Review of EU Legal Acts
Commission Implementing Regulation (EU) 2025/902 – African Swine Fever Control Zones
This regulation modifies the areas designated as restricted zones due to African Swine Fever (ASF) outbreaks. It amends Annex I of Implementing Regulation (EU) 2023/594, redefining Zones I, II, and III in Member States based on the latest ASF outbreaks in both wild and domestic pigs.
The updated annex specifies geographical areas within Member States, categorized by risk level: Zone I (lower risk), Zone II (higher risk), and Zone III (highest risk, recent outbreaks). It addresses changes in the ASF situation in Germany, Estonia, Latvia, Hungary, Poland, Czechia, Greece, Italy and Slovakia, leading to the demarcation of new restricted zones in these countries.
The zoning relies on the epidemiological situation, overall ASF status, spread risk, EU ASF guidelines, WOAH standards, and Member State justifications. Affected Member States are obliged to implement special disease control measures within these zones, including restrictions on pig movement and biosecurity enhancements.
Commission Implementing Regulation (EU) 2025/900 – Avian Influenza and Poultry Imports
This regulation amends Implementing Regulation (EU) 2021/404 by updating Annexes V and XIV, which list third countries authorized to export poultry and related products to the EU.
It adjusts the entries for Canada, the United Kingdom, and the United States, modifying which zones within these countries can export poultry products to the EU. These changes reflect recent outbreaks of highly pathogenic avian influenza (HPAI) and control measures implemented.
Some zones previously restricted due to HPAI have been re-authorized, while new zones in Canada and the US with recent outbreaks are now restricted. The regulation also corrects a numbering error related to a specific zone in the United States (US-2.997) introduced by Implementing Regulation (EU) 2025/641.
Council Implementing Regulation (EU) 2025/886 – Cyber-attacks Sanctions
This regulation amends Annex I to Regulation (EU) 2019/796, updating the reasons for including six individuals already under restrictive measures for cyber-attacks threatening the EU.
The updated entries provide details about their involvement in cyber-attacks, particularly those targeting the Organisation for the Prohibition of Chemical Weapons (OPCW) and the German federal parliament (Deutscher Bundestag). The updated entries also mention indictments by a grand jury in the United States for related crimes.
The updates serve to reinforce the reasons for maintaining these individuals on the sanctions list.
Council Regulation (EU) 2025/903 – Sanctions Concerning Ukraine’s Territorial Integrity
This regulation amends Council Regulation (EU) No 269/2014, introducing a new criterion for listing individuals or entities involved in transferring ownership or control of business interests from sanctioned Russian businesspersons.
It adds a new point (m) to Article 3(1), targeting those enabling the transfer of ownership from sanctioned individuals if it significantly frustrates existing sanctions, with exceptions for transfers explicitly permitted by EU regulations.
A new Article 3(1b) addresses leading businesspersons in Russia who claim to have transferred their business interests after February 24, 2022. These individuals will remain on the sanctions list unless they provide sufficient, recent, and reliable information proving they no longer meet the original criteria for being sanctioned.
Commission Regulation (EU) 2025/877 – Cosmetic Products
This regulation amends Regulation (EC) No 1223/2009 on cosmetic products. It updates the list of prohibited or restricted substances to reflect the latest scientific classifications of certain substances as carcinogenic, mutagenic, or toxic for reproduction (CMR).
It adds several newly classified CMR substances to the list of prohibited substances in Annex II and removes one substance, Trimethylbenzoyl Diphenylphosphine Oxide, from the list of allowed substances for restricted use in Annex III.
Additionally, it clarifies the chemical name and CAS number for cymoxanil in Annex II to align with the corresponding entry in Regulation (EC) No 1272/2008. The most important provision is the immediate prohibition of the newly listed CMR substances in cosmetic products from 1 September 2025.
Review of each of legal acts published today:
Commission Implementing Regulation (EU) 2025/902 of 12 May 2025 amending Annex I to Implementing Regulation (EU) 2023/594 laying down special disease control measures for African swine fever
Here’s a breakdown of the Commission Implementing Regulation (EU) 2025/902:
**1. Essence of the Act:**
This regulation amends Annex I of Implementing Regulation (EU) 2023/594, which outlines special disease control measures for African swine fever (ASF). The key purpose is to update and redefine the restricted zones (Zones I, II, and III) in specific Member States due to new outbreaks of ASF in both wild and kept porcine animals. This aims to control the spread of the disease based on the latest epidemiological situation.
**2. Structure and Main Provisions:**
* **Amends Annex I:** The core of the regulation is the replacement of Annex I in the original Implementing Regulation (EU) 2023/594 with a new version. This annex lists the restricted zones I, II, and III within Member States.
* **Restricted Zones:** The annex details specific geographical areas within Member States, categorized into restricted zones based on the risk level associated with ASF outbreaks.
