News

Oct 31, 2025

Customs Law: ECJ clarifies ex officio reimbursement

In its judgment C-206/24 of 1 August 2025, the European Court of Justice (ECJ) ruled on the conditions under which a customs authority is obliged to reimburse import duties levied without legal basis ex officio. The ECJ clarified: Ex officio reimbursement requires that the customs authority itself determines within three years of the entry in the accounts that the duties were levied without legal basis – and that it also knows the identity of the affected person and the reimbursement amount. If this information is missing, the authority must take reasonable, but not disproportionate, measures to obtain it. If unsuccessful, the obligation to reimburse terminates after the deadline – even if the authority determined within the deadline that the duties were not legally owed.

Oct 29, 2025

The 19th Sanctions Package against Russia

On October 23, 2025, the European Union (EU) adopted its 19th package of sanctions against Russia. The new package targets the energy and financial sectors in particular. At the same time, however, export and service bans were tightened and personal restrictions expanded.

Oct 23, 2025

EU Commission proposes changes to EUDR

Following the EU’s Environment Council on 21 October 2025, EU Commissioner Jessika Roswall announced a targeted simplification package for the European Deforestation Regulation (EUDR).Following her announcement, the Commission published a formal proposal to change the EUDR, including the introduction of a new Annex III (link). Although the Commission proposes substantive changes to the EUDR, the date of application of the EUDR remains unchanged under the proposal. The Commission only introduced a six-month delay for small and micro enterprises for 30 December 2026 (instead of 30 June 2026).Substantive changes concern in particular so-called “downstream operators” and “micro and small primary operators”.

Oct 2, 2025

The snapback mechanism against Iran – reintroduction of EU sanctions

On the night of 28 September 2025, the deadline for the so-called “snapback mechanism”, initiated by Germany, France, and the United Kingdom, expired. As a result, the sanctions imposed by the UN Security Council on Iran – which had been suspended since January 2016 – are once again in force. The possibility of reimposing sanctions was legally established under international law as part of the Vienna Agreement on Iran’s nuclear program (Joint Comprehensive Plan of Action, JCPoA) in 2015. The EU responded immediately and implemented the UN sanctions into directly applicable EU law through Regulation (EU) 2025/1975 and Implementing Regulations (EU) 2025/1980 and 2025/1982.

Oct 1, 2025

Extension of the "50% Rule" to US (Re-)Export Controls

On September 29, 2025, the US Bureau of Industry and Security’s new interim final rule came into force, expanding end-user controls to cover affiliates of certain listed entities.

Sep 24, 2025

Possible Postponement of EUDR

EU Commissioner Jessica Roswall, Directorate-General for Environment, Water Resilience and a Competitive Circular Economy, wrote a letter to the European Parliament today declaring the Commission's intention to postpone the application of the European Deforestation Regulation (“EUDR”) by one year. The same was confirmed by Alois Rainer, the German Minister for Agriculture, Food and Regional Identity. The Regulation, which entered into force on 29 July 2023, was originally scheduled to apply from 30 December 2024. Following a previous deferral, the application date had already been moved to 30 December 2025.

News

Customs Law: ECJ clarifies ex officio reimbursement

The 19th Sanctions Package against Russia

EU Commission proposes changes to EUDR

The snapback mechanism against Iran – reintroduction of EU sanctions

Extension of the "50% Rule" to US (Re-)Export Controls

Possible Postponement of EUDR

Our newsletter – your monthly update on the new developments in trade compliance, economic security, and sustainability