On the night of September 28, 2025, the deadline for the so-called "snapback mechanism" initiated by Germany, France, and the United Kingdom expired. This means that the UN Security Council sanctions against Iran, which had been suspended since January 2016, are back in force. The EU reacted immediately and transposed the UN sanctions into directly applicable EU law.

On September 29, 2025, a new Interim Final Rule of the US Bureau of Industry and Security came into effect, extending (re-)export control restrictions to affiliated companies of certain listed companies.

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

Annex I to Regulation (EU) 2021/821 (the “Dual-Use Regulation”), which lists goods, including software and technologies, that are classified as “dual-use” – meaning they can be used for both civilian and military purposes – and are therefore always subject to export authorization from the EU, is usually updated annually. On 8 September 2025, the European Commission published a draft Delegated Regulation amending Annex I (C(2025) 5947 final). The announced update introduces numerous new technical entries, particularly in the areas of semiconductor technology, cryogenics, and quantum computing. Companies exporting goods to third countries must familiarize themselves with the changes promptly. The regulation is expected to enter into force at the end of 2025.

In its judgment of 1 August 2025 in Case C-602/24, the European Court of Justice (ECJ) addressed the conditions for VAT exemption on the export of goods under VAT Directive 2006/112/EC. The Court clarified that supplies originally declared by the supplier as intra-Community supplies, but subsequently delivered by the purchaser to locations outside the EU without the supplier's knowledge, can also qualify for VAT exemption. It thus reaffirmed that the actual circumstances alone are decisive for VAT exemption, and the taxpayer's intentions and beliefs are irrelevant. Formal requirements under national law must not preclude this. As in all cases of this kind, this does not apply if the taxpayer acts in bad faith. Continuing its established case law, the ECJ emphasizes the principle of fiscal neutrality, the importance of good faith, and the irrelevance of formal violations if the substantive requirements for VAT exemption are met.

On August 28, 2025, Germany, France, and the United Kingdom triggered the snapback mechanism provided for in Security Council Resolution 2231 (2015). This could lead to the reinstatement of the economic sanctions imposed on Iran by the UN Security Council. The sanctions had been suspended in 2015 in exchange for Iran's commitment to dismantle its nuclear program under the Joint Comprehensive Plan of Action (JCPoA). Due to Iran's continued violations of the JCPoA's obligations and the failure of negotiations on a possible successor agreement, the sanctions could now be reinstated unless an agreement is reached within 30 days.

The Federal Ministry of Labor and Social Affairs (BMAS) published its draft bill of July 28, 2025, to amend the Supply Chain Due Diligence Act (LkSG). The draft bill provides significant relief for companies. Key points include the abolition of the reporting obligation and a restriction of the offenses punishable by fines. The Federal Office for Economic Affairs and Export Control (BAFA) will retain its auditing powers.

On July 22, 2025, the European Commission published a Call for Evidence in advance of a potentially forthcoming environmental omnibus package. The aim is to simplify and harmonize regulatory requirements in the environmental sector concerning waste, products, and industrial emissions, and to reduce the bureaucratic burden on businesses, without compromising the objectives pursued by the legislation. We provide an overview of the omnibus project and your opportunities to participate.

On 16 July 2025, the European Commission presented a comprehensive proposal for the recasting of Directive 2011/64/EU (Tobacco Tax Directive). The recasting of the Tobacco Tax Directive aims to fundamentally modernize the taxation of tobacco and related products.