EU Sustainability Policy News Feed

New EU-TARCI Codes for CBAM goods imports available Irish customs authority has officially made public the new EU TARIC Codes that are to be used by importers of CBAM goods when declaring goods for release for free circulation. These are to be applied from 1 January 2026. Seems to be an easy one. But be cautious. As usual, proper organization will be required. Examples: customs systems need to be updated, customs brokers need to be informed. Continuously, to reflect any changes of the CBAM status. That requires monitoring and workflow. Also, due diligence is required, especially in groups of companies having similar naming. It is an usual issue in practice that wrong EORI of group companies having a similar name is accidentally used in import declarations by customs service providers, respectively if import accompanying documentation was not clear enough. If that happens, now also the CBAM treatment can be messed up. Therefore, careful planning, instruction and workflow is needed. EY can help to thoughtfully analyze, plan and implement.

📢 Plenary Update: EUDR Delay Moves Forward ✅ In the plenary on this date, the Parliament voted for a 12-month delay to hashtag#EUDR. This aligns with the Council and goes further than the original Commission proposal, which only suggested a delay for smaller enterprises. While not yet law, this alignment strongly signals that a year’s delay is now extremely likely. 🔍 Key Highlights: 🗓 Parliament calls for a review of the “administrative burden” of EUDR by Spring 2026, making further simplification likely. 🔜 Next steps: trilogue negotiations begin soon. With 30 December looming and political alignment on the delay, expect this to feature in any eventual deal. 🗳 Final vote on the legislative proposal is expected 15–18 December. ❓ Open Questions that keep me awake at night: 🔄 How to treat re-imports of EUDR products previously placed on the market? 🌍 How to export products that were put on the market by a Tier-N supplier without the obligation to hand down DDS? ⚖️ Who carries liability, given significant penalties remain? 📅 How to prepare for next year, with a review planned for April 2026? 📌 Footnote: The EPP voted again with the right, as seen in the recent Omnibus vote. How will this impact sustainability measures in the EU going forward?

EUDR: European Parliament supports simplification measures Today, the European Parliament adopted its position on simplifying the implementation of the EU Deforestation Regulation (EUDR). Important: This is not a final decision. The deadlines are not officially postponed. This is solely the Parliament’s position, which now enters negotiations with the Council and the Commission. Parliament’s proposed extension: Large companies: application from 30 December 2026 Micro and small companies: application from 30 June 2027 Parliament’s proposed simplifications: The obligation to submit the due-diligence statement should apply only to the operator who first places the product on the EU market, not to all downstream operators or traders. Micro and small primary operators should be required to submit only a one-off simplified declaration. Next steps: The text now moves into trilogue negotiations between: the European Parliament the Council of the EU the European Commission A deadline extension or simplification will only become legally binding once all three institutions agree on a final joint text and it is published in the Official Journal of the EU.

EUDR European Parliament Votes - 26.11.25* ➡️ KEY CHANGES - Entry into application delayed by 12 months - Only first operators submit DDSs - Only first downstream operators (and traders TBC) collect upstream reference numbers - Review clause by 30 April 2026 ➡️ NEW CATEGORIES - Four-tier system (no risk category) rejected - Micro and small primary operators category accepted / can provide postal addresses instead of geolocation data ➡️ LIGHTER OBLIGATIONS - Collect reference numbers only if supplier is (first) operator - Remove obligations for downstream operators (and traders TBC) to communicate reference numbers downstream - Remove obligation to communicate reference numbers to customs authorities upon export, when not first operator ➡️ SCOPE AND REVISIONS - Review of EUDR scope (commodities and ecosystems) not removed - Printed books, newspapers, and other products of the printing industry removed from the scope ➡️ OPEN QUESTIONS - Maintenance of parallelism between downstream operators and traders - How to prove a relevant product was already subject to due diligence and covered by a DDS if it was exported and is being re-imported into the EU - Purpose of the requirement of non-SME downstream operators and traders to register in TRACES (check validity of upstream reference numbers? Information for NCAs?) * After first, cursive reading. May be amended and/or completed. Jeroen Truin Ashish Sinha Jonathan Baumeler Ramona Hinny-Broger Ivan Kostakev Leonie Smit Salvador Sullivan Fabienne Gauch Evelina B. Jan Steiner Alain Al Chahabi

