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Review of the EU legislation for 15/01/2025

Here’s a concise review of the most significant legal acts from the provided set:

1. Poultry Import Regulations

Updates import rules for poultry products from Canada, UK, and US due to avian influenza outbreaks. Establishes new restricted zones with 10km radius around outbreak locations and updates existing restrictions.

2. Financial Reporting Standards

Updates IFRS taxonomy for electronic financial reporting, including new technical specifications for XBRL elements and standardized definitions for financial concepts, effective from January 2025.

3. Cyber Solidarity Act

Creates three main mechanisms: European Cybersecurity Alert System, Emergency Mechanism, and Incident Review Mechanism. Establishes cyberhubs network and EU Cybersecurity Reserve for incident response.

4. Geographical Indications Framework

Harmonizes rules for geographical indications across wine, spirits, and agricultural products sectors. Sets procedures for registration, amendments, and cancellations of GIs and TSGs, including detailed requirements for compliance attestation.

5. Heavy-duty Vehicle CO2 Emissions

Establishes procedures for verifying CO2 emissions of heavy-duty vehicles in service, including test methods, statistical evaluation, and correction mechanisms for deviations.

6. Anti-dumping Measures

Imposes provisional duties on Chinese lysine imports (58.3-84.8%) and tinplated products (14.1-62.6%) to counter unfair trade practices.

7. Commercial Refrigeration Equipment

Provides temporary exemption from restrictions on fluorinated greenhouse gases for specific types of commercial refrigeration equipment until June 2026.

8. EU-Ukraine Public Procurement

Opens mutual access to public procurement markets between EU and Ukraine for supplies by central government and local authorities.

Review of each of legal acts published today:

Commission Implementing Regulation (EU) 2025/80 of 13 January 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 Commission Implementing Regulation amends the rules for importing poultry, poultry products and game birds from Canada, the United Kingdom and the United States into the European Union due to outbreaks of highly pathogenic avian influenza (HPAI) in these countries.The regulation updates Annexes V and XIV of Implementing Regulation (EU) 2021/404 by adding new restricted zones in areas where HPAI outbreaks occurred and removing restrictions from zones where the disease situation has improved. It specifically addresses outbreaks that occurred in December 2024 in Ontario (Canada), Norfolk (UK), and multiple US states.The main changes include:

  • Adding new restricted zones CA-2.248 to CA-2.251 in Ontario, Canada
  • Adding zones GB-2.337 to GB-2.340 in Norfolk, UK
  • Adding zones US-2.760 to US-2.797 covering multiple US states
  • Removing restrictions from certain previously affected zones where disease control measures were successfully completed
  • Correcting technical descriptions of three Canadian zones (CA-2.245 to CA-2.247)

The regulation provides detailed geographical coordinates and descriptions for each new restricted zone, along with specific conditions for imports from these areas. It implements a 10km radius restriction zone around each outbreak location and requires appropriate animal health certificates for any permitted imports.

Commission Delegated Regulation (EU) 2025/19 of 26 September 2024 amending the regulatory technical standards laid down in Delegated Regulation (EU) 2019/815 as regards the 2024 update of the taxonomy for the single electronic reporting format

This legislative act represents a technical update to the regulatory standards for electronic financial reporting formats in the EU, specifically updating the IFRS taxonomy to reflect the latest accounting standards and reporting practices published by the IFRS Foundation in 2023-2024.The act is structured around several key modifications to existing Delegated Regulation (EU) 2019/815, including complete replacement of Annexes I, II and VI, as well as updates to Annexes III and V. These changes incorporate new developments in Inline XBRL specifications and provide enhanced guidance for financial statement tagging.The most significant provisions include:

  • Updated technical specifications for XBRL elements used in financial reporting
  • New standardized definitions for financial concepts and their attributes
  • Detailed requirements for tagging and structuring comprehensive income information
  • Specific measurement and disclosure requirements for deposits and financial instruments
  • Implementation timeline starting from January 1, 2025, with optional early adoption from January 1, 2024

Regulation (EU) 2025/38 of the European Parliament and of the Council of 19 December 2024 laying down measures to strengthen solidarity and capacities in the Union to detect, prepare for and respond to cyber threats and incidents and amending Regulation (EU) 2021/694 (Cyber Solidarity Act)

