Regulatory Compliance updates March 2025

March 27, 2025

EU adopts 16th sanctions package against Russia

As part of the comprehensive sixteenth package of sanctions adopted earlier today, the Council decided to impose targeted restrictive measures on an additional 48 individuals and 35 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. 

EU imposed full-fledge sanctions over three entities transporting Russian crude oil and oil products and providing substantial revenues to the Russian Government. Additionally, this package continues targeting actors responsible for circumventing EU sanctions, including through third countries. For the first time, the Council also decided to sanction, a crypto-currency exchange based in Russia, Garantex, which is closely associated with EU-sanctioned Russian banks.

Sanctions will also be imposed on third countries actors directly supporting the Russian war effort. Today’s listings include one Chinese firm specialised in the production of satellite imagery, notably to the benefit of the Russia’s military-industrial complex, together with its chairman, as well as two senior officials in the Korean People’s Army.

Responding to Russian propaganda remains also a priority. Alongside notorious Russian propagandists, the EU is notably listing NewsFront, and SouthFront, two outlets presenting distorted interpretations of history and manipulated information in line with Kremlin messaging while also targeting European and global audiences with distorted and manipulated information Concerning listed individuals, the EU is targeting businessmen active in the Russian mining and energy sectors, politicians and proxies from the non-government controlled areas of Ukraine, people involved in the mass abduction, illegal re-education, deportation and forced transfer of Ukrainian children from occupied territories of Ukraine to Russia and public figures, including a former Ukrainian politician now working for Russia.

Altogether, EU restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine now apply to over 2400 individuals and entities. Those designated today are subject to an asset freeze and EU citizens and companies are forbidden from making funds available to them. Natural persons are additionally subject to a travel ban, which prevents them from entering into or transiting through the territories of EU member states.

EU CBAM: new Commission proposal will simplify and strengthen

The European Commission has adopted a new package of proposals to simplify EU rules, boost competitiveness, and unlock additional investment capacity. This is a major step forward in creating a more favourable business environment to help EU companies grow, innovate, and create quality jobs.

By bringing our competitiveness and climate goals together, we are creating the conditions for EU businesses to thrive, attract investment, achieve our shared goals – such as the European Green Deal objectives – and unlock our full economic potential. These first ‘Omnibus' packages of 26 February 2025 bring together proposals in a number of related legislative fields, covering a far-reaching simplification in the fields of sustainable finance reporting, sustainability due diligence, EU Taxonomy, carbon border adjustment mechanism, and European investment programmes. As part of this, the Commission proposed a set of changes to simplify CBAM and make it more effective.

Firstly, the Commission proposes to simplify CBAM for small CBAM importers, mostly SMEs and individuals, by introducing a new CBAM de minimis threshold exemption of 50 tonnes mass. These are importers who import small quantities of CBAM goods, representing very small quantities of embedded emissions entering the EU from third countries. This means keeping around 99% of emissions still in the CBAM scope, while exempting around 90% of the importers. For those importers who remain in the CBAM scope, the proposed changes will also facilitate compliance with CBAM obligations. For instance, by simplifying the authorisation of declarants, the calculation of emissions, and the management of CBAM financial liability. This will be coupled with measures making CBAM more effective, by strengthening anti-abuse provisions and developing a joint anti-circumvention strategy together with national authorities. 

Next steps

Simplification is key to reducing administrative burden for SMEs and occasional importers. This learning period, during the CBAM transitional phase, has allowed us to develop the policy measures jointly with stakeholders. Simplification is also a precondition to review CBAM and make it stronger and more efficient.

Going forward, the next steps will include a full review of CBAM later this year, to assess its potential extension to other ETS sectors, downstream goods, indirect emissions. The Commission will also examine, in this context, how to help exporters of CBAM products at risk of carbon leakage. This will be followed by a legislative proposal in early 2026.

EU uses the Customs Surveillance system to monitor Industrial Chemical Imports

The European Commission has initiated customs surveillance of imports of certain ethylene and ammonia products, primarily used in fertiliser production and industrial applications, to monitor their rapid influx into the EU market. The Commission will utilise the EU customs surveillance system to gather import statistics to enhance the Commission's understanding of the market situation, enabling it to better assess potential complaints or requests from industry.