🚨 hashtag#CBAM draft benchmarks, here’s the leaked draft behind today’s noise. If your feed exploded today with urgent CBAM webinars and “exclusive updates”, you’re not alone. A leaked draft of Benchmarks has been circulating, and many (including myself) were trying to understand where it came from, but it is finally here! Key points from the leaked draft: • Benchmarks differ for actual vs. default values • Complex goods require precursor benchmark adjustments • Benchmarks depend on production routes • Separate benchmarks for grey vs. white clinker • Period-specific benchmarks for some CN codes • Default values may reflect country-specific production routes No official text has been published yet, but it is important to follow. A quick reminder: CBAM has always been about community, transparency, and helping each other navigate the details. Let’s keep that spirit 😉 🤝

New SFDR updates in under 90 seconds below! The EU Commission's Final Proposal is a hard reset of the Sustainable Finance Disclosure Regulation (SFDR). We put together the table below and this summary to let you know what the new articles say. If you advise clients, run funds, or sit in risk/compliance, these changes will shape your 2027–2028 strategy. Here are the new SFDR product categories: 1. Article 7 — Transition -For products backing companies/projects on a credible transition path. -70% of the portfolio must support the transition objective. -Partial Paris-Aligned Benchmark exclusions apply. -Product-level PAI disclosures required. -May use the word “impact” if criteria are met. 2. Article 8 — ESG Basics -Integrates ESG beyond risk management, but without transition or sustainability objectives. -Requires 70% alignment with the stated ESG strategy. -Limited exclusions. -No PAI requirement at product level. -Much narrower than today’s Article 8. 3. Article 9 — Sustainable Features -For products investing in already sustainable assets or pursuing a sustainability objective. -70% sustainable alignment required. -EU Taxonomy ≥15% counts as meeting the 70% test. -Full PAB exclusions, including strict fossil-fuel limits. -PAI disclosures + extra reporting for impact funds. 4. Article 9a — Mixed Products -For portfolios blending Article 7 and Article 9 approaches across asset classes. -Still must meet the 70% threshold using Article 9 criteria. -Not a new label—more a structural option for multi-asset strategies. 5. Article 6a — ESG-Uncategorised Products -Cannot use ESG wording in names. -Any sustainability statements must be minimal and secondary (<10% of strategy description). -Designed to eliminate ESG-lite positioning. What this all means: No grandfathering. No professional-investor opt-outs. The old Article 8/9 system will go away. Disclosures will be simpler, but product requirements will be sharper and more rule-based. Private markets will get clarity on ramp-up periods. The legislative process will take 12–18 months, followed by a transition period. We are helping investors navigate these new requirements and stay ahead of the curve. Get in touch for our full analysis on SFDR and to learn more! hashtag#sfdr hashtag#EU hashtag#sustainablefinance hashtag#investors

The European Commission has just released the final version of the hashtag#SFDR simplification proposal. Key elements of the proposal: 1️⃣ Entity-level PAI disclosures: Most financial market participants will no longer need to report entity-level PAIs. 2️⃣ Product-level disclosures: Disclosures will focus on data that is "available, comparable, and meaningful", aligned with the three new product categories and easier for retail investors to interpret. 3️⃣ A three-tier product categorisation system: (1) Sustainable: products contributing to sustainability goals and meeting high sustainability standards, (2) Transition: investments backing credible environmental or social improvements.(3) ESG Basics: broader ESG approaches without meeting the first two categories. All categories must channel 70% of the portfolio into the stated sustainability strategy and exclude harmful activities (e.g., tobacco, prohibited weapons). And importantly: “ESG” claims in product names and marketing will be reserved for categorised products, a step to restore trust and curb greenwashing. 👉 Let’s hope Parliament and Council now move it forward constructively, without watering it down under vague notions of “competitiveness.”

The latest developments around the EU Deforestation Regulation (EUDR) show an increasingly divided landscape. In the past 24 hours, political institutions and industry groups have taken sharply contrasting positions on whether the EUDR should be postponed or implemented as planned. On 19 November 2025, the Council of the European Union announced that it has adopted its negotiating mandate on the Commission’s proposed targeted amendment to the EUDR. The Council supports a one year postponement of compliance deadlines, shifting obligations for large and medium companies to 30 December 2026 and for micro and small enterprises to 30 June 2027. Source: Council press release This formal position allows the Council to begin negotiations with the European Parliament, which must also approve the amendment before any delay can take effect. At the same time, industry and civil society groups have issued a strong and coordinated response. A coalition representing companies and NGOs in the cocoa, coffee, palm oil, rubber and timber sectors released an open call urging EU institutions to avoid another EUDR delay. The coalition argues that postponement threatens long term forest protection goals, undermines regulatory certainty and penalizes companies that have already invested in due diligence and traceability systems. Source: Business and Human Rights Resource Centre These two developments amount to a clear split. While the Council is pushing for additional time, a significant part of the industry is asking the EU to uphold the regulation’s original timeline and deliver clarity. Why this matters for businesses preparing for EUDR compliance This divergence creates a challenging environment for companies operating in EUDR regulated supply chains. The outlook remains unsettled because: The Council supports a postponement, but the European Parliament has not secured consensus on the amendment. Key stakeholders in the most affected sectors are now advocating for immediate implementation, creating pressure to maintain the original schedule. The future compliance date depends on negotiations between the Council and Parliament, and final agreement may not arrive until the end of the year. The regulation’s core requirements such as traceability, geolocation data, legality verification and due diligence obligations remain fully intact, regardless of the final timeline. For companies that paused their EUDR readiness projects, the current situation increases exposure. Traceability mapping, supplier documentation, risk assessment and data verification all require time and coordinated effort. Delaying preparation now increases the risk of being unprepared when enforcement begins, whether in 2025 or 2026. Search interest around EUDR delay, EUDR timeline, and EUDR enforcement date continues to rise, and many businesses are closely watching the upcoming negotiations. Strategic takeaway The next stage of the amendment process moves to formal negotiations between the European Parliament and the Council. Until those negotiations conclude, the EUDR timeline remains uncertain but the regulatory requirements do not. Companies that continue with preparation and maintain due diligence work will be in a stronger position both operationally and reputationally when the final timeline is confirmed. Trusty Compliance continues to monitor the Commission and Parliamentary discussions closely. Our priority is to ensure that all clients remain aligned with the Regulation’s current requirements and prepared for any upcoming adjustments. Trusty’s EUDR Passport and Supply Chain Monitor solutions already provide the infrastructure to meet these obligations, with adaptable workflows designed to incorporate any future modifications once officially adopted.

𝗕𝗿𝗲𝗮𝗸𝗶𝗻𝗴 𝗡𝗲𝘄𝘀: 𝗧𝗵𝗲 𝗘𝗨 𝗣𝗮𝗿𝗹𝗶𝗮𝗺𝗲𝗻𝘁 𝗵𝗮𝘀 𝗷𝘂𝘀𝘁 𝘃𝗼𝘁𝗲𝗱 𝘁𝗼 𝘀𝘂𝗯𝘀𝘁𝗮𝗻𝘁𝗶𝗮𝗹𝗹𝘆 𝗿𝗲𝗱𝘂𝗰𝗲 𝘁𝗵𝗲 𝘀𝗰𝗼𝗽𝗲 𝗼𝗳 𝗘𝗨 𝘀𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗿𝘂𝗹𝗲𝘀. 𝗜𝘁 𝗽𝗿𝗶𝗼𝗿𝗶𝘁𝗶𝘀𝗲𝘀 𝗱𝗲𝗿𝗲𝗴𝘂𝗹𝗮𝘁𝗶𝗼𝗻 𝗮𝗻𝗱 𝘄𝗶𝗹𝗹 𝗿𝗲𝘀𝗵𝗮𝗽𝗲 𝘁𝗵𝗲 𝗳𝘂𝘁𝘂𝗿𝗲 𝗼𝗳 𝗖𝗦𝗥𝗗 𝗮𝗻𝗱 𝗖𝗦𝗗𝗗𝗗 𝗳𝗼𝗿 𝘆𝗲𝗮𝗿𝘀 𝘁𝗼 𝗰𝗼𝗺𝗲. The European Parliament adopted its negotiating position on the "Omnibus I" package today. This vote, passed by a new centre-right and right-wing alliance, aims to simplify rules and cut red tape for European businesses. This marks a significant political shift. It provides a clear direction after a long period of regulatory uncertainty that followed the rejection of a prior compromise in October. 𝗛𝗲𝗿𝗲 𝗮𝗿𝗲 𝘁𝗵𝗲 𝗽𝗿𝗶𝗺𝗮𝗿𝘆 𝗰𝗵𝗮𝗻𝗴𝗲𝘀 𝗶𝗻 𝘁𝗵𝗲 𝗣𝗮𝗿𝗹𝗶𝗮𝗺𝗲𝗻𝘁'𝘀 𝗽𝗼𝘀𝗶𝘁𝗶𝗼𝗻: 🔸 The CSDDD will now apply only to very large firms, with thresholds raised to companies with over 5,000 employees and €1.5 billion in net turnover. 🔸 The mandatory requirement for companies to adopt a climate transition plan under the CSDDD has been removed. 🔸 Due diligence obligations are now focused on a "risk-based approach" and direct business partners, rather than the entire value chain. 🔸 Sector-specific European Sustainability Reporting Standards (ESRS) are set to become voluntary. 𝗠𝘆 𝗧𝗮𝗸𝗲 This vote is a clear setback for sustainability disclosure and for the original ambition of the EU Green Deal. Make no mistake, the rollbacks on climate plans and value chain due diligence are substantial, and they shift the burden of accountability onto the very largest companies. However, the deadlock is now over. For businesses, the extended period of EU uncertainty has been a major challenge. This vote, while a dilution, provides a clear (if very different) path forward. And it is progress nonetheless. This should be viewed as a baseline. It is better to have a weak framework that can now be built upon, than no framework at all. These thresholds and rules can be amended in the future as the market adapts. Now, it's time to move on, and work with the rules we have been handed down. hashtag#EU hashtag#Sustainability hashtag#CSRD hashtag#CSDDD hashtag#ESGRaporting hashtag#DueDiligence hashtag#EUGreenDeal hashtag#Regulation

It's been quite the week for the world of sustainability - and our EY team! Some updates for you to be aware of: 📄 Published 📄- The Omnibus simplification package for the EU CBAM has been officially published - bringing the changes into reality. Richard J. Albert's summary here is a great place to see what is changing: https://lnkd.in/eUASnKCe 🚫 Rejected 🚫- The EU Parliament rejected a mandate on EU CSRD and CSDDD "Omnibus" simplification packages, meaning more voting (and likely policy change) is required - such as via the proposed vote in November: https://lnkd.in/evkeDy-y 🌲 Proposed 🌲- More changes to the EU Deforestation regulation (EUDR) have been proposed by the EU Commission, expected to change timelines and compliance. Check out Ossian Nilsson's great summary here: https://lnkd.in/eTV2CBuT 🚢 Delayed 🚢- Decisions on the International Maritime Organisation (IMO) proposed carbon price have been delayed by a year, potentially delaying any applicability to beyond 2028. More from Reuters here: https://lnkd.in/e27gAJei In the meantime, we've been busy ourselves! 🧩 On Friday, we launched our "Total Reporting" framework to a packed house of ESG reporting professionals. I loved Rebecca Donnellan's summary here: https://lnkd.in/e6vdpGWa 📊 Since then, EY has launched our annual reporting package - the Value Realized report. This covers both our financial and non-financial reporting - check it out here: https://lnkd.in/ecUZPeyU ⚙️ For me, this all followed a great session the prior week on Controls (ESG and beyond!) for the Industrials sector from David Lee and the EY Birmingham team. Check out his summary post here: https://lnkd.in/euQFPV2Y It's difficult to keep up with all of this movement - amidst a sea of other policy change and corporate activity. If a catch-up with me or the team to help stay on top of things is ever helpful, do reach out. Rob Doepel Alenka Turnsek Danny An Khoi Vu Mark Feldman Laura Saavedra Hetika Shah Jemma Snelling Edward Ripley Piers C. Lee Downham David Evans George Davidson Gerard Gallagher