The Cyber Solidarity Act (Regulation (EU) 2025/38) establishes a comprehensive framework to strengthen the EU’s cybersecurity capabilities and response mechanisms. It creates three main pillars: the European Cybersecurity Alert System, the Cybersecurity Emergency Mechanism, and the European Cybersecurity Incident Review Mechanism. The act aims to enhance detection of cyber threats, improve incident response coordination, and strengthen solidarity between Member States in cybersecurity matters.The regulation’s structure includes five chapters covering general provisions, the European Cybersecurity Alert System, the Cybersecurity Emergency Mechanism, the European Cybersecurity Incident Review Mechanism, and final provisions. It also amends Regulation (EU) 2021/694 (Digital Europe Programme) to incorporate new operational objectives and funding arrangements.Key provisions include:

  • Establishment of a pan-European network of cyberhubs consisting of National Cyber Hubs and Cross-Border Cyber Hubs to enhance detection and situational awareness capabilities
  • Creation of an EU Cybersecurity Reserve composed of trusted managed security service providers to assist in responding to significant cybersecurity incidents
  • Introduction of coordinated preparedness testing for entities in critical sectors
  • Development of mechanisms for information sharing and cooperation between Member States
  • Provision of support to associated third countries under specific conditions
  • Implementation of incident review procedures to learn from significant cybersecurity events

The regulation introduces significant changes compared to previous frameworks by:

  • Creating new operational structures for cyber threat detection and response
  • Establishing formal mechanisms for cross-border cooperation and assistance
  • Introducing specific funding arrangements for cybersecurity initiatives
  • Setting up clear procedures for third country participation
  • Implementing new review and evaluation mechanisms

Commission Implementing Regulation (EU) 2025/26 of 30 October 2024 laying down rules for the application of Regulation (EU) 2024/1143 of the European Parliament and of the Council as regards registrations, amendments, cancellations, enforcement of the protection, labelling and communication in respect of geographical indications and traditional specialities guaranteed, and amending Implementing Regulation (EU) 2019/34 as regards geographical indications in the wine sector, and repealing Implementing Regulations (EU) No 668/2014 and (EU) 2021/1236

This is a comprehensive implementing regulation that lays down detailed rules for the application of Regulation (EU) 2024/1143 regarding geographical indications (GIs) and traditional specialities guaranteed (TSGs).The regulation establishes three main areas of rules:

  • Procedures for registration, amendments, cancellations, and management of GIs and TSGs
  • Requirements for attestation of compliance with product specifications
  • Rules on labeling and communications

The key provisions include:

  • Detailed requirements for applications, oppositions, amendments and cancellations of GIs and TSGs
  • Rules for maintaining electronic Union registers of protected names
  • Specifications for official attestations of compliance
  • Requirements for using EU symbols and indications on products
  • Procedures for communications between Member States and the Commission

The regulation also amends existing rules for wine GIs and repeals previous implementing regulations for agricultural products and spirit drinks to create a harmonized framework across all sectors. It includes 18 detailed annexes with forms and specifications for various procedures.

Commission Delegated Regulation (EU) 2025/29 of 30 October 2024 repealing Delegated Regulation (EU) 2021/1235 supplementing Regulation (EU) 2019/787 of the European Parliament and of the Council with rules concerning applications for registration of geographical indications of spirit drinks, amendments to product specifications, cancellation of the registration and the register

This Commission Delegated Regulation repeals the previous Regulation (EU) 2021/1235 which dealt with rules concerning geographical indications of spirit drinks. The repeal is part of a broader harmonization of EU rules on geographical indications across three agricultural sectors: wine, spirit drinks, and agricultural products.The act consists of two articles: Article 1 simply repeals Regulation (EU) 2021/1235, while Article 2 sets the entry into force provision. The regulation is quite straightforward in its structure and purpose, being purely technical in nature.The key aspects of this regulation relate to the consolidation of rules on geographical indications. The previous separate frameworks for different agricultural sectors are being replaced by a single common Union framework established by Regulation (EU) 2024/1143. The rules that were previously contained in Regulation (EU) 2021/1235 are now covered either directly in Regulation (EU) 2024/1143 or in the new Delegated Regulation (EU) 2025/27, making the old regulation obsolete and necessitating its repeal to avoid regulatory conflicts.

