As part of the “Omnibus Package I,” the European Commission is proposing changes to the carbon border adjustment mechanism, responding to ongoing criticism from businesses regarding the complex regulations. At the same time, importers must continue preparing for full implementation in 2026. This article outlines the planned changes and shows what still needs to be done in 2025.

On February 5, 2025, the European Commission presented its toolbox for secure and sustainable e-commerce. The measures it contains are not new, but largely reiterate the Commission's proposals for reforming the Union Customs Code, which it presented in May 2023. What is new, however, is that the Commission wants to significantly accelerate the handling of current e-commerce challenges. Among other things, it proposes bringing forward the customs reform to 2026.

On 30 January 2025, the European Commission presented its report on the implementation of Regulation (EU) 2021/821 (Dual-Use Regulation) for the reporting period 2022–2023.

The implementation of Directives (EU) 2022/2555 (NIS-2 Directive) and (EU) 2022/2557 (CER Directive) has failed in Germany for the time being. As has now become known, the previous coalition partners were unable to agree on transposing the directives into German law after the government's collapse. Nevertheless, companies should assess whether they are likely to be affected by the implementing legislation and prepare to implement the associated obligations.

On 12 December 2024, Regulation (EU) 2024/3015 on the prohibition of products made using forced labour on the Union market (‘FLR’) entered into force. The ban will apply from 14 December 2027 to products that are placed on the EU market, made available or exported from the EU. The FLR follows, among others, the US ‘The Uyghur Forced Labor Prevention Act (’UFLPA‘)’, which also includes import bans on products from forced labour.