EU delays first set of retaliatory tariffs in Trump trade war

The European Commission will delay one batch of its tariff response to Donald Trump's steel and aluminum duties from April 1 to April 13 to allow time to find a “mutually agreeable solution. The move consolidates both parts of the EU's planned two-stage response into a single measure covering €26 billion in US exports. The delay will also allow the Commission to fine-tune its response to take into account further reciprocal tariffs from Washington which are expected as soon as April 2. The decision comes after criticism from the leaders of Ireland, Italy, and France on the EU’s handling of countermeasures to U.S. tariffs, after Trump threatened to slap a 200 percent levy on all wines, champagne and alcoholic products coming from the EU.

EU Common Military List of the European Union

European Parliament and of the Council updated of the list of defence-related products in line with the Common Military List of the European Union of 19 February 2024. The Annex to Directive 2009/43/EC shall apply those provisions from 5 June 2025. Link

EU Import Control System 2 (ICS2) – Are you ready?

Import Control System 2 (ICS2) is an advance cargo information system designed to improve security in the international transportation of goods and involved supply chain. All Economic Operators (EOs) that bring goods to or transiting through the EU, have to declare safety and security data to ICS2, through the Entry Summary Declaration (ENS).  Based on the ENS, all goods are subject to safety and security risk analysis and better targeted controls.  

ICS2 helps to better identify high-risk consignments and intervene at the most appropriate point in the supply chain, while facilitating legitimate flow of goods.  1 April 2025: ICS2 Go-live date for rail and road carriers.  Link - roadLink - rail

EU suspends & lifts some Syria sanctions

The Council decided to suspend a number of restrictive measures in view of the situation in Syria. This decision is part of the EU’s efforts to support an inclusive political transition in Syria, and its swift economic recovery, reconstruction, and stabilisation.

The EU aims to facilitate engagement with Syria, its people, and businesses, in key areas of energy and transport, as well as to facilitate financial and banking transactions associated with such sectors and those needed for humanitarian and reconstruction purposes. Link

European Union: Fluorinated greenhouse gases

An update of TARIC export measures (measure type 765) for labelling requirements has been made in TARIC. YA pair of condition (labelling requirements) has been deleted from the export measures on F-gases listed in Annex II and Annex III (Reg 2024/573). The labelling requirement (article 12.9. (Reg 2024/573) stays introduced only for fluorinated greenhouse gases listed in Annex I (Reg 2024/573). The start date of this update is 12.3.2025.

EU Commission proposes plan for continued facilitation of Ukraine steel imports

The European Commission has proposed a plan to support Ukraine’s important iron and steel sectors, which would continue to exempt their imports into the EU from trade defence measures. A new Commission regulation proposes continuing the suspension of certain parts of Regulation (EU) 2015/478 as regards imports from Ukraine into the European Union. This proposal constitutes a legal basis for the continuous suspension of the steel safeguard measure as concerns Ukraine.  

Iron and steel exports to the EU are a significant source of revenue for Ukraine. Continuing to exempt these products from steel safeguard measures would support Ukraine's economy, by helping to alleviate the difficult situation faced by Ukrainian producers and exporters because of Russia's unprovoked and unjustified war of aggression. 

The proposal will now go to the Council and European Parliament for approval. If adopted, it will ensure that Ukrainian steel exports into the EU continue to be exempt from EU steel safeguard measures even after the expiration of the EU’s temporary autonomous trade measures (ATMs).  

EU Commission announces actions for safe and sustainable e-commerce imports

The Commission is taking action to tackle risks stemming from low-value imports sold via non-EU online retailers and marketplaces hosting non-EU traders. The Commission encourages actions, among others, in the areas of customs and trade, such as launching customs controls, consumer protection and the Digital Services and Digital Markets Acts.

EU support for the implementation of the Arms Trade Treaty

Council Decision (CFSP) 2025/442 on Union outreach activities in support of the implementation of the Arms Trade Treaty (ATT) has been released. The Decision concerns outreach activities of the European Union in support of the implementation of the Arms Trade Treaty (ATT). This treaty, adopted by the UN General Assembly in 2013, aims to establish strict international standards to regulate the legal trade in conventional arms and to prevent and combat illicit arms trafficking. The decision continues and expands on previous Union actions, such as Council Decisions (CFSP) 2013/768, 2017/915 and 2021/2309, which supported Member States and partners in developing national arms transfer control systems in line with ATT requirements. The new decision emphasises cooperation with existing and new partners to ensure sustainability of progress and promote a regional approach to ATT implementation. EUR 3.1 million has been allocated for the implementation of the above-mentioned activities.
Link

Norway is preparing to introduce CBAM in 2027

The Norwegian government has announced that it is planning to introduce the country’s own Carbon Border Adjustment Mechanism (CBAM) from 2027. The ministry of climate and environment and The Norwegian Environment Agency will work together on the scheme. With its CBAM, Norway aims to prevent the European industry from losing its competitiveness and from relocating to other countries where environmental regulations are not stringent.