Regulation (EU) 2025/37 of the European Parliament and of the Council of 19 December 2024 amending Regulation (EU) 2019/881 as regards managed security services (Text with EEA relevance)

This Regulation amends Regulation (EU) 2019/881 (Cybersecurity Act) to include managed security services in the European cybersecurity certification framework. The key aspects are:The Regulation expands the scope of EU cybersecurity certification to cover managed security services, which are services provided to third parties for cybersecurity risk management, including incident handling, penetration testing, security audits and consulting.The main provisions include:

  • New security objectives specifically for managed security services certification schemes, focusing on staff competence, internal procedures, data protection, and service quality
  • Requirements that managed security services must be provided with appropriate expertise, experience and professional integrity
  • Three assurance levels (basic, substantial, high) for certification of managed security services based on risk levels
  • Rules for conformity assessment, monitoring compliance, and market surveillance of certified managed security services

The Regulation aims to improve cybersecurity in the EU by ensuring managed security services meet high security standards through certification, while avoiding market fragmentation. It establishes clear requirements for service providers and creates a harmonized approach to certification across the EU.

Commission Delegated Regulation (EU) 2025/27 of 30 October 2024 supplementing Regulation (EU) 2024/1143 of the European Parliament and of the Council with rules concerning the registration and the protection of geographical indications, traditional specialities guaranteed and optional quality terms and repealing Delegated Regulation (EU) No 664/2014

This Regulation supplements EU Regulation 2024/1143 by establishing detailed rules for registration and protection of geographical indications (GIs), traditional specialities guaranteed (TSGs) and optional quality terms for wine, spirit drinks and agricultural products. It creates a unified framework for managing these quality schemes across all three sectors, replacing previous separate regulations.The Regulation consists of 5 chapters covering introductory provisions, geographical indications, special rules for agricultural products, traditional specialities guaranteed, and final provisions. It contains 14 articles that detail specific procedures and requirements.Key provisions include:

  • Detailed procedures for opposition to GI/TSG applications, including 3-month consultation periods between parties
  • Rules for standard and temporary amendments to product specifications, including approval processes and communication requirements
  • Requirements for sourcing raw materials for protected geographical indications
  • Length limitations and content requirements for TSG product specifications
  • Rules on using TSG-designated products as ingredients in processed products

The Regulation establishes clear timelines and responsibilities for Member States and the Commission in managing these quality schemes. It requires transparency in procedures through publication of decisions and amendments in the Official Journal and the EU Register of Geographical Indications. Special provisions are included for cross-border geographical indications and products from third countries.

Commission Delegated Regulation (EU) 2025/28 of 30 October 2024 amending Delegated Regulation (EU) 2019/33 supplementing Regulation (EU) No 1308/2013 of the European Parliament and of the Council as regards applications for protection of designations of origin, geographical indications and traditional terms in the wine sector, the objection procedure, restrictions of use, amendments to product specifications, cancellation of protection, and labelling and presentation

This Regulation amends the existing rules regarding geographical indications, designations of origin, and traditional terms in the wine sector. It is part of a broader effort to establish a unified framework for geographical indications across wine, spirit drinks, and agricultural products sectors in the European Union.The Regulation modifies Commission Delegated Regulation (EU) 2019/33 by removing provisions that are now covered by the new unified framework established by Regulation (EU) 2024/1143 and Delegated Regulation (EU) 2025/27. However, it maintains specific provisions that are essential to the wine sector, including rules about the language of registered names, packaging requirements, production area derogations, and labeling obligations.Key provisions that remain in force include:

  • Requirements for the language of protected names
  • Justification for packaging wine within geographical areas
  • Derogations for production in demarcated geographical areas
  • Exceptions from using ‘protected designation of origin’ in labeling
  • General provisions for wine labeling and presentation
  • Rules regarding traditional terms in the wine sector

The Regulation maintains all provisions that do not directly relate to geographical indications while removing those that would conflict with the new unified framework. It also simplifies the procedural language requirements, stating that all documents sent to the Commission must be in an official EU language or accompanied by a certified translation.

