Regulatory Compliance updates August 2025

August 31, 2025

The Commission (EU) has set the date for the launch of the EES at 12 October 2025

The European Commission has set 12 October 2025 as the date for the gradual launch of the EU's Entry/Exit System (EES). It will collect biometric data such as fingerprints, facial image and other travel information, gradually replacing the current passport stamping system. Link

European Commission released updated guidance for the EU Deforestation Regulation

Article 15(5) of Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010 (hereinafter referred to as EUDR) sets out that the Commission may develop guidelines in order to facilitate harmonized implementation of the Regulation.

This guidance document is not legally binding; its sole purpose is to provide information on certain aspects of the EUDR. It does not replace, add to or amend the provisions of the EUDR, which establishes the legal obligations. This guidance document should not be considered in isolation; it must be used in conjunction with the legislation and not as a ‘stand- alone’ reference.

This guidance document is, however, useful reference material for anyone who must comply with the EUDR as it further clarifies dedicated parts of the legislative text, meaning it can guide operators and traders. It can also guide national competent authorities and enforcement bodies as well as national courts in the process of implementing and enforcing the EUDR. The issues addressed in this document were discussed and developed in cooperation with designated representatives of the Member States. Additional issues can be addressed once there is more experience in applying the EUDR, and in this case the guidance document would be revised accordingly.

For all issues addressed in this guidance document it should be noted that in accordance with Recital (43) the definitions of the Regulation build on the work of the Food and Agriculture Organization of the United Nations (FAO), the Intergovernmental Panel on Climate Change (IPCC), the United Nations Environment Programme (UNEP), and the International Union for the Conservation of Nature (IUCN).

The second edition of the guidance document improves clarity, including on application timelines, precision of the provisions for operators and traders, facilitating simple and efficient due diligence and traceability. Source: European Commission

EU postpone the implementation of due diligence policies for battery manufacturers

Regulation (EU) 2025/1561 of the European Parliament and of the Council amending Regulation (EU) 2023/1542 as regards the obligations of economic operators regarding battery due diligence policies has been published. The main change introduced by Regulation 2025/1561 is to postpone the date of application of these obligations from 18 August 2025 to 18 August 2027, which is intended to give more time for battery manufacturers to adapt their supply chains and to notify conformity assessment bodies. At the same time, the publication date of the Due Diligence Guidance has been postponed from 18 February 2025 to 26 July 2026. The regulation also highlights the need to harmonise economic due diligence with Directive (EU) 2024/1760 on the elimination of adverse impacts on human rights and the environment in supply chains. The document aims to support the proper functioning of the EU internal market and to reduce the negative impact of batteries on the environment and human health, while maintaining a high level of public health protection.  The regulation enters into force on 31 July 2025 and is directly applicable in all member states. Link

EU: Critical Milestone Achieved in the Proof of Union Status (PoUS) Project

The Proof of Union Status (PoUS) Project has achieved an important milestone by launching phase 2

  • Success of Phase 1: Digitizing Trade Documentation

The Proof of Union Status (PoUS) Project has successfully implemented Phase 1, introducing the T2L/T2LF data as a proof of the customs status of Union goods. Launched on 1 March 2024, this phase significantly improved trade processes by replacing paper-based documentation with electronic data. Today, the central PoUS system is adopted by traders across all Member States, having processed and registered over 660,000 proofs of Union status for goods to date.

  • Launch of Phase 2: Streamlining Maritime Trade (15 August 2025)

On 15 August 2025, the PoUS Project has reached a milestone with the launch of Phase 2, which implements the Customs Goods Manifest (CGM). This enhancement enables traders to manually submit proof of Union Status requests for sea-transported goods via the PoUS Specific Trader Portal (PoUS STP) in the form of CGM/CGMF data.

  • Future Integration with Maritime National Single Windows (MNSW)

Once the Maritime National Single Windows (MNSWs) are fully operational in Member States, traders will be able to submit CGM/CGMF data automatically through these platforms. MNSWs will then forward the data directly to the PoUS system. This integration will significantly benefit maritime traders handling high-volume cargo by streamlining data exchange and accelerating customs procedures.

  • Commission Support and Monitoring

The European Commission remains committed to ensuring the smooth operation of the PoUS system. It will closely monitor the project’s progress in collaboration with Member States and provide tailored support to address implementation challenges and maintain operational efficiency. Source: European Commission

IMPLEMENTING REGULATION of imports originating in the People’s Republic of China, Saudi Arabia and the United States of America

Commission Implementing Regulation (EU) 2025/1718 of 5 August 2025 making imports of 1,4-Butanediol originating in the People’s Republic of China, Saudi Arabia and the United States of America subject to registration (CN codes 2905 39 26 and 2905 39 28) Link

Suspending measures concerning certain products originating in the United States of America

Commission Implementing Regulation (EU) 2025/1727 of 5 August 2025 suspending commercial rebalancing measures concerning certain products originating in the United States of America and certain products exported from the Union to the United States of America imposed by Implementing Regulation (EU) 2025/1564. On 27 July 2025 the Union and the United States reached a political agreement as regards their trade relationship, providing, inter alia, for immediate tariff relief for Union imports to the United States. As a result, the United States committed to imminently modify certain tariffs applicable to Union imports in line with that political agreement, reducing the applicable rate to a maximum of a 15 % ad valorem. Link

United States-European Union Joint Statement on a framework on an agreement on reciprocal, fair and balanced trade

The United States and the European Union are pleased to announce that they have agreed on a Framework on an Agreement on Reciprocal, Fair, and Balanced Trade ('Framework Agreement'). This Framework Agreement represents a concrete demonstration of our commitment to fair, balanced, and mutually beneficial trade and investment. This Framework Agreement will put our trade and investment relationship – one of the largest in the world – on a solid footing and will reinvigorate our economies’ reindustrialisation. It reflects acknowledgement by the European Union of the concerns of the United States and our joint determination to resolve our trade imbalances and unleash the full potential of our combined economic power. The United States and the European Union intend this Framework Agreement to be a first step in a process that can be further expanded over time to cover additional areas and continue to improve market access and increase their trade and investment relationship.

The key terms include:

The European Union intends to eliminate tariffs on all US industrial goods and to provide preferential market access for a wide range of US seafood and agricultural goods, including tree nuts, dairy products, fresh and processed fruits and vegetables, processed foods, planting seeds, soybean oil, and pork and bison meat. The European Union will immediately take the necessary steps to extend the Joint Statement of the United States and the European Union on a Tariff Agreement announced on 21 August 2020, with respect to lobster (that expired 31 July 2025), coupled with an expanded product scope to include processed lobster. The United States commits to apply the higher of either the US Most Favored Nation (MFN) tariff rate or a tariff rate of 15%, comprised of the MFN tariff and a reciprocal tariff, on originating goods of the European Union. Additionally, effective as of 1 September 2025, the United States commits to apply only the MFN tariff to the following products of the European Union: unavailable natural resources (including cork), all aircraft and aircraft parts, generic pharmaceuticals and their ingredients and chemical precursors. The United States and the European Union agree to consider other sectors and products that are important for their economies and value chains for inclusion in the list of products for which only the MFN tariffs would apply. Source: European Commission

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