Regulatory Compliance updates January 2025

January 16, 2025

Bulgaria and Romania will join the Schengen area

The (EU) Commission has welcomed the unanimous decision of the Council to abolish controls at the internal land borders with Romania and Bulgaria on 1 January 2025. However, internal border controls will continue to be carried out at the land borders between Romania and Bulgaria - as well as Hungary and Romania - for a period of at least six months.

China Releases Dual-Use List HS Code and ECCN Mapping

On December 31, 2024, China’s Ministry of Commerce (MOFCOM) released the long-awaited mapping of Harmonized System (HS) codes and Export Control Numbers (ECCNs) for dual-use items, with immediate effect. This significant regulatory update aims to enhance the clarity and enforceability of China’s export control laws, aligning with global standards. Dual-use items—goods, technology, or software that can be used for both civilian and military purposes—are subject to strict export controls under China’s Export Control Law (ECL). The mapping of HS codes to ECNs simplifies the identification of controlled items, making it easier for businesses to comply with these regulations.

Key Highlights of the Mapping:
1. Comprehensive Scope: Over 4,000 HS codes have been matched with corresponding ECNs, covering categories such as aerospace, telecommunications, advanced materials, and biotechnology. 
2. Enhanced Compliance: The mapping helps exporters accurately classify their goods, reducing the risk of non-compliance and potential penalties. Although it serves as reference and there is no precise one to one correlation. ECCNs are not compulsory in customs declarations for controlled items in China.
3. Global Harmonization: By aligning its controls with international standards like those of the Wassenaar Arrangement, China aims to bolster its position in global trade. For more details, please refer link

EU: Electronic VAT exemption certificate: political agreement on the new directive

On 10 December 2024, the Council agreed on the new directive proposal from the Commission to introduce an electronic tax certificate for VAT exemptions. The directive will introduce an electronic certificate to replace the existing paper certificate that is used when goods are to be exempt from VAT, for example because they are imported for embassies, international organisations or armed forces.

EU ICS2: Important reminder for air traders bringing goods into the EU

Reporting accurate and complete data is crucial to ensure compliance with the EU’s Important Control System 2 (ICS2) requirements. Air carriers must remain diligent, ensuring accurate data and proactively verifying all shipments details, including e-commerce, to mitigate risks of misdeclaration and avoid delays and penalties at customs.

EU New VAT exemptions for small businesses

From 1 January 2025, small businesses with an annual EU turnover of up to EUR 100,000 can get a VAT exemption. Watch the video to learn more and visit the web portal to check eligibility criteria. Link

EU adopts 15th package of restrictive measures, and Belarus

The Council adopted a 15th package of economic and individual restrictive measures with the objective of further limiting Russia’s ability to wage its illegal, unprovoked and unjustified war of aggression against Ukraine. The Council agreed on a significant package of 84 listings, which consists of 54 persons and 30 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The Council is adding further vessels to the list of those subject to a port access ban and ban on provision of a broad range of services related to maritime transport. This measure is intended to target non-EU tankers circumventing the oil price cap mechanism or support the energy sector of Russia, or vessels that are responsible for transporting military equipment for Russia or involved in the transport of stolen Ukrainian grain. 52 vessels originating from third countries were targeted on these grounds, bringing the total of designated vessels to 79.

The Council also added 32 new entities to the list of those directly supporting Russia’s military and industrial complex in its war of aggression against Ukraine. They will be subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector. Some of these entities are located in third countries (China, India, Iran, Serbia and the United Arab Emirates) and have been involved in the circumvention of trade restrictions or have engaged in the procurement of sensitive items used for Russian military operations, like UAVs and missiles.

In addition, the EU designated individuals and entities pursuant to EU sanctions against Belarus (Regulation (EC) No 765/2006). The EU designated 26 Belarusian and Russian individuals and two Belarusian entities—including judges who issued rulings against individuals who dissented against the Belarusian government and prison officials accused of inhumane treatment of political prisoners—subjecting them to asset freezes and travel bans.
For more details, please refer link

EU: TARIC measures of fluorinated greenhouse gases

Import control of fluorinated greenhouse gases – have been integrated in the TARIC database (start date 1-1-2025) for metred dose inhalers (goods codes ex3004 23, ex3004 39, ex3004 9 and ex9019 20) with labelling requirements. However, re-labelling of medicines is subject to a special approval by the European Medicines Agency or national authorities. It is not feasible in practice for the medical industry to comply with the F-gas labelling requirement as from 1 January 2025. Thus, while industry should remain committed to comply with the provision as soon as possible, national customs administrations should allow the manufacturers of metered dose inhalers the necessary time to comply with the special approval procedure. Therefore, the following updates were done in TARIC database:

  • TARIC document code Y054: Goods labelled according to the provisions of Article 12 of Regulation (EU) 2024/573

has been replaced with the newly created

  • TARIC document code Y166:  Metered dose inhalers labelling according to the provisions of Article 12 of Regulation (EU) 2024/573, submitted to special approval by the European Medicines Agency or national authorities - See footnote CD807".