Looking forward to the EUDR (EU Deforestation Regulation) Webinar for Swiss Exporters: 📅 Webinar registration: https://lnkd.in/ed_hxqSZ 🕚 3 December 2025 | 11:00–12:00 CET Alfonso Orlando Stephan Geiger Some initial thoughts on the simplifications proposed on the 21th of October 2025 by the EU Commission 🔍 ✅ Simplification for Downstream Operators & Traders No reference to upstream DDS required. However, non-SME downstream operators and traders must still register in TRACES. 🧾 New Category: Micro & Small Primary Operators Eligible if based in a “low risk” country. Can submit simplified declarations (Annex III) and receive declaration identifiers. Allowed to use other EU systems for filing; Member States will upload these into TRACES. May disclose postal addresses instead of geolocation data. 👤 Authorised Representatives Will now only represent operators, not traders. 🔄 Clarified Roles Downstream operators and traders are now jointly addressed under Article 5 📅 SME Qualification Cut-Off Extended from 31 December 2020 to 31 December 2024. 🕒 Timeline Adjustments Go-live for non-SME operators remains 30 December 2025. Enforcement (partly) deferred by 6 months - to be further analyzed

𝗕𝗿𝗲𝗮𝗸𝗶𝗻𝗴 𝗻𝗲𝘄𝘀 𝗼𝗻 𝗢𝗺𝗻𝗶𝗯𝘂𝘀 - 𝘁𝗵𝗲 𝗘𝗨 𝗣𝗮𝗿𝗹𝗶𝗮𝗺𝗲𝗻𝘁 𝘃𝗼𝘁𝗲𝗱 𝗮𝗴𝗮𝗶𝗻𝘀𝘁 𝗝𝗨𝗥𝗜 𝗰𝗼𝗺𝗽𝗿𝗼𝗺𝗶𝘀𝗲 A lot has happened regarding Omnibus the last weeks. The thriller continues…. 𝟭. 𝗖𝗦𝗥𝗗/𝗖𝗦𝗗𝗗𝗗: 𝗘𝗨 𝗽𝗮𝗿𝗹𝗶𝗮𝗺𝗲𝗻𝘁 𝗷𝘂𝘀𝘁 𝗱𝗲𝗰𝗶𝗱𝗲𝗱 𝚊̲𝚐̲𝚊̲𝚒̲𝚗̲𝚜̲𝚝̲ 𝘀𝘂𝗽𝗽𝗼𝗿𝘁𝗶𝗻𝗴 𝘁𝗵𝗲 𝗝𝗨𝗥𝗜 𝗰𝗼𝗺𝗽𝗿𝗼𝗺𝗶𝘀𝗲 🗳️ 🇪🇺 Thus, instead of starting the trilogue with Commission and Council on Friday, the EU parliament will now have a discussion on Omnibus #81 in their next plenary session on 11-13. November. The proposal of the JURI committee incl. an increase of the thresholds to: - 1000 employees + 450m€ revenue for CSRD - 5000 employees + 1.5b€ revenue for CSDDD However, this proposal was only supported by the EPP, S&D and Renew. In the secret vote in parliament 𝟯𝟬𝟵 𝗠𝗘𝗣𝘀 𝘄𝗲𝗿𝗲 𝗶𝗻 𝗳𝗮𝘃𝗼𝘂𝗿, 𝘄𝗵𝗶𝗹𝗲 𝟯𝟭𝟴 𝘃𝗼𝘁𝗲𝗱 𝗮𝗴𝗮𝗶𝗻𝘀𝘁. 