Analysis of EU Legislation
1. Anti-Dumping Duty on Steel Track Shoes from China
The EU has imposed a 62.5% anti-dumping duty on steel track shoes from China, excluding certain specialized types. For track chains, the duty applies to the value of Chinese steel track shoes if they make up at least 31% of the chain’s value.
2. Joint Clinical Assessments for Medical Devices
New rules detail how EU countries and the Commission will exchange information during joint clinical assessments (JCAs) of medical devices. Health technology developers will be informed about device selection for JCA and required information.
3. Authorisation of ‘B. Braun Medical Propanol Family’ Biocidal Products
The ‘B. Braun Medical Propanol Family’ is authorized for use as human hygiene products, disinfectants, and food/feed area disinfectants from November 2025 to October 2035. The active substances are propan-1-ol and propan-2-ol. A long-term storage stability test is required by September 2026.
4. Amendments Regarding Quillaia Extract (E 999) as a Food Additive
Quillaia extract can now be used as an emulsifier in flavorings and solid/liquid food supplements (excluding those for infants and young children). Updated specifications include a more detailed definition, CAS number, minimum saponin content, reduced limits for toxic elements, and new limits for cadmium and calcium oxalate, as well as microbiological criteria.
5. EU-Ukraine Association Committee Decision on Trade
The EU-Ukraine Association Committee introduces Annex I-E to enhance trade relations by reducing and eliminating customs duties. For 2025, tariff rate quotas will be seven-twelfths of Annex I-E quantities. Ukraine must align its legislation with EU legal acts by December 31, 2028, and report annually on progress.
Commission Implementing Regulation (EU) 2025/2081
The EU has imposed a definitive anti-dumping duty of 62.5% on steel track shoes from China, following an investigation that confirmed the products were being dumped on the EU market, harming local industry. Certain specialized steel track shoes are excluded from this duty, and detailed rules apply to steel track shoes assembled in track chains.
Commission Implementing Regulation (EU) 2025/2086
This regulation establishes detailed procedures for EU member states and the European Commission to exchange information during joint clinical assessments (JCAs) of medical devices. It covers preparation, updating, and participation in assessments, including templates. Health technology developers will be informed about device selection for JCA and required information.
Commission Implementing Regulation (EU) 2025/2074
The ‘B. Braun Medical Propanol Family’ biocidal product family is authorized from November 2025 to October 2035 for product-types 1, 2 and 4, which include human hygiene, disinfectants not for direct human/animal use, and food/feed area disinfection. Active substances are propan-1-ol and propan-2-ol. A long-term storage stability test is required by September 2026.
Commission Regulation (EU) 2025/2084
Quillaia extract can now be used as an emulsifier in flavorings and solid/liquid food supplements (excluding those for infants and young children). Updated specifications include a detailed definition, CAS number, minimum saponin content, reduced limits for toxic elements, and new limits for cadmium and calcium oxalate, as well as microbiological criteria.
Decision No 3/2025 of the EU-Ukraine Association Committee
The EU-Ukraine Association Committee introduces Annex I-E to enhance trade relations by reducing and eliminating customs duties. For 2025, tariff rate quotas will be seven-twelfths of Annex I-E quantities. Ukraine must align its legislation with EU legal acts by December 31, 2028, and report annually on progress. Safeguard measures may be applied in case of serious economic, societal, or environmental difficulties.
No new legal acts were published today.
Review of Regulation (EU) 2025/2083 (CBAM)
The EU has updated the Carbon Border Adjustment Mechanism (CBAM), introducing a “de minimis” exemption for importers of small quantities (less than 50 tonnes annually) of goods, clarifying that indirect customs representatives must obtain authorized CBAM declarant status, and refining the accounting of carbon prices paid in third countries. It also specifies rules for calculating embedded emissions and extends the deadline for submitting the CBAM declaration to September 30th of each year.
Review of Regulation (EU) 2025/2073 (Insolvency Proceedings)
The EU updates the lists of recognised insolvency proceedings and practitioners across the EU to reflect changes in national insolvency laws in Member States including Belgium, Bulgaria, Czechia, Estonia, Spain, France, Italy, Luxembourg, Malta and Slovakia.
Review of Regulation (EU) 2025/1958 (Supervisory Financial Information)
The EU adjusts data points for supervisory financial information (FINREP) reporting by credit institutions, introducing detailed breakdowns by categories like past due dates, types of instruments, and impairment. Affected institutions need to update reporting systems by December 30, 2025.
Regulation (EU) 2025/2083 of the European Parliament and of the Council
The EU has fine-tuned the Carbon Border Adjustment Mechanism (CBAM), introducing a ‘de minimis’ exemption for importers of small quantities of goods (below 50 tonnes annually), clarifying the rules for deducting carbon prices paid in third countries, specifying the registration process for operators and installations in third countries and introducing fees payable by authorised CBAM declarants to cover the costs of the common central platform.
Regulation (EU) 2025/2073 of the European Parliament and of the Council
The EU updates the lists of insolvency proceedings and insolvency practitioners recognized by EU Member States under Regulation (EU) 2015/848 on insolvency proceedings. The new annexes contain the updated lists of insolvency proceedings (Annex A) and insolvency practitioners (Annex B) for each Member State, reflecting recent changes in their national laws.
Regulation (EU) 2025/1958 of the European Central Bank
The ECB amends Regulation (EU) 2015/534, focusing on reporting supervisory financial information. It requires less significant credit institutions to provide additional data on performing and non-performing exposures, as well as forborne exposures. Institutions need to update reporting systems by December 30, 2025.
CJEU Judgment regarding air passenger rights
The CJEU clarifies that a lightning strike, which necessitates safety inspections, constitutes an ‘extraordinary circumstance’ under Regulation No 261/2004. However, the air carrier must still demonstrate that it took all reasonable measures to mitigate the consequences of the delay.
CJEU Judgment concerning the loss of a pet during air travel
The CJEU clarifies that pets are considered ‘baggage’ under the Montreal Convention, and the loss of a pet falls under baggage liability rules, not passenger rules.
CJEU Judgment regarding anti-dumping duties on bