EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.
New legislation
Transition Period for AES Extended Until December 14, 2025
On 11 February 2025, the Dutch Customs Administration announced that the final step towards the full implementation of the Automated Export System (AES) has been extended. Originally, EU member states were required to take a new step in the AES process before 11 February 2025; however, this has not been achieved in some cases. Consequently, the transition period has been extended until 14 December 2025, which is now designated as the TPendDate.
AES is a European automated system that facilitates the export process and replaces the current Export Control System (ECS). The system aims to enhance oversight of goods leaving the EU customs territory. The Netherlands was required to comply with AES regulations by the end of November 2023, which may have implications for businesses and software developers.
The implementation of AES stems from the Union Customs Code (UCC), which was introduced in 2016. EU member states are obligated to implement the UCC changes and comply with AES requirements, with further digitization of customs processes being a key objective. AES enables Customs authorities to exercise greater control over goods exiting the EU, thereby ensuring that shipments do not pose a threat to the security, health, and well-being of EU citizens.
16th package of economic and individual sanctions against Russia
On 24 February 2025, the European Council has adopted the 16th sanctions package against Russia. Below we will give a high-level overview of the new measures against Russia in the field of trade.
The EU Council has added 53 new entities to its sanctions list for directly supporting Russia's military and industrial complex in its aggression against Ukraine. These entities will face stricter export restrictions on dual-use goods and technologies, as well as items that could enhance Russia's defence capabilities.
The updated sanctions also expand the list of restricted items contributing to the technological advancement of Russia's military. New additions include chemical precursors for riot control agents, software for computer numerical control (CNC) machines, chromium compounds, and UAV controllers.
Furthermore, the EU has imposed additional restrictions on the export of goods that bolster Russia's industrial capacity, including certain chemicals, plastics, and rubber, along with limitations on their transit through Russia. Import restrictions on primary aluminium, a significant revenue source for Russia, have also been intensified.
These measures reflect the EU's ongoing commitment to countering Russia's military capabilities and supporting Ukraine.
Norway to join the EU’s Carbon Border Adjustment Mechanism (CBAM)
The Norwegian government has announced that it is planning to join the Carbon Border Adjustment Mechanism ("CBAM"), therewith becoming the first EFTA country joining this scheme.
The Norwegian government has stated that the preparations for CBAM will start in 2025, however it is still uncertain when CBAM will be fully implemented.
The Confederation of Norwegian Enterprise (NHO) has expressed concerns regarding the absence of a transitional period for Norwegian businesses. Since Norwegian importers did not participate in the CBAM trial phase, they may face competitive disadvantages once the mechanism is fully operational in 2026. Therefore, the NHO proposed to introduce a transitional period specially for Norwegian companies to ensure that they can adapt to the new rules.
While CBAM may initially pose challenges, Norway’s participation in the same system as the EU ultimately represents a significant opportunity. Aligning with European and global sustainability objectives will enable Norwegian businesses to maintain their competitiveness in an increasingly eco-conscious market. By committing to carbon reduction measures alongside the EU, Norway enhances its position in international trade. Early preparation will be essential to ensuring a seamless transition and mitigating potential disruptions, thereby positioning Norwegian companies for long-term success in a low-carbon economy.
CBAM simplifications – Omnibus I
On 26 February 2025, as part of the larger Omnibus I package, the Commission has published a proposal to amend the Carbon Border Adjustment Mechanism ("CBAM") Regulation to simplify and strengthen the current CBAM legislation. The proposed simplifications are expected to reduce the administrative burdens on entrepreneurs, particularly small importers.
Please see our alert about the proposed changes, here.
EUDR updates
- Additional dates for virtual training sessions on the EUDR Information System are available on the webpage of the European Commission. See this link and navigate to “Training and User Manuals” in the menu on the left hand side.
- On 20 February 2025, the European Commission published a new document on “Understanding your company position in the supply chain”. The document contains various scenarios for different types of supply chains and describes the EUDR related obligations of companies in the supply chain. The document can be accessed via this link.