News

New and updated General Authorisations

03 March 2026

In a press release dated 30 January 2026, the Federal Ministry for Economic Affairs and Energy (Bundesministerium für Wirtschaft und Energie – BMWE) announced a new package of measures, jointly adopted with the Federal Office for Economic Affairs and Export Control (Bundesamt für Wirtschaft und Ausfuhrkontrolle – BAFA), aimed at accelerating and simplifying export controls for military and dual‑use items. In light of the current security policy challenges, the package includes several revised and newly introduced General Authorisations (Allgemeine Genehmigungen – AGGen), which entered into force on 1 February 2026. The following article provides a brief overview of the most important changes.

New and updated General Authorisations

Tariff Quotas: General Court confirms Requirements for the “First-Come, First Served” Principle

27 February 2026

The administration of numerous tariff quotas is based on the so-called “first-come, first serve” principle. For the application of a reduced customs duty rate under a tariff quota, the decisive factor is the time at which the customs declaration is accepted. The General Court of the European Union (GC) (Case T-177/25) has now clarified: A missing quota number cannot be added later in order to benefit from a quota that has already been exhausted and thus obtain a lower rate of duty. The quota number must be stated completely and correctly when the declaration is submitted – otherwise, the regular rate of duty applies.

Tariff Quotas: General Court confirms Requirements for the “First-Come, First Served” Principle

ESPR: Ban on destruction of unsold consumer products and disclosure requirements

18 February 2026

It’s a well-documented fact that a proportion of unsold products (especially textiles) are routinely being destroyed before being used, generating significant avoidable waste and CO² emissions. To address this issue, Article 24 of the Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products (ESPR) requires businesses to disclose data about unsold consumer products while Article 25 sets an outright ban on the destruction of certain products. On 9 February 2026, the European Commission (EC) published a delegated act setting out exemptions from this ban (section 1), as well as an implementing regulation specifying the format for the disclosure requirements regarding discarded unsold consumer products (section 2).

ESPR: Ban on destruction of unsold consumer products and disclosure requirements

Amendments to the AWG and AWV to implement Directive (EU) 2024/1226

06 February 2026

The Act on the Adjustment of Criminal Offenses and Penalties for Violations of Restrictive Measures of the European Union (Gesetz zur Anpassung von Straftatbeständen und Sanktionen bei Verstößen gegen restriktive Maßnahmen der Europäischen Union), which came into force on 6 February 2026, adapts in particular the Foreign Trade and Payments Act (Außenwirtschaftsgesetz – AWG) and the Foreign Trade and Payments Ordinance (Außenwirtschaftsverordnung – AWV) to the requirements of the EU Directive on the definition of criminal offences and penalties for the violation of Union restrictive measures, Directive (EU) 2024/1226. The aim is to close loopholes in criminal liability and create a hrmonized, effective EU-wide criminal regime for violations of EU sanctions. The changes will in some cases lead to an increase in penal risks for companies and responsible persons. Numerous violations of EU sanctions that were previously only punishable as administrative offenses under German law will in future be prosecuted as criminal offenses, while at the same time new offenses will be introduced and existing penalties expanded. The most important changes for companies are outlined below.

Amendments to the AWG and AWV to implement Directive (EU) 2024/1226

EU and India reach political agreement on FTA – the 'mother of all deals'?

29 January 2026

With the political agreement on a Free Trade Agreement (“FTA”) between the European Union (“EU”) and India on January 27, 2026, a significant breakthrough has been achieved after years of negotiations. This article summarizes the key elements of the planned agreement and outlines the next steps toward its entry into force.

EU and India reach political agreement on FTA – the 'mother of all deals'?

Mercosur-EU-FTA close to the finishing line

12 January 2026

On 9 January 2026, the Mercosur-EU-Free Trade Agreement (Mercosur-EU-FTA) was approved by a majority of the member states of the European Union. This brings the agreement close to the finish line. This article provides an overview of the agreement's key aspects and the next steps.

Mercosur-EU-FTA close to the finishing line

The Omnibus I on the home straight

18 December 2025

On December 8, 2025, an agreement was reached in the EU trilogue procedure on the so-called "Omnibus I" proposal, which the European Commission had presented on February 26, 2025. Omnibus I is part of the simplification packages proposed by the Commission to reduce the regulatory burden on companies. The Omnibus I package addresses, in particular, the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). The so-called "stop-the-clock" directive, which was also adopted as part of Omnibus I in April 2025, had already postponed the application of the CSRD and CSDDD. The new directive is now intended to simplify certain substantive provisions of the CSRD and CSDDD.

The Omnibus I on the home straight

NIS-2 Implementation Act: New compliance obligations for numerous companies

10 December 2025

After the German Bundestag passed the NIS2 Implementation and Cybersecurity Strengthening Act (“NIS2UmsuCG”) in November 2025 and the Bundesrat approved it, the Act was published in the Federal Law Gazette on December 5, 2025, and entered into force the following day. The NIS2UmsuCG transposes the NIS2 Directive (EU) 2022/2555, adopted at the EU level, into national law, although with some delay. It introduces comprehensive amendments, particularly to the Federal Office for Information Security Act (“BSIG”). With the NIS2UmsuCG, in addition to the operators of critical infrastructure (“KRITIS”) already regulated, further entities will now be required to comply with the cybersecurity obligations stipulated in the amended BSIG. The scope of the BSIG is thus extended to approximately 30,000 additional companies across numerous sectors of the economy.

NIS-2 Implementation Act: New compliance obligations for numerous companies

Implementation of the EU Packaging Regulation (PPWR) in Germany

05 December 2025

On November 17, 2025, the Federal Ministry for the Environment, Climate Protection, Nature Conservation and Nuclear Safety (BMUKN) presented the draft bill for the new Packaging Law Implementation Act (VerpackDG-E). The current Packaging Act (VerpackG) is to be adapted to the requirements of the EU Packaging Regulation (Regulation (EU) 2025/40, Packaging and Packaging Waste Regulation – PPWR), which will apply from August 12, 2026. This article provides an overview of the background and key changes in packaging law.

Implementation of the EU Packaging Regulation (PPWR) in Germany

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