Regulatory Compliance updates January 2026

January 30, 2026

Bulgaria joins euro area from 1 January

From 1 January 2026, the euro gradually replaced the lev as Bulgaria's currency. With Bulgaria's accession, 21 EU Member States and more than 357 million EU citizens will share the EU's common currency. The euro will deliver practical benefits to Bulgarian citizens and businesses. It will make travelling and living abroad easier, boost the transparency and competitiveness of markets, and facilitate trade.

EC Communication on the CBAM Register

According to the CBAM Regulation, from 1 January 2026, the validation of CBAM licences for CBAM goods is enforced by customs authorities before release for free circulation, including the monitoring of the 50 tonne threshold, while facilitating the import of CBAM goods by SMEs in line with the Omnibus Package. Key operational results: (1) More than 12,000 business operators applied for a CBAM authorization by January 7, 2026; (2) More than 4100 CBAM business operators have successfully obtained the status of an authorised CBAM declarant across the EU before and immediately after 1 January 2026; (3) In total, 10 483 Import Declarations with CBAM goods were verified automatically and in real time between 1 January and 7 January 2026 through integrated customs systems.

European Union DUAL USE Items updates

Following the implementation in TARIC of the  “Commission Delegated Regulation (EU) 2025/2003 of 8 September 2025 amending Regulation (EU) 2021/821 of the European Parliament and of the Council as regards the list of dual-use items”, the new "dual use correlation table" has been published on CIRCAbc, valid from 01/01/2026. Source

New EU requirements for the electronic service of documents

The published Commission Implementing Regulation (EU) 2026/101 of 15 January 2026 lays down detailed technical specifications and operational requirements for the decentralised IT system to support the electronic judicial and administrative procedures provided for in Regulation (EU) 2023/2844. The act sets out the rules for the functioning of the system, its interoperability, security, data exchange requirements and how documents are to be served by the European electronic access point. The timetable for implementation is set out in Annex VIII. The regulation enters into force on 5 February 2026 and is directly applicable in all Member States.

European Parliament stalls a U.S.–EU trade deal in response to tariff threats

The European Union's legislative body on Wednesday halted work on the formal approval and implementation of the trade deal it reached last summer with President Donald Trump. "Given the continued and escalating threats, including tariff threats, against Greenland and Denmark, and their European allies, we have been left with no alternative but to suspend work" on the deal, said Bernd Lange, the chairman of the European Parliament's international trade committee. "Until the US decides to re-engage on a path of cooperation rather than confrontation," no steps to move the deal forward would be taken, Lange said in a statement. The announcement came after Trump on Saturday said he would hit seven European Union countries, plus the U.K., with tariffs if they did not allow the United States to control Greenland. The E.U. trade deal was reached in July during a visit by European Commission President Ursula von der Leyen to Trump's golf club in Turnberry, Scotland.

EU: New rules of origin from the PEM Convention

The Ministry of Finance's Customs Department has announced that from 1 January 2026, the EU will apply the new, i.e. the so-called revised rules of origin of the EMF Convention in all its bilateral agreements that contain a dynamic reference to the Convention in the relevant protocols on rules of origin (agreements with Iceland, Switzerland – including Liechtenstein, Norway, the Faroe Islands, Egypt, Jordan, Morocco, Palestine, Tunisia, Albania, Bosnia and Herzegovina, North Macedonia, Montenegro, Serbia, Kosovo, Moldova, Georgia, Ukraine). Pending the ratification of the revised Convention, Morocco, Egypt, Palestine and Tunisia will export their products to the EU using the transitional rules also contained in their bilateral agreements with the EU.

EU CBAM: New regulations on default values of embedded emissions

The Ministry of Finance's Customs Department has announced that from 1 January 2026, the EU will apply Commission Implementing Regulation (EU) 2025/2621 of 16 December 2025 laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and of the Council as regards the setting of default values has been published. The new rules set out the methods for determining default values for embedded emissions for goods covered by the CBAM, in particular: (1) emissions embedded in goods other than electricity, (2) emissions related to imported electricity, (3) indirect embedded emissions, in accordance with Article 7 of Regulation 2023/956. The aim of the regulation is to provide a consistent, comparable and reliable system for determining embedded emissions that will enable the CBAM to function properly and reduce the risk of circumvention of EU climate regulations.

EU: New rules on access to technology in emergency situations

Regulation (EU) 2025/2645 of the European Parliament and of the Council of 16 December 2025 on compulsory licensing in the context of crisis management and amending Regulation (EC) No 816/2006 has been published. The aim of the regulation is to enable the European Union to respond quickly and in a coordinated manner to crises by ensuring access to products that are essential for public health, safety or the functioning of the economy. The regulation aims to ensure that in crisis situations, the EU can access technologies, medicines, vaccines, medical tools and other products that are limited in availability. The regulation enters into force on 19 January 2026 and is directly applicable in all member states.

European Commission consultations on aluminium scrap

The European Union is considering a new measure to keep aluminium scrap available on the European market – a key step towards the green transition and strategic autonomy. The initiative aims to address the lack of availability and affordability of secondary raw materials for the aluminium sector. The Commission is asking stakeholders at different levels of the value chain (primary and secondary aluminium producers, recyclers, traders, users, etc.) to properly assess the impact of different options across the aluminium supply chain in the EU. The information provided by stakeholders through this questionnaire is therefore very relevant. The first stage is public consultations, which will last until 31 January 2026.

United States: CBP Publishes FAQ for Electronic Refunds

In a Cargo Systems Messaging Service (CSMS) bulletin published on January 27, 2026, U.S. Customs and Border Protection (CBP) posted a reminder to the trade on the upcoming interim final rule on electric refunds and provided updated resources for the transition. CBP has provided informational notices, training guides, support calls, reference sheet, and a new ACE Portal and ACH Refunds Frequently Asked Questions (FAQ) document. All CBP issued refunds will be processed electronically via automated clearing house (ACH) starting on February 6, 2026. Source

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