𝟮. 𝗖𝗕𝗔𝗠 𝗳𝗶𝗻𝗮𝗹𝗹𝘆 𝗶𝗺𝗽𝗹𝗲𝗺𝗲𝗻𝘁𝗲𝗱 ✅ On October 20th, the Omnibus amendments to the CBAM Regulation entered into force, including the new threshold of 50 tonnes per year and material group, and the postponement of the first CBAM report to September 2027 (for the year 2026). 𝟯. 𝗘𝗨 𝗧𝗮𝘅𝗼𝗻𝗼𝗺𝘆 𝘀𝗰𝗿𝘂𝘁𝗶𝗻𝘆 𝗽𝗲𝗿𝗶𝗼𝗱 𝗽𝗿𝗼𝗹𝗼𝗻𝗴𝗲𝗱 𝘁𝗼 𝗝𝗮𝗻 𝟱𝘁𝗵 𝟮𝟬𝟮𝟲 ⌛ The substantive amendments to the EU Taxonomy proposed by the European Commission — such as the 𝗺𝗮𝘁𝗲𝗿𝗶𝗮𝗹𝗶𝘁𝘆 𝘁𝗵𝗿𝗲𝘀𝗵𝗼𝗹𝗱 𝗼𝗳 𝟭𝟬% and the 𝘀𝗶𝗺𝗽𝗹𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻 𝗼𝗳 𝗰𝗲𝗿𝘁𝗮𝗶𝗻 𝗗𝗡𝗦𝗛 𝗰𝗿𝗶𝘁𝗲𝗿𝗶𝗮 — have been under review by the Council and Parliament since July 4. This review period has now been extended to six months (until January 4, 2026) as stated in a joint meeting of the ECON & ENVI committees on October 6th. 𝟰. 𝗚𝗲𝗿𝗺𝗮𝗻 𝗖𝗦𝗥𝗗 𝗹𝗮𝘄🧑‍⚖️ 🇩🇪 The government draft has been referred to the Committee on Legal Affairs and Consumer Protection on October 9th. It already reflects the 𝘀𝘁𝗼𝗽-𝘁𝗵𝗲-𝗰𝗹𝗼𝗰𝗸 rule and the 𝟭,𝟬𝟬𝟬-𝗲𝗺𝗽𝗹ovyee threshold from the Omnibus proposal. The Bundesrat also voted in favour of the government draft last Friday. 𝗔𝗹𝘀𝗼: 𝗛𝗼𝘁 𝗻𝗲𝘄𝘀 𝗰𝗼𝗺𝗶𝗻𝗴 𝗼𝗻 𝗘𝗨𝗗𝗥 🌴 The Commission published its proposed amendments to EUDR yesterday. It shall enter into force as planned on December 30th for medium and large companies (no delay), but get a 6-month grace period, with checks only starting on June 30th 2026. The biggest simplification is that downstream operators and traders are proposed to be exempt from due diligence requirements and filing DDSs, and only need to obtain and keep records of DDS references. Small and micro operators would get further simplifications and a delay until 30.12.2026. ⬇️ Links in the comments 𝘛𝘩𝘢𝘯𝘬𝘴 𝘵𝘰 Andreas Rasche 𝘢𝘯𝘥 Dr. Martin W. Schönberger

