EU: Commission sets type of evidence to be provided by importers to prove country of ‘melt and pour’ of steel products subject to EU Steel Regulation
The Commission's implementing act responds to requirements laid down in the Steel Regulation, and was unanimously backed by EU Member States on 19 August.
The introduction of the country of 'melt and pour' requirement in the Steel Regulation aims to enhance the transparency and traceability of steel products imported into the European Union, allowing the Commission to address potential circumvention and ensure the effectiveness of EU steel measures against the effects of global overcapacity.
The implementing act applies from 1 October 2026. From then on, importers must declare on their customs declaration the country in which the steel has been melted and poured, in order to be able to import steel products subject to the Steel Regulation into the EU market. As of 1 October 2027, the listed documents will only be accepted as complementary to the Mill Test Certificate, rather than as standalone documents.
The Commission will continue to work closely with Member States and stakeholders to support the smooth implementation of the new traceability requirements.
EU Deforestation Regulation (EUDR) - Regulation (EU) 2023/1115 updated
Commission Delegated Regulation (EU) 2026/2102 amends Annex I to the EU Deforestation Regulation (EUDR) and clarifies which commodities and products fall within its scope.
Key changes:
Scope of EUDR clarified – the Regulation provides more precise definitions of the commodities and products covered by the EUDR, reducing uncertainty around certain CN codes and product categories.
- Cattle products
- The scope of cattle is clarified to cover cattle of the Bos genus/sub-genera.
- Buffalo, bison and other bovine animals outside the specified categories are excluded.
- Frozen cattle tongues (CN 0206 21 00) are added to the list of relevant products.
- Cattle leather products removed
- Certain cattle hides, skins and leather products under CN 4101, 4104 and 4107 are removed from Annex I.
- These products will therefore no longer be subject to EUDR requirements based on these entries.
- Oil palm products
- The Regulation clarifies that the relevant commodity is oil palm (Elaeis spp.).
- Products derived from other palm species, such as babassu, are excluded.
- Several palm-oil derivatives are added to the EUDR product list.
- New palm-oil-related products
- Additional products under various CN headings, including 1516, 1518, 1520, 2916, 2924, 3401, 3824 and 3907, are brought into scope where they are derived from oil palm.
- Companies should therefore check not only the CN code but also the raw material/origin of the product.
- Rubber
- The Regulation clarifies that the relevant rubber is rubber derived from Hevea brasiliensis.
- Other natural gums and rubbers, as well as synthetic rubber, are excluded from the EUDR scope.
- Bamboo and rattan
- Bamboo, rattan and other woody materials are excluded from the definition of relevant wood commodities.
- A product should therefore not be treated as EUDR-relevant simply because its CN code falls within a wood-related heading.
- Soluble coffee
- Soluble coffee is added to the list of relevant products.
- This expands the EUDR scope beyond the coffee products previously listed.
- Samples and testing
- Specific exclusions are introduced for certain samples of negligible value used to solicit orders.
- Products imported/exported specifically for examination, analysis or testing may also be excluded when the conditions set by the Regulation are fulfilled, e.g. where the goods are consumed or destroyed during testing.
- Important date for newly added products
- The newly added products, including soluble coffee, certain palm-oil derivatives and frozen cattle tongues, will become subject to EUDR requirements from 30 December 2027.
- Practical recommendation for companies
- Companies should review their product portfolios and CN codes against the amended Annex I.
- Particular attention should be paid to products containing palm oil, rubber, wood or cattle-derived materials, as the amended rules may change whether a product falls within the EUDR scope.
- Companies handling samples or testing materials should also assess whether the new exclusions apply to their shipments.
New EU Customs Code and Customs Authority
Regulation (EU) 2026/2108 of the European Parliament and of the Council of 16 September 2026 establishing a new Union Customs Code and a European Union Customs Office (EUCA) has been published in the Official Journal of the European Union. The new legal act replaces the existing regulations (Regulation No. 952/2013) and thoroughly reforms the customs union, responding to the challenges of global trade and the dynamic growth of e-commerce transactions. From the perspective of the electronics, ICT and trade sectors, the key element of the reform is the full digitalisation of processes through a centralised EU customs data centre and new rules for the settlement of distance sales. For compliance professionals, the regulation introduces stricter obligations to verify the compliance of goods with EU standards, new rules on the liability of importers and a strict monitoring system for trusted traders. The EU Customs Authority (based in Lille) will take over operational functions in the coordination of risk analysis and crisis management at the Community level. The system based on the EU Customs Data Centre will be introduced gradually – from 1 March 2031 on a voluntary basis, becoming fully mandatory for all entrepreneurs from 1 March 2034. The Regulation applies from 21 September 2027.