Commission Implementing Regulation (EU) 2025/35 of 13 January 2025 implementing Regulation (EU) 2019/1242 of the European Parliament and of the Council by determining the procedures for the in-service verification of the CO2 emissions of heavy-duty vehicles

This Regulation establishes detailed procedures for verifying CO2 emissions and fuel consumption of heavy-duty vehicles in service (in-service verification). It defines how type-approval authorities should test vehicles to check if their actual CO2 emissions match the values declared in certification documents. The Regulation also sets rules for reporting and correcting any deviations found.The act consists of 24 articles and 5 annexes covering the selection of vehicle families for testing, test procedures, statistical evaluation methods, and reporting requirements. Key structural elements include procedures for different types of tests (verification testing procedure, air drag tests, tire rolling resistance tests, mass tests) and steps for evaluating and acting on test results.Main provisions include:

  • Type-approval authorities must select vehicles based on risk assessment performed by the Commission
  • Minimum number of vehicle families to be tested is determined based on manufacturer’s production volume
  • Detailed test conditions and procedures are specified for each type of test
  • Statistical methods are provided to evaluate test results and determine if there are deviations
  • If deviations are found, CO2 emission values must be corrected for all affected vehicles
  • Annual reporting requirements for authorities on verification activities and results

Commission Implementing Regulation (EU) 2025/74 of 13 January 2025 imposing a provisional anti-dumping duty on imports of lysine originating in the People’s Republic of China

This is a Commission Implementing Regulation imposing provisional anti-dumping duties on imports of lysine originating in China. The regulation imposes provisional anti-dumping duties ranging from 58.3% to 84.8% on imports of lysine and its derivatives from China. The duties will apply for 6 months. Key provisions include:

  • The investigation found evidence of dumping by Chinese exporters causing material injury to the EU industry
  • Individual duty rates were set for two company groups (Meihua at 84.8% and Eppen at 58.3%)
  • Other cooperating companies received a duty of 71.6%
  • All other Chinese imports will face the highest rate of 84.8%
  • The duties apply to lysine in various forms including hydrochloride, sulphate and liquid forms
  • Application of individual rates requires presentation of valid commercial invoices

The regulation contains detailed analysis of dumping calculations, injury assessment, causation and Union interest considerations that led to imposing the measures. The duties aim to counter unfair trade practices while maintaining supply to the EU market.

Commission Delegated Regulation (EU) 2025/65 of 31 October 2024 amending Delegated Regulation (EU) 2019/2123 as regards the conditions under which a separate Common Health Entry Document is submitted for consignments leaving a border control post for a control point where identity and physical checks are to be performed

This Regulation introduces changes to the documentation requirements for consignments that undergo identity and physical checks at control points different from border control posts in the EU. It specifically modifies the rules regarding the Common Health Entry Document (CHED) submission process for goods entering the European Union.The Regulation amends Delegated Regulation (EU) 2019/2123 by introducing a new requirement for operators to link two Common Health Entry Documents in the information management system. The first CHED is submitted at the border control post, while a separate CHED must be submitted for the control point where identity and physical checks will be performed.The main provisions of the act focus on:

  • The requirement for operators to complete and submit a separate CHED into the information management system for official controls (IMSOC) before the consignment leaves the border control post
  • The obligation to link this separate CHED with the original CHED submitted at the border control post
  • The notification of expected arrival time and means of transport to the competent authorities at the control point

This modification aims to ensure better traceability of consignments and proper information flow between authorities regarding the outcomes of official controls and decisions on consignments. The change affects the documentation process for goods that undergo checks at control points other than their entry border control post.

Commission Implementing Regulation (EU) 2025/33 of 13 January 2025 authorising an exemption pursuant to Regulation (EU) 2024/573 of the European Parliament and of the Council, with regard to the use of fluorinated greenhouse gases with a GWP of 150 or more in blast cabinets, artisanal gelato ice cream makers, ice makers, trolleys for preserving and regenerating food, retarder prover cabinets, frozen drinks dispensers and cold cream dispensers

