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Review of the EU legislation for 10/06/2025

Here is a summary of the EU legal acts you provided:

Commission Delegated Regulation (EU) 2025/1141 on conflicts of interest for issuers of asset-referenced tokens

This regulation sets out detailed rules for how companies issuing asset-referenced tokens must manage conflicts of interest. It requires them to establish comprehensive policies and procedures to identify, prevent, manage, and disclose any potential conflicts. These policies must cover various areas, including remuneration, relationships with third-party service providers, and the allocation of resources. The goal is to ensure that issuers act in the best interests of token holders and maintain trust in the market.

Commission Delegated Regulation (EU) 2025/1140 on record-keeping for crypto-asset service providers

This regulation specifies what records crypto-asset service providers need to keep concerning all their services, activities, orders, and transactions. The aim is to ensure consistent and comparable record-keeping across the sector, enabling authorities to supervise and enforce regulations effectively. The regulation details what data must be recorded for various services and transactions, including information on the parties involved, timestamps, and crypto-asset identification, all aimed at improving transparency and accountability in the crypto-asset market.

Commission Implementing Regulation (EU) 2025/1127 identifying “neighbouring container transhipment ports”

This regulation identifies East Port Said in Egypt and Tanger Med in Morocco as “neighbouring container transhipment ports.” This designation is important because, under Regulation (EU) 2023/1805, stops by containerships at these ports will not be considered a “port of call” for the purposes of calculating fuel usage and emissions reporting. This may impact how shipping companies meet their obligations for using renewable and low-carbon fuels.

Commission Implementing Regulation (EU) 2025/1128 approving an amendment to the product specification for ‘Ail rose de Lautrec’ PGI

This regulation officially approves changes to the product specification for ‘Ail rose de Lautrec,’ a type of garlic protected as a geographical indication. This means the updated requirements for this garlic are now legally recognized and protected under EU law. Producers must comply with these updated specifications.

Commission Implementing Regulation (EU) 2025/1139 imposing a provisional anti-dumping duty on imports of hardwood plywood from China

This regulation introduces temporary anti-dumping duties on specific types of hardwood plywood imported from China. The Commission found that these imports were being sold at unfairly low prices (dumped), harming the EU’s plywood industry. The regulation sets duty rates for specific Chinese exporters and a general rate for all other imports. Importers must provide specific invoices to benefit from the individual duty rates.

Review of each of legal acts published today:

Commission Delegated Regulation (EU) 2025/1141 of 27 February 2025 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council as regards regulatory technical standards specifying the requirements for policies and procedures on conflicts of interest for issuers of asset-referenced tokens

This Commission Delegated Regulation (EU) 2025/1141 supplements Regulation (EU) 2023/1114, focusing on regulatory technical standards for policies and procedures regarding conflicts of interest for issuers of asset-referenced tokens. It aims to ensure that issuers identify, prevent, manage, and disclose conflicts of interest effectively, considering the size, internal organization, and complexity of their operations. The regulation emphasizes the importance of sound governance and management to maintain trust in the financial market segment of asset-referenced tokens. It also addresses potential conflicts arising from the management of asset reserves and interactions with third-party service providers.

The regulation consists of 9 articles. It defines key terms such as ‘connected person’ and ‘group’ to clarify the scope of the regulation. It specifies circumstances that could affect the objectivity of connected persons and outlines scenarios where conflicts of interest may arise, including economic interests, responsibilities, and relationships. It requires issuers to establish written policies and procedures that reflect the size, complexity, and nature of their asset-referenced token operations. These policies must include processes for identifying, preventing, managing, and disclosing conflicts of interest, as well as measures to ensure effective internal and external communication. The regulation also addresses remuneration policies, arrangements with third-party service providers, and the allocation of resources for managing conflicts of interest. Finally, it mandates the disclosure of the nature and source of conflicts of interest and the steps taken to mitigate them, ensuring transparency for holders and prospective holders of asset-referenced tokens.

Key provisions include the requirement for issuers to closely monitor transactions involving the exchange of asset-referenced tokens for funds or other crypto-assets, especially when the issuer is a party to the transaction and it involves connected persons. The regulation also mandates that remuneration policies do not incentivize employees or management to favor their own interests over those of token holders. Additionally, it requires that arrangements with third-party service providers ensure they act in accordance with the issuer’s conflict of interest policies. The regulation emphasizes the need for a designated person responsible for managing conflicts of interest, who must have the necessary authority and independence to perform their duties effectively.

Commission Delegated Regulation (EU) 2025/1140 of 27 February 2025 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying records to be kept of all crypto-asset services, activities, orders and transactions undertaken

This is Commission Delegated Regulation (EU) 2025/1140, which supplements Regulation (EU) 2023/1114, also known as MiCA (Markets in Crypto-Assets regulation). The regulation specifies the records that crypto-asset service providers must keep regarding all crypto-asset services, activities, orders, and transactions they undertake. It aims to ensure consistent and comparable record-keeping across the financial sector, enabling competent authorities to effectively supervise and enforce the MiCA regulation. The regulation also seeks to minimize the reporting burden for crypto-asset service providers by aligning with existing standards where possible.