Revision of the EUDR Regulation: Significant Exemptions for Packaging, Rubber, and Technical Samples
Commission Delegated Regulation (EU) 2026/2102 of July 13, 2026, amending Annex I to Regulation (EU) 2023/1115 on combating deforestation (EUDR), has been published in the Official Journal of the EU. The amendment introduces key clarifications and technical exemptions, explicitly exempting packaging materials and containers (made of wood, paper, and cardboard) used exclusively to secure, protect, or transport other goods placed on the market, as well as accompanying instructions, marketing labels, waste, used products, and free test samples. Equally important for the technology industry, finished rubber articles (HS code ex 4016) and drive belts and straps (HS code ex 4010) have been removed from the list, and the scope of rubber raw materials has been strictly limited to the Hevea brasiliensis species, excluding, among other things, synthetic rubber.
For companies in the electronics and ICT sectors, these changes represent a significant operational relief—they eliminate the need to geolocate forest plots for cardboard boxes, pallets, and wooden cable drums used to protect imported digital equipment, as well as for small rubber gaskets in device housings. From the perspective of sales and procurement departments, this legislation eliminates the risk of logistical gridlock at EU customs borders and facilitates the procurement of components. For compliance departments, in turn, the amendment clarifies the scope of supply chain audits, exempting transport packaging from the requirement to collect due diligence statements (DDS), while mandating continued monitoring of separately sold paper products and newly added palm oil derivatives (e.g., selected polyethers under ex 3907 29, subject to implementation as of December 30, 2027). The regulation entered into force on September 18, 2026, and is directly applicable in all member states.
European Commission Guidelines on CBAM Verification and Accreditation
The European Commission (DG TAXUD) published comprehensive guidelines on the verification of emission reports and the accreditation of verifiers by National Accreditation Bodies (NABs) as part of the definitive period of the CBAM mechanism, effective from 1 January 2026. The document explains in detail the rules for the audit of embedded emissions, the validation of monitoring plans for installations outside the EU, the control of precursors (m.in steel and aluminium), the calculation of free allowances (SEFA) and the criteria for materiality and site visits. For the electronics and information and communication technology (ICT) sector, which uses enclosures, components, connectors and raw materials covered by the CBAM, the guidelines mean that foreign suppliers need to be prepared for rigorous audits by accredited entities to report actual emission values instead of unfavourable default values. From the perspective of international trade and logistics, the published timeline is crucial: from 1 September 2026, verifiers will have access to the CBAM Register, and from January 2027 they will issue official verification reports in it, on the basis of which authorised applicants will settle certificates. Compliance departments receive clear guidelines on the verification of power purchase agreements (PPAs), certification of testing laboratories and supply chain monitoring against ISO 17029 and ISO 14065 standards.
New EU Delegated Regulation: Assessment and verification systems for power, control and communication cables
The European Commission has adopted Delegated Regulation (EU) 2026/1310 of 11 June 2026, complementing the new EU legal framework for construction products (Regulation 2024/3110). This act establishes specific assessment and verification systems (SoV) applicable to individual families and categories of construction products. The regulation takes into account the specificities of horizontal characteristics (such as reaction to fire or release of hazardous substances) and minimises the administrative burden on manufacturers. From the point of view of the electronics and ICT sector (e.g. power, control and communication cables), the regulation precisely defines stringent rating systems (e.g. system 1+ for the selected fire classification). For compliance and trade specialists, the new regulations provide a direct basis for verifying compliance and applying harmonized technical specifications on the EU market. The regulation enters into force on 17 September 2026, is binding in its entirety and is directly applicable in all EU member states.
Steel imports into the EU from 1 October 2026: Obligation to confirm the country of smelting and pouring
The European Commission has adopted Implementing Regulation (EU) 2026/1963 of 28 August 2026, which specifies the types of evidence required from importers to confirm the country of 'smelting and pouring' of steel. These rules, linked to the EU Steel Regulation, aim to improve the traceability of steel products and tackle global overcapacity. The basic document required for importing into the EU is to be a certificate from the production plant containing information on the country of smelting and pouring and the smelting number. During the transitional period (from 1 October 2026 to 30 September 2027), a flexible documentation framework and the use of supplementary or alternative documents (e.g. invoices, quality certificates or production documents) in the absence of a main certificate were allowed. From the perspective of international trade and compliance persons, failure to provide the required and verified information on the country of origin of steel will result in the rejection of imports by customs authorities. For the electronics and ICT sectors, the new regulations are of indirect importance – mainly in the context of the use of steel components in infrastructure, housings or equipment, and strict requirements for supply chain verification. The regulation applies from 1 October 2026 , while Article 1(3) applies from 1 October 2026 to 30 September 2027. The Regulation is binding in its entirety and directly applicable in all Member States.