South Africa: Invoice details on customs declarations

Following a period of engagement, development, and testing with industry and technical service providers, SARS requests that trade now include invoice data in all electronic customs declarations submitted to SARS. As of 1 April 2025, customs declarations not containing invoice data will have an increased probability of being selected for documentary inspection or audit, and of such declarants being requested to upload invoices as supporting documentation.

South Africa: updated the product list which require export permits

The following tariff headings require export permits:

  • 7403.12, 7403.13, 7403.19, 7403.21, 7403.22 and 7403.29.
  • Tariff headings 8422.90 and 8471.49.90 do not require a Letter of Authority for NRCS.

UK update to open general export licence

The Export Control Joint Unit (ECJU) has updated the OGEL exports in support of Joint Strike Fighter (F-35 Lightning II). This open general export licence (OGEL) allows the export or transfer of goods, software or technology for the Joint Strike Fighter (F-35 Lightning II) (JSF) Programme from the UK to any of the destinations or countries listed in this licence. This includes re-exporting goods, software or technology to and from permitted destinations, even if they have been incorporated into other products. Greece has been added as a destination to the F35 open general export licence (OGEL).

UK Department for Business Trade has removed Rwanda as a permitted

destination for the Open Export General License (OGEL) PCBs and components for military goods, OGEL software, and source code for military goods.

UK: Update to Banana Import Licence Requirement

Please note the upcoming tariff measure change for bananas as of 21 March 2025, does not impact on existing arrangements for traders who declare Additional Procedure Code 1BN at the time of import together with document code C046 and document status code XU.

UK: Update to Suspension Measures

Following the publication of Tariff Stop Press Notice - 14 March 2025 HMRC are aware of the following current suspension issues:

  • 2915704098 missing measure type 103 measure with additional code 2701.
  • 3808942030 missing measure type 112 as previous measure was inadvertently ended for 13 March 2025.
  • HMRC are also aware of some potential issues with the application of the document codes as outlined in the initial Stop Press Notice.

UK: Transition of Suspensions to Measure Type 112 - Autonomous tariff suspension from 14 April

The way that the UK manages COVID and Business suspensions in the Customs Tariff is changing. This will affect those commodities where the suspension is currently delivered via an additional code combined with a footnote:

  • Business suspensions – measure type 103 using additional codes 2700-2704;
  • Covid suspensions – measure type 103 using additional codes 2600/2601;
  • With all declarations now being undertaken within the Customs Declaration System we have the ability to improve on this method, reducing risks caused by deviation from the more standard data model; and reducing burdens for declarants.

Therefore, from the 14th of April 2025:

  • Measures which are currently set as a 103 - Third country duty with an additional code suspension 2600/2601 (Covid) or 2700-2704 (Business) are changing to measure type 112 - Autonomous tariff suspension.
  • Rather than additional codes informing the coverage of the suspension the following document codes will apply:
  • 9Y11: Goods that are COVID-19 critical
  • 9Y12: Duty suspension of 0% applies - see footnote for coverage. Please do not use if the MFN import duty rate is 0%
  • 9Y15: The declared goods fall under partial suspension.

UK/OFSI Notice to Exporters

The Department for Business and Trade has updated the guidance for UK exporters on countering Russian sanctions evasion and circumvention. Link

United Kingdom: Upcoming updates to the UK strategic export control list

To reflect the recent updates to the control lists administered by the multilateral export control regimes and some domestic administrative updates, the UK Strategic Export Control List will be amended to include the following key changes:

  • amendments in line with changes published in the control lists on The Wassenaar Arrangement website, as adopted into UK legislation – these include changes to the following control list entries: ML10, 1C002, 1C005, 3A002, 3C005, 5A001, 5E001, 5A002, 6A005, 8A001, 8A002, 9A004, 9B and 9E003
  • editorial amendments to Technical Notes and definitions in certain entries, including an amendment to the definition of ‘spacecraft’ resulting in new definitions for ‘satellite’, ‘space probe’ and ‘space vehicle’
  • amendments in line with changes agreed under the guidelines on the Nuclear Suppliers Group (NSG) website, which include changes to following control list entries: 0B004a, 0B004b, 1A202, 1A225, 1B228 and 6A225
  • amendments in line with changes agreed under the Australia Group (Australia Group website) in the control list entry 2B352
  • amendment to the technical parameters of the existing control under PL9013a4 aimed at high-end digital processing integrated circuits (ICs) most suitable for AI training
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