This Commission Implementing Regulation provides a temporary exemption for specific types of commercial refrigeration equipment from the restrictions on using fluorinated greenhouse gases with Global Warming Potential (GWP) of 150 or more. The exemption applies from January 1, 2025, to June 30, 2026, allowing manufacturers additional time to transition to more environmentally friendly alternatives.The Regulation is structured around two main articles. Article 1 lists six specific types of refrigeration equipment that are granted the exemption, including blast cabinets, artisanal gelato ice cream makers, ice makers, food preservation trolleys, retarder prover cabinets, and frozen drinks dispensers. Each equipment type has specific technical parameters defining its scope. Article 2 establishes the implementation timeline.Key provisions include:
– The exemption applies only to equipment within specified capacity ranges
– Equipment must be properly labeled according to Article 12(2) of Regulation (EU) 2024/573
– The exemption is limited to 18 months, providing manufacturers time to convert their production to alternatives
– The regulation covers specific commercial and industrial refrigeration equipment used in sectors such as food service, healthcare, and hospitality
– The exemption was granted based on technical feasibility considerations and to avoid disproportionate costs for manufacturers

Commission Implementing Regulation (EU) 2025/34 of 13 January 2025 approving a modification of a traditional term in the wine sector in accordance with Article 115(2) of Regulation (EU) No 1308/2013 of the European Parliament and of the Council (Chacolí-Txakolina)

This Regulation approves a modification to the traditional wine term ‘Chacolí-Txakolina’ in Spain’s wine sector. The modification was requested by Spain and will be entered in the EU’s electronic register of protected traditional terms for wines. The approval comes after no objections were received during the publication period.The Regulation consists of two main articles: Article 1 approves the modification of the traditional term ‘Chacolí-Txakolina’, and Article 2 establishes that the regulation enters into force 20 days after its publication in the Official Journal of the EU. The act follows the standard procedure for modifying traditional terms in the wine sector as outlined in Regulation (EU) No 1308/2013 and its implementing regulations.Key provisions of the act include:
– The formal approval of the modification to the traditional term ‘Chacolí-Txakolina’
– The requirement to enter the modified term in the electronic register of protected traditional terms
– The confirmation that no objections were received during the publication period
– The binding nature of the regulation in all EU Member States

Commission Implementing Regulation (EU) 2025/32 of 13 January 2025 approving a modification of a traditional term in the wine sector in accordance with Article 115(2) of Regulation (EU) No 1308/2013 of the European Parliament and of the Council (Vino de calidad con indicación geográfica)

This Commission Implementing Regulation approves a modification to the traditional term ‘Vino de calidad con indicación geográfica’ in the wine sector, which was requested by Spain. The modification will be entered in the electronic register of protected traditional terms for wines.The regulation consists of two main articles: Article 1 approves the modification of the traditional term, and Article 2 establishes that the regulation enters into force on the twentieth day following its publication in the Official Journal of the European Union.The key aspects of this regulation include:
– The modification was examined in accordance with Articles 28(2), 28(3), and 34 of Commission Delegated Regulation (EU) 2019/33
– No objections were received during the prescribed period under Article 22 of Commission Implementing Regulation (EU) 2019/34
– The modified term will be registered in the electronic register of protected traditional terms as referred to in Article 25 of Implementing Regulation (EU) 2019/34

Commission Implementing Regulation (EU) 2025/81 of 13 January 2025 imposing a provisional anti-dumping duty on imports of flat-rolled products of iron or non-alloy steel plated or coated with tin originating in the People’s Republic of China

This is a Commission Implementing Regulation imposing provisional anti-dumping duties on imports of flat-rolled products of iron or non-alloy steel plated or coated with tin (‘tinplated products’) originating in China.The regulation imposes provisional anti-dumping duties ranging from 14.1% to 62.6% on imports of tinplated products from China for a period of 6 months. The duties were imposed after an investigation found evidence of dumping by Chinese exporters that caused material injury to the EU industry.The main provisions include:

  • Detailed methodology for calculating dumping margins and injury elimination levels
  • Different duty rates for individual cooperating Chinese exporters (14.1-47.1%) versus non-cooperating companies (62.6%)
  • Requirements for valid commercial invoices to apply individual duty rates
  • Discontinuation of prior registration of imports

The investigation found that Chinese imports increased significantly while undercutting EU prices, causing material injury to EU producers through loss of market share, price suppression and declining profitability. The Commission concluded provisional duties were necessary to prevent further injury to the EU industry.Key changes compared to previous versions include the introduction of new methodology under Article 2(6a) for calculating normal value due to significant market distortions in China, and consideration of future environmental compliance costs when determining injury elimination levels.

