News

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.

Sep 19, 2025

Update of the EU List of Dual Use Items

Annex I of Regulation (EU) 2021/821 ("Dual-Use Regulation"), which lists goods, including software and technologies, that are to be classified as "dual-use" - meaning they are fit for civil as well as military use - and which are therefore always subject to an authorization requirement when exported from the EU, is usually updated once a year. On September 5, 2025, the European Commission published the draft of a Delegated Regulation amending Annex I (C(2025) 5947 final). The announced update brings numerous new technical entries, particularly in the areas of semiconductor technology, cryotechnology, and quantum computing. Companies that export goods to third countries should familiarize themselves with the changes shortly. The legal act is expected to enter into force at the end of 2025.

Sep 9, 2025

VAT Exemption on Exports: Actual Circumstances are Decisive

In its judgment of 1 August 2025 in Case C602/24, the Court of Justice of the European Union (CJEU) addressed the conditions for the exemption from value added tax (VAT) in the context of the export of goods under Directive 2006/112/EC on the common system of value added tax. The Court clarified that supplies may qualify for VAT exemption even if they were initially declared by the supplier as intra-Community supplies but were subsequently exported to third countries by the purchaser without the supplier’s knowledge. The Court thereby reaffirmed that it is the actual circumstances of the transaction that are decisive for the VAT exemption and that the intentions or assumptions of the taxable person are irrelevant. National formal requirements may not contradict this principle. However, this does not apply where the taxable person has acted in bad faith. Continuing its established case-law, the Court emphasized the principle of fiscal neutrality, the importance of good faith, and the irrelevance of formal breaches where the substantive conditions for VAT exemption are met.

News

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

Update of the EU List of Dual Use Items

VAT Exemption on Exports: Actual Circumstances are Decisive

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