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Feb 20, 2025

Fast-track for the EU Customs Reform?

On 5 February 2025, the European Commission presented its toolbox for safe and sustainable e-commerce. The tools contained in the toolbox are not new. They essentially repeat the Commission's proposals for a reform of the Union Customs Code, which it presented in May 2023. What is new, however, is that the Commission is seeking to significantly speed up the legislative process to address the current challenges posed by e-commerce imports. Among other things, the Commission proposes to frontload the customs reform to 2026.

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Feb 10, 2025

European Commission report on trade in dual-use items published

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

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Feb 5, 2025

Critical infrastructures: No transposition of the NIS-2 and CER Directives before the federal elections

The implementation of Directives (EU) 2022/2555 (NIS-2 Directive) and (EU) 2022/2557 (CER Directive) in Germany has failed for the time being. As was recently reported, the previous "traffic light" coalition partners have no longer been able to agree on the transposition of the directives into German law after the government fell apart. Irrespective of this, companies should review whether they are likely to be affected by the transposition laws and prepare themselves for the implementation of the relevant obligations.

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Jan 15, 2025

New General Export Authorizations simplify exports of military and dual-use items

As of 15 January 2025, General Export Authorizations (GEAs) No. 13 and No. 25 are being extended to allow the export of dual-use and military items in connection with the German Federal Government’s enhancement measures. In addition, further military items are included in GEA No. 33. With regard to dual-use items, there are new GEAs for (re-)exports after maintenance, repair or for replacement as well as for intra-group software and technology exports.

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Jan 10, 2025

End-use documents: New requirements and templates

On December 10, 2024, two BAFA general orders came into force that are important for many exporting companies. Firstly, the BAFA eased its earlier formal require-ments for end-use documents, particularly with regard to the previously mandatory handwritten signature. It also published two new templates to be used when applying for authorizations for the export of export-controlled items to Russia and Belarus.

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Jan 8, 2025

Amendments to the reporting system (AWV reports) entered into force

On 1st January 2025, important amendments to the reporting system (Sections 63 ff. AWV) came into force, which have to be complied with for the first time for the reporting month of January 2025. In particular, the German Federal Government has increased the reporting thresholds and partially standardized reporting deadlines. In addition, clarifications were introduced with regard to the transfer of crypto assets and changes were made to reporting obligations for interest payments for foreign bonds and money market securities.

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