* **Zone I:** Areas with a lower risk.
* **Zone II:** Areas with a higher risk than Zone I.
* **Zone III:** Areas with the highest risk, typically where recent outbreaks have occurred.
* **Member States Affected:** The regulation specifically addresses changes in the ASF situation in Italy and Slovakia, leading to the demarcation of new restricted zones in these countries. It also includes changes in restricted zones in Germany, Estonia, Latvia, Hungary, Poland, Czechia and Greece.
* **Criteria for Zoning:** The amendments are based on:
* The epidemiological situation of ASF in affected areas.
* The overall ASF situation in the Member State.
* The risk of further spread.
* Scientifically agreed principles and criteria for zoning, as outlined in the EU’s ASF guidelines.
* International standards, such as the World Organisation for Animal Health (WOAH) Terrestrial Animal Health Code.
* Justifications provided by the competent authorities of the Member States.
* **Entry into Force:** The regulation enters into force the day after its publication in the Official Journal of the European Union.
**3. Main Provisions Important for Use:**
* **Geographical Boundaries:** The most critical aspect is the precise definition of the restricted zones within each Member State. These are described using administrative boundaries (e.g., municipalities, districts) and, in some cases, specific geographical features (e.g., roads, railway lines, water bodies).
* **Disease Control Measures:** The designation of an area as a restricted zone triggers specific disease control measures as outlined in the original Implementing Regulation (EU) 2023/594. These measures may include:
* Restrictions on the movement of live pigs and certain pig products.
* Enhanced surveillance and testing for ASF.
* Biosecurity measures for pig farms.
* Measures to control wild boar populations.
* **Obligations for Member States:** Member States with areas listed in Annex I are obligated to implement the special disease control measures within the designated zones.
* **Dynamic Situation:** The regulation acknowledges that the ASF situation is dynamic, implying that the restricted zones may be subject to further changes as the epidemiological situation evolves.
* **Territorial Continuity:** The regulation highlights the importance of ensuring territorial continuity when defining restricted zones, meaning that the zones should be contiguous and not fragmented.
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This regulation has implications for Ukraine and Ukrainians, as African Swine Fever is a threat to pig farming and trade. Ukrainians involved in these activities within the EU should be aware of the restricted zones and comply with the relevant disease control measures.
Commission Implementing Regulation (EU) 2025/900 of 12 May 2025 amending Annexes V and XIV to Implementing Regulation (EU) 2021/404 as regards the entries for Canada, the United Kingdom and the United States in the lists of third countries, territories or zones thereof authorised for the entry into the Union of consignments of poultry and germinal products of poultry, and of fresh meat of poultry and game birds
This is an amendment to Implementing Regulation (EU) 2021/404, focusing on the lists of third countries authorized to export poultry, germinal products of poultry, and fresh meat of poultry and game birds into the EU.
The regulation adjusts Annexes V and XIV of Implementing Regulation (EU) 2021/404. These annexes list third countries, territories, or zones authorized for the entry into the Union of consignments of poultry and related products. The changes involve updates to the entries for Canada, the United Kingdom, and the United States, modifying which zones within these countries are permitted to export these products to the EU. These modifications are based on recent outbreaks of highly pathogenic avian influenza (HPAI) and the measures taken to control the spread of the disease. Additionally, it corrects a numbering error related to a specific zone in the United States (US-2.997) introduced by Implementing Regulation (EU) 2025/641.
The key provisions involve the modification of specific zones within Canada, the United Kingdom, and the United States that are authorized to export poultry and related products to the EU. Certain zones that had restrictions due to previous HPAI outbreaks have been re-authorized following the implementation of disease control measures. Conversely, new zones in Canada and the United States, where recent HPAI outbreaks have been confirmed, are now subject to restrictions, meaning that poultry and related products from these zones cannot be imported into the EU. The correction of the numbering error for the US zone ensures that the correct geographical area is subject to the appropriate restrictions.
Council Implementing Regulation (EU) 2025/886 of 12 May 2025 implementing Regulation (EU) 2019/796 concerning restrictive measures against cyber-attacks threatening the Union or its Member States
Council Implementing Regulation (EU) 2025/886 amends Annex I to Regulation (EU) 2019/796, which concerns restrictive measures against cyber-attacks threatening the Union or its Member States. The regulation updates the reasons for including six individuals already listed, who are connected to cyber-attacks. This regulation directly impacts the enforcement of sanctions related to cyber security threats within the EU.
The structure of the regulation is straightforward. It contains two articles: Article 1 states that Annex I of Regulation (EU) 2019/796 is amended as per the Annex to this new regulation. Article 2 specifies that the regulation will come into force the day after its publication in the Official Journal of the European Union. The Annex provides updated entries for individuals already listed under ‘A. Natural Persons’ in Annex I of Regulation (EU) 2019/796, specifically entries 3 to 8.
