Smith worries about this policy change’s effect on the public health as well as the general disorder it creates for regulatory environment work. In the short term, however, Smith says that state level and international regulatory policies have been driving decarbonization and that momentum won’t just vanish.
More specifically, Smith has worked directly with branded merch companies on these matters. He wouldn’t be surprised to hear many of the comments made by leaders stated above.
Mike Smith
CEO & Founder, Aclymate
“For the branded merch industry, I think this is largely irrelevant,” Smith says. “State and international regulations will continue to apply to the large contract end users of our products, who will in turn continue to require their supply chains to report and reduce their emissions, and this pressure will continue to build.”
That point was echoed by David Geiger, MAS, president of Geiger, PPAI 100’s No. 5 distributor, who emphasized that in the case of the Lewiston, Maine-based firm, sustainability is motivated by principles rather than federal regulation.
“From an industry perspective, in the absence of federal standards, compliance pressure is unlikely to disappear,” Geiger says. “We anticipate increased state-level action, creating a more fragmented landscape and increasing administrative complexity for companies. Navigating differing requirements across jurisdictions can be more complex and resource-intensive for businesses than operating under a single, uniform framework.
David Geiger, MAS
President, Geiger
“At the same time, consumer expectations continue to rise, with purchasing decisions increasingly influenced by values, transparency and environmental impact. For us, sustainability goes beyond compliance. It is a competitive differentiator and fundamental to how we build trust and create long term value in the marketplace.”
Nick McCulloch, director of ESG at PCNA, PPAI 100’s No. 5 supplier, points out that policy is one thing, but the industry is affected by climate issues no matter what’s happening in the government. It’s unavoidable, and some of the work that promo companies do with carbon tracking and information sharing is building the roadmaps needed to go forward.
“Regardless of shifts in federal policy, climate-related disruptions and costs are already showing up in supply chains and insurance. For promotional products companies with global sourcing, the practical move is to map exposure and build resilience now, on your timeline, before a crisis hits,” says McCulloch. “And as key markets like California, the EU and China advance sustainability disclosure expectations, credible data and strong risk management will still be essential for doing business.”
Nick McCulloch
Director of ESG, PCNA
McCulloch comes back to the same point that most of the voices above have echoed: Any notion of “doing the right thing” is matched by the business logic of sticking to your sustainability principles.
“At PCNA, we’re continuing to focus on sustainability because it’s good business. In 2024, we reduced our energy intensity by 12% and achieved a 20.5% reduction in Scope 1 and 2 emissions since 2022, alongside an 83% waste diversion rate at our Leed’s facility,” McCulloch says. “These efforts strengthen our operations and help ensure we can meet evolving expectations from customers and regulators, no matter how the policy landscape changes.”