EUDR Simplification Proposal - Technical Details (in addition to widely circulated updates)* 1. Removal of references to upstream DDSs - HOWEVER, non-SME downstream operators and non-SME traders must still register in TRACES 2. New category of « micro and small primary operators » with special regime: - Submit « simplified declarations » (instead of DDSs) as per Annex III, and receive « declaration identifiers » that they communicate - Are allowed to use other EU systems to file simplified declarations; and Member States are responsible for adding those in TRACES - Instead of disclosing geolocation data, can disclose postal addresses Important note: must be established in a country classified as « low risk » 3. Authorised representatives would only represent operators (no longer traders) 4. Downstream operators and traders addressed jointly under Art. 5 (removal of uncertainties on different regimes) 5. Timelines changed for enforcement and reviews 6. SME qualification cut-off date moved from 31 December 2020 to 31 December 2024 *Based on a cursive reading - this post may be amended *Subject to adoption by EU institutions #EUDR #EU #Deforestation #Regulation #BHR #GreenDeal #Simplifications Relevant documentation: https://lnkd.in/eX9r7qCk

🌍 EUDR to Enter into Application on 30 December 2025 — No Delay Expected The European Commission has proposed targeted adjustments to support the timely rollout of the EU Deforestation Regulation (EUDR) — confirming that the regulation will enter into application as planned. 📅 Compliance timelines: Large and medium companies: 30 December 2025, with a six-month grace period for enforcement Micro and small enterprises: 30 June 2026 Key updates include: 🎯A streamlined IT system requiring only one due diligence statement at the market entry point 🎯Simplified reporting for micro and small operators from low-risk countries 🌱 🎯Reduced obligations for downstream actors such as retailers and manufacturers 📉 These measures aim to reduce administrative burden by up to 30%, while maintaining robust tracking and compliance mechanisms. 🗣️ Next step(s)The European Parliament and the Council will now discuss the Commission's proposal. They would need to formally adopt the targeted amendment of the EU Deforestation Regulation before it can come into effect. The Commission calls on both institutions to swiftly adopt the proposal for an extended implementation period by the end of 2025.

✅⚖️𝗙𝗶𝗻𝗮𝗹𝗹𝘆! 𝗧𝗵𝗲 𝗖𝗕𝗔𝗠 𝘀𝗶𝗺𝗽𝗹𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻 𝗶𝘀 𝗼𝗳𝗳𝗶𝗰𝗶𝗮𝗹. The amended regulation has just been published in the Official Journal (🗓️17 October 2025) and will enter into force three days later. The main features of the new CBAM regime: 🧾 De minimis exemption: mass-based threshold of 50 tonnes/year (excl. H₂ & electricity). 💰 Carbon price deduction: importers may deduct carbon costs paid in any third country. 📋 Delegated reporting: declarants can assign a "CBAM representative" to report. ⏳ Reporting deadline: now 30 September of each year. ✅ Verification: only actual emission values must be verified; default values exempt. 🔁 Default values: now permitted. 📆 Certificate purchase for 2026 emissions starts Feb 2027. 📉 Certificate ratio: quarterly coverage dropped to 50% and the free allocation of EU ETS allowances has been integrated. 🔄 Repurchase deadline: 31 October of each year. We now await the forthcoming non-legislative acts to complete the picture. #CBAM #trade #customs

In a post for the Oxford Business Law Blog, my colleague Jeroen Truin and I break down the practical implementation challenges caused by the EU Regulation on Deforestation-Free Products (#EUDR), highlighting blind spots and compliance hurdles, and providing recommendations across three key groups: policymakers, enforcement authorities, and businesses. The regulation, entering into application on 30 December 2025, spearheads the EU’s second corporate sustainability legislative wave, focusing on supply-chain due-diligence obligations with heavy sanctions in case of incompliance. The first legislative wave focused on transparency through mandatory disclosure obligations. The observations and recommendations are relevant not only for the EUDR, but also for upcoming EU sustainability due-diligence legislation such as the Corporate Sustainability Due Diligence Directive (#CSDDD), the Forced Labour Regulation (#EUFLR), the Batteries Regulation (#EUBR), and the Ecodesign for Sustainable Products Regulation (#ESPR).