The main provision of this regulation is the updated information regarding the listed individuals. The updated information includes details about their involvement in cyber-attacks, particularly those targeting the Organisation for the Prohibition of Chemical Weapons (OPCW) and the German federal parliament (Deutscher Bundestag). The updated entries also mention indictments by a grand jury in the United States for related crimes. These updates serve to reinforce the reasons for maintaining these individuals on the sanctions list, ensuring that the restrictive measures remain justified and enforceable. **** One of the listed persons, Evgenii Serebriakov, is indicated as a leader of “Sandworm” group, which has carried out cyber-attacks on Ukraine.
Council Regulation (EU) 2025/903 of 13 May 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
Here’s a breakdown of Council Regulation (EU) 2025/903:
**1. Essence of the Act:**
This regulation amends Council Regulation (EU) No 269/2014, which concerns restrictive measures against actions undermining Ukraine’s territorial integrity, sovereignty, and independence. The amendment introduces a new criterion for listing individuals or entities involved in transferring ownership, control, or economic benefits from the business interests of leading Russian businesspersons already under sanctions. It also clarifies the burden of proof required to maintain these leading businesspersons on the sanctions list, even if they claim to have transferred their business interests.
**2. Structure and Main Provisions:**
* **Article 1:** This article contains the core amendments to Regulation (EU) No 269/2014.
* **Addition to Article 3(1):** A new point (m) is added, targeting individuals or entities that have participated in or enabled the transfer of ownership, control, or economic benefit of the business interests of leading Russian businesspersons who are already sanctioned. This applies if the transfer significantly frustrates the existing sanctions, with exceptions for transfers explicitly permitted by EU regulations.
* **Insertion of Article 3(1b):** This new paragraph addresses leading businesspersons operating in Russia who are listed in Annex I and claim to have transferred their business interests after February 24, 2022. It states that these individuals will continue to be considered leading businesspersons and remain on the sanctions list unless sufficient, recent, and reliable information proves they no longer meet the original criteria for being sanctioned.
* **Article 2:** This article specifies that the regulation comes into force on the day following its publication in the Official Journal of the European Union and is binding in its entirety and directly applicable in all Member States.
**3. Main Provisions Important for Use:**
* **New Listing Criterion (Article 1(1)):** The addition of point (m) to Article 3(1) is crucial. It broadens the scope of sanctions to include those facilitating the transfer of assets from sanctioned individuals, which aims to prevent the circumvention of existing measures.
* **Burden of Proof (Article 1(2)):** The insertion of Article 3(1b) is significant because it shifts the burden of proof. Leading businesspersons who claim to have transferred their assets must now demonstrate that they no longer meet the criteria for being sanctioned. This provision is designed to prevent individuals from easily evading sanctions through nominal transfers of ownership.
Commission Regulation (EU) 2025/877 of 12 May 2025 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards the use in cosmetic products of certain substances classified as carcinogenic, mutagenic or toxic for reproduction
This is a description of Commission Regulation (EU) 2025/877 amending Regulation (EC) No 1223/2009 on cosmetic products.
This regulation updates the list of substances prohibited or restricted in cosmetic products to reflect the latest scientific classifications of certain substances as carcinogenic, mutagenic, or toxic for reproduction (CMR). It aims to ensure a high level of human health protection and legal certainty for businesses. The regulation adds several newly classified CMR substances to the list of prohibited substances in Annex II of Regulation (EC) No 1223/2009 and removes one substance, Trimethylbenzoyl Diphenylphosphine Oxide, from the list of allowed substances for restricted use in Annex III. Additionally, it clarifies the chemical name and CAS number for cymoxanil in Annex II to align with the corresponding entry in Regulation (EC) No 1272/2008.
The regulation amends Annex II (list of prohibited substances) and Annex III (list of restricted substances) of Regulation (EC) No 1223/2009. It adds several substances to Annex II, effectively banning them from use in cosmetic products. These include diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide (Trimethylbenzoyl Diphenylphosphine Oxide), 2,2′,6,6′-tetrabromo-4,4′-isopropylidenediphenol (tetrabromobisphenol-A), transfluthrin (ISO), clothianidin (ISO), and several other chemical compounds. It also modifies entry 1580 in Annex II to include additional chemical names and CAS numbers for cymoxanil. Furthermore, it removes entry 311 from Annex III, which previously allowed the use of Trimethylbenzoyl Diphenylphosphine Oxide for professional use in artificial nail systems at a maximum concentration of 5%.
The most important provision is the immediate prohibition of the newly listed CMR substances in cosmetic products from 1 September 2025. This includes the removal of Trimethylbenzoyl Diphenylphosphine Oxide, previously allowed in artificial nail systems, indicating a stricter approach towards potentially harmful substances in cosmetics.