The Regulation is structured into 18 articles, divided into 3 sections, and includes an annex.

* **Section 1 (Articles 1-2):** Focuses on the retention of records and general provisions, including definitions of key terms like “transaction” and “undertaking a transaction.” It mandates that records be kept in a format accessible for competent authorities, ensuring easy access, correction tracking, and data integrity. It also specifies that crypto-asset service providers must keep records listed in Section 1 of the Annex, depending on the nature of their services and activities.
* **Section 2 (Articles 3-5):** Details record-keeping requirements for specific crypto-asset services and activities, including policies and procedures, documents setting out rights and obligations, and the safekeeping of clients’ crypto-assets and funds.
* **Section 3 (Articles 6-17):** Focuses on record-keeping of orders and transactions, including specific requirements for identifying individuals, algorithms, and legal entities involved in transactions. It also addresses the recording of orders and transactions executed via trading platforms or service providers to which Regulation (EU) 2023/1114 does not apply. It also sets out requirements for the identification of crypto-assets and the recording of transactions undertaken by branches.
* **Annex:** Provides detailed tables outlining the specific data points to be recorded for various services, activities, orders, and transactions. It includes information on identifying relevant parties, trading capacity, dates and times, order validity, crypto-asset identification, order types, prices, and on-chain data.

Some of the main provisions of the act that may be the most important for its use are:

* **Article 2:** Specifies the conditions for retaining records, ensuring they are accessible, tamper-proof, and allow for effective supervision by competent authorities.
* **Article 3:** Requires crypto-asset service providers to keep records of their policies and procedures, including assessments and reviews of their effectiveness.
* **Article 5:** Sets out detailed requirements for record-keeping in relation to the safekeeping of clients’ crypto-assets and funds, ensuring clear segregation and auditability.
* **Articles 6 and 7:** Detail the specific data points that must be recorded for every order and transaction, respectively, as outlined in the tables in Sections 2 and 3 of the Annex.
* **Articles 9 and 14:** Establish standardized methods for identifying natural persons and legal entities involved in crypto-asset transactions, using identifiers like LEI codes and national client identifiers.
* **Article 15:** Requires the use of a Digital Token Identifier (DTI) or an equivalent identifier approved by ESMA to identify crypto-assets in records.
* **Article 17:** Mandates that crypto-asset service providers identify themselves in records using a validated and renewed Legal Entity Identifier (LEI).

Commission Implementing Regulation (EU) 2025/1127 of 6 June 2025 laying down rules for the application of Regulation (EU) 2023/1805 of the European Parliament and of the Council as regards of identifying neighbouring container transhipment ports

This Commission Implementing Regulation (EU) 2025/1127 specifies which ports are considered “neighbouring container transhipment ports” for the purpose of Regulation (EU) 2023/1805, which concerns the use of renewable and low-carbon fuels in maritime transport. The regulation identifies ports outside the EU but near Member States that have a high percentage of container transhipment activity. Stops in these listed ports are excluded from the definition of “port of call” under certain provisions of Regulation (EU) 2023/1805.

The regulation consists of two articles and an annex. Article 1 states that the neighbouring container transhipment ports are those listed in the annex. Article 2 specifies that the regulation will come into force three days after its publication in the Official Journal of the European Union. The annex lists the specific ports that meet the criteria. The regulation builds upon the criteria already established in Commission Implementing Regulation (EU) 2023/2297, which identified similar ports under Directive 2003/87/EC.

The key provision of this regulation is the list in the Annex, which identifies East Port Said (Egypt) and Tanger Med (Morocco) as neighbouring container transhipment ports. This means that, under Regulation (EU) 2023/1805, stops by containerships at these ports will not be considered a “port of call” for the purposes of calculating fuel usage and emissions reporting, potentially affecting how shipping companies comply with the requirements for using renewable and low-carbon fuels.

Commission Implementing Regulation (EU) 2025/1128 of 6 June 2025 approving a non-minor amendment to the product specification of the protected geographical indication Ail rose de Lautrec pursuant to Regulation (EU) 2024/1143 of the European Parliament and of the Council

This Commission Implementing Regulation (EU) 2025/1128 approves a non-minor amendment to the product specification for the protected geographical indication (PGI) ‘Ail rose de Lautrec,’ a type of garlic. The approval follows the procedure outlined in Regulation (EU) 2024/1143, which governs geographical indications for various agricultural products. The regulation acknowledges that France applied for this amendment under the previous Regulation (EU) No 1151/2012, and the application was published in the Official Journal. Since no objections were received, the amendment is now approved.