Regulation (EU) 2025/11 of the European Parliament and of the Council of 19 December 2024 amending Regulation (EU) 2018/1806 as regards Vanuatu

This Regulation amends EU visa requirements by removing Vanuatu from the list of countries whose nationals are exempt from visa requirements and adding it to the list of countries whose nationals must obtain visas when crossing EU external borders. This change is primarily due to concerns about Vanuatu’s investor citizenship schemes, which allowed foreign nationals to obtain Vanuatu citizenship through investment.The Regulation consists of two main articles. Article 1 contains the technical amendments to Regulation (EU) 2018/1806, specifically moving Vanuatu from Annex II (visa-exempt countries) to Annex I (visa-required countries). Article 2 establishes the entry into force provision.The key provisions detail the reasons for this change, including:

  • Vanuatu’s investor citizenship schemes allowed rapid citizenship acquisition without physical presence requirements
  • The screening process for citizenship applications was deemed inadequate, with extremely short processing times (14-30 days) and very low rejection rates
  • Despite legislative changes in 2023, Vanuatu failed to provide satisfactory proof of implementation of stronger security measures
  • Concerns about the verification of applicants’ documents and lack of information exchange with applicants’ countries of origin
  • Continued acceptance of applications from Russian nationals after Russia’s invasion of Ukraine
  • Absence of adequate monitoring mechanisms for previously issued passports

Decision No 2/2024 of the EU-Ukraine Association Council of 1 October 2024 on the granting of reciprocal market access for supplies for state, regional and local authorities and bodies governed by public law in accordance with Annex XXI-A to Chapter 8 of the Association Agreement between the European Union and the European Atomic Energy Community and their Member States, of the one part, and Ukraine, of the other part [2025/68]

This Decision establishes reciprocal market access between the EU and Ukraine in the field of public procurement, specifically for supplies by state, regional and local authorities and bodies governed by public law. This is a significant step in the implementation of the EU-Ukraine Association Agreement’s provisions on public procurement.The Decision consists of three articles that establish the reciprocal market access, confirm the authenticity of the Decision in all EU official languages and Ukrainian, and set the entry into force date. It follows the positive assessment of Ukraine’s implementation of phase 2 of the legislative approximation process as outlined in Annex XXI-A of the Association Agreement.The key provisions of the Decision include:

  • Mutual opening of public procurement markets for supplies between the EU and Ukraine
  • Coverage of procurement by state, regional and local authorities and bodies governed by public law
  • Implementation of the market access provisions as set out in Annex XXI-A of the Association Agreement
  • Recognition of Ukraine’s progress in approximating its public procurement legislation with EU standards

This Decision represents a concrete step in the gradual and simultaneous opening of public procurement markets between the EU and Ukraine, as envisaged in Article 154 of the Association Agreement. It follows Ukraine’s successful implementation of necessary legislative reforms and institutional changes in its public procurement system.

Decision No 1/2024 of the EU-Ukraine Association Council of 1 October 2024 on the granting of reciprocal market access for supplies for central government authorities in accordance with Annex XXI-A to Chapter 8 of the Association Agreement between the European Union and the European Atomic Energy Community and their Member States, of the one part, and Ukraine, of the other part [2025/59]

This Decision establishes reciprocal market access between the EU and Ukraine for public procurement of supplies by central government authorities. It represents a significant step in implementing the EU-Ukraine Association Agreement’s provisions on public procurement.The Decision consists of three articles that establish mutual market access, confirm the authenticity of translations in all EU official languages and Ukrainian, and set the entry into force date. It follows a positive assessment of Ukraine’s implementation of phase 1 of the legislative approximation process outlined in Annex XXI-A of the Association Agreement.The key provisions include:

  • Reciprocal opening of markets for supplies procurement by central government authorities between the EU and Ukraine
  • Recognition of Ukraine’s progress in approximating its public procurement legislation with EU standards
  • Implementation of the gradual and simultaneous market opening principle established in Article 154 of the Association Agreement

The Decision is particularly significant as it represents the first practical step in opening public procurement markets between the EU and Ukraine, following Ukraine’s successful implementation of initial legislative reforms in this area. This creates new opportunities for suppliers from both the EU and Ukraine to participate in central government tenders in each other’s markets.

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