The European Commission designates ChatGPT as VLOSE, and Reddit and Roblox as VLOPs
The European Commission has designated ChatGPT as a Very Large Online Search Engine (VLOSE) and Reddit and Roblox as Very Large Online Platforms (VLOPs) under the EU's Digital Services Act (DSA), after they have exceeded the threshold of 45 million monthly active users in the EU. The designated services have four months – until the end of December 2026 – to implement stringent obligations, including, m.in, assessing and mitigating systemic risks related to algorithms, the protection of minors, disinformation or public safety. For the electronics and ICT industries, the recognition of generative AI (ChatGPT) as an online search engine sets an important regulatory precedent, directly affecting the architecture of AI solutions and consumer devices and applications integrating these technologies. Commerce and digital marketing managers must prepare for changes in the rules of content distribution, product visibility in AI search engines, and in advertising and monetization mechanisms on large platforms.
EU-Taiwan Technology Alliance: Cooperation on AI Chip Design, Packaging, and Data Centers
The second EU-Taiwan Semiconductor Industry Dialogue, organized by the European Commission and the EETO office, took place in Taipei, coinciding with the SEMICON Taiwan 2026 trade show. The meeting, attended by market leaders and coordinated by the EU’s ChipDiplo technology diplomacy consortium, focused on the impact of the new European Chips Act 2.0 legislative proposal and the rapidly growing demand from European data centers for advanced artificial intelligence chips. For the European electronics and ICT sectors, these discussions open up opportunities to combine the EU’s strengths in microprocessor architecture, EDA tools, and intellectual property (IP) with Taiwan’s dominance in foundry manufacturing, advanced packaging, and system integration. From an international trade perspective, the event supports the transformation of Taiwanese companies from traditional component suppliers into direct investment partners expanding Europe’s AI infrastructure stack (AI stack). For compliance and supply chain security teams, on the other hand, the monitoring of industrial risks, the control of dual-use technology transfers, and the assurance of the continuity of supply for components critical to the European digital ecosystem—all carried out as part of the ChipDiplo initiative—are of key importance.
Netherlands Restricts Imports from Israeli Settlements
The Dutch Government, through the Ministry of Foreign Affairs, introduced new restrictions on goods originating from Israeli settlements in territories occupied by Israel. Published in Staatsblad 2026, 222, the measure takes effect on September 22, 2026, and prohibits the importation of covered goods into Dutch territory, along with certain related trade activities. Importers of Israeli-origin goods into the Netherlands should maintain sufficient documentation to demonstrate they are not sourced from restricted locations. Where preferential tariff treatment under the EU-Israel Association Agreement is claimed, customs document code Y864 remains applicable to indicate the proof of origin does not relate to an excluded territory.
Extension of restrictions in the border zone with the Republic of Belarus
The Minister of the Interior and Administration issued a regulation of 24 August 2026 introducing a temporary ban on staying in a certain area in the border zone adjacent to the border with the Republic of Belarus (Journal of Laws of 2026, item 1129). The new regulations enter into force on 1 September 2026 and extend the validity of the buffer zone for another 90 days in the Podlaskie Voivodeship. The restrictions include designated sections with a length of 78.29 km in the area of operation of the Border Guard posts in Michałów, Narewka, Białowieża, Dubicze Cerkiewne and Czeremsha. From the perspective of the trade, logistics and border transport sector, the regulation is associated with strict security requirements and restrictions on access to areas adjacent to the border. For those dealing with compliance and legal services for business entities operating in the region, it is crucial to take into account the statutory exemptions and procedures for obtaining passes from the competent commander of the SG post.
United States: CBP Issues Guidance on Canadian Products Excluded from Importation into the U.S.
On September 28, 2026, U.S. Customs and Border Protection (CBP) published a bulletin via its Cargo Systems Messaging Service (CSMS) providing implementation guidance for Presidential Proclamations 11061, 11062, and 11063, which identify certain Canadian-origin products as to be "excluded from importation" into the U.S. According to the bulletin, as of 12:01 a.m. Eastern Time on September 29, 2026, any entry that contains products covered by the three proclamations "will be unconditionally rejected" by CBP. Products entered into a Customs bonded warehouse or admitted prior to the exclusions taking effect "may be withdrawn for consumption and will be subject to the 50 percent ad valorem duty under Presidential Proclamations 11046, 11047, and 11048, as applicable." The CSMS bulletin also provides guidance on the scope of alcoholic beverages subject to the exclusion and outlines new reject messaging added to the Automated Commercial Environment (ACE) to support the enforcement of the exclusion. Source
United States: CBP Publishes Guidance on Polysilicon Product Import BanIn a Cargo Systems Messaging Service (CSMS) bulletin issued on September 23, 2026, U.S. Customs and Border Protection (CBP) published guidance on the upcoming import ban on certain polysilicon products. The temporary final rule for the import ban is detailed in a Federal Register Notice (FRN) published by the Bureau of Industry and Security (BIS) on September 24, 2026. Under the rule, BIS will monitor existing companies that import polysilicon or polysilicon derivatives in advance of future import adjustments on December 4, 2026. According to BIS, it will review imports for “evidence of stockpiling, limit a newly established importer’s ability to stockpile, and subject companies that are stockpiling to an import prohibition if necessary.” Importers that become subject to a polysilicon or polysilicon derivatives import prohibition may apply for a waiver of this restriction. Source