The structure of the act is simple: it consists of a preamble outlining the legal basis and reasoning for the decision, followed by two articles. Article 1 formally approves the amendment to the product specification of ‘Ail rose de Lautrec’ PGI as published in the Official Journal. Article 2 states that the regulation will enter into force twenty days after its publication in the Official Journal. This regulation repeals and replaces Regulation (EU) No 1151/2012.

The most important provision is Article 1, which legally validates the changes to the product specification of ‘Ail rose de Lautrec’. This means that the updated requirements and characteristics for this PGI are now officially recognized and protected under EU law. Producers and stakeholders involved with ‘Ail rose de Lautrec’ need to be aware of the specific details of the approved amendment as published in the Official Journal to ensure compliance.

Commission Implementing Regulation (EU) 2025/1139 of 6 June 2025 imposing a provisional anti-dumping duty on imports of hardwood plywood from the People’s Republic of China

Here’s a breakdown of Commission Implementing Regulation (EU) 2025/1139, which imposes a provisional anti-dumping duty on imports of hardwood plywood from China.

**1. Essence of the Act:**

This regulation introduces a temporary anti-dumping duty on specific types of hardwood plywood imported from China into the European Union. The European Commission has determined that these imports are being dumped (sold at unfairly low prices), which is causing material injury to the EU’s hardwood plywood industry. The duties are meant to offset the effects of this dumping and protect EU producers.

**2. Structure and Key Provisions:**

The regulation is structured as follows:

* **Initiation of the Investigation:** Details the start of the anti-dumping investigation following a complaint by the Greenwood Consortium.
* **Registration of Imports:** Mentions that imports of hardwood plywood were subject to registration prior to this regulation.
* **Interested Parties:** Describes how the Commission engaged with various stakeholders (EU producers, Chinese exporters, importers, etc.).
* **Comments on Initiation:** Summarizes the arguments made by different parties regarding the complaint, dumping calculations, and injury.
* **Sampling:** Explains the process of selecting companies for investigation and the eventual decision to abandon sampling due to lack of cooperation from selected Chinese exporters.
* **Questionnaire Replies and Verification Visits:** Lists the companies that were visited and verified as part of the investigation.
* **Investigation Period:** Specifies the period examined for dumping and injury (July 1, 2023 – June 30, 2024).
* **Product Definition:** Defines the specific type of hardwood plywood subject to the duty.
* **Dumping Determination:** This section is very detailed and covers:

* The procedure for determining normal value (the fair market price) when domestic prices in China are considered unreliable due to “significant distortions.”
* Evidence of significant distortions in the Chinese economy, particularly in the hardwood plywood sector, based on government intervention.
* The selection of Türkiye as a representative country to determine undistorted costs.
* The sources used to establish undistorted costs for raw materials, labor, and energy.
* The calculation of the dumping margin (the difference between the normal value and the export price).
* **Injury Determination:** Assesses the harm caused to the EU industry, looking at factors like production, sales, market share, prices, and profitability.
* **Causation:** Examines whether the dumped imports from China caused the injury to the EU industry, or if other factors were responsible.
* **Level of Measures:** Determines the appropriate level of anti-dumping duty to offset the injury, considering raw material distortions.
* **Union Interest:** Assesses whether imposing the duties is in the overall interest of the EU, considering the impact on various stakeholders.
* **Provisional Anti-Dumping Measures:** Specifies the duty rates for individual Chinese exporters and a rate for “all other imports.”
* **Registration:** Discontinues the registration of imports.

**3. Main Provisions for Practical Use:**

* **Anti-dumping duties:** Pizhou Jiangshan Wood Co., Ltd – 25,1 %; All other imports originating in the PRC – 62,4 %.
* **Product Scope:** The duty applies to hardwood plywood consisting solely of sheets of wood other than bamboo and okoumé, each ply not exceeding 6 mm thickness, with at least one outer ply of tropical wood or non-coniferous wood, of species specified under subheadings 4412 31, 4412 33 and 4412 34, whether or not coated or surface-covered, currently falling under CN and TARIC codes 4412 31 10 80, 4412 31 90 00, 4412 33 10 12, 4412 33 10 22, 4412 33 10 82, 4412 33 20 10, 4412 33 30 10, 4412 33 90 10, and 4412 34 00 10, and originating in the People’s Republic of China.
* **Invoice Requirement:** To benefit from the individual duty rate, importers must present a specific commercial invoice with a signed declaration certifying the origin and manufacturer of the plywood.
* **Monitoring:** Imports of certain types of plywood (those with thin softwood outer layers) will be monitored to prevent circumvention of the duties.
* **Retroactivity:** The regulation does not apply retroactively.
* **Comments:** Interested parties have a limited time to submit written comments or request a hearing regarding the regulation.
* **Discontinuation of registration:** Customs authorities are hereby directed to discontinue the registration of imports established in accordance with Article 1 of Implementing Regulation (EU) 2024/3140.

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