Once when the medical industry will be able to comply with the F-gas labelling requirements as stated in Article 12 of Regulation (EU) 2024/573, TARIC document code Y166 will be replaced with TARIC document code Y054: Goods labelled according to the provisions of Article 12 of Regulation (EU) 2024/573

New footnote CD 807 with a link to the guidance explaining the above-mentioned situation has been introduced and associated to goods codes ex3004 23, ex3004 39, ex3004 9 and ex9019 20.

EU: Carbon Border Adjustment Mechanism – TARIC data explanation

An explanation document on the TARIC data used to implement the provisions of Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism has been published at the Link

EU: Combined Nomenclature 2025 – 2710 19 43 31

A Member State draw our attention to the discrepancy between the descriptions of CN code 2710 19 42 (Having a bio-based carbon content of at least 80 % by weight) and the following TARIC codes with the description of “Blends containing by weight 20 % or less of paraffinic gasoil obtained from synthesis and/or hydro-treatment, of non-fossil origin”: 

  • 2710 19 42 31, 
  • 2710 19 42 32, 
  • 2710 19 42 39. 

Having taken into account the 2025 changes and the fact that 2710 19 42 “bio-based carbon content” correlates with a content “of non-fossil origin” >= 80%, the concerned product (2710 19 43 31) is integrated under 2710 19 44 00 (Other) as of 1st January 2025.

EU: New Computerised Transit System (NCTS): The deployment of the phase 5 is on track

29 countries (Member States and other countries which are part of the Common Transit Convention) have deployed the new phase 5 of NCTS and in all countries the operations are running smoothly. North-Macedonia (MK), and Greece (GR) are expected to join in December to be followed by the final group of countries with Andorra (AD), Belgium (BE), Hungary (HU), Malta (MT), Portugal (PT) and San Marino (SM) which are expected to go-live in January. The legal deadline for the deployment by Member States (MSs), Common Transit Convention (CTC) contracting parties and economic operators to deploy and use NCTS5 is 2/12/2024. The delayed countries and the economic operators involved in transit operations in these countries are using the transitional period which runs until 21/01/2025 to finalize their new system. Besides the technical aspects, business adjustments also need to be made regarding data collection and submission to NCTS5. 

To present, more than 85% of the transit declarations and related messages are transmitted through this new system in compliance with the deadline. The remaining 15% should transition in the upcoming weeks in line with the national plans and transition strategies defined by each of the countries, and with the ultimate deadline of 21/01/2025.  The transition and migration period also ends for the economic operators at the latest by 31/12/2024 for Ireland (IE) and by 20/01/2025 for France (FR).

European Commission published the dual use correlation table

European commission has published the dual use correlation table, which is effective from 01 January 2025. For more details, please refer link.

EU: Air Tanzania banned from flying in the European Union

The European Commission has updated the EU Aviation Safety List, a list of airlines that are subject to an operating ban or operating restrictions in the European Union because they do not meet international safety standards. The EC has also decided not to grant Air Tanzania a third country operator (TCO) authorisation. Link

Georgia to join the Common Transit Convention and the Convention on the Simplification of Formalities in Trade in Goods

As of 1 February 2025, Georgia will become the latest country to join the  Common Transit Convention and the Convention on the Simplification of Formalities in Trade in Goods. This move follows Georgia's formal agreement to accede to the Conventions on 19 December 2024. By joining these Conventions, Georgia will be part of a network that facilitates the movement of goods across borders between the EU and other participating countries, including Norway, Iceland, Switzerland, North Macedonia, Serbia, Türkiye, Ukraine, and the UK. The simplified rules for border crossing, such as mutually recognised financial guarantees and reduced controls, will cut costs for businesses in the EU, Georgia and other participating countries.

Proofs of origin during PEM transitional period

2 proofs of origin have been created upon request of our colleagues of the Origin Unit to be used within the context of PEM transitional period and from 01.01.2025.

U078 = “Movement certificate EUR. 1 bearing the following statement in English in Box 7: "REVISED RULES"
U079 = “Origin declaration bearing the following statement in English after the text of the declaration: “REVISED RULES”. For more information, see the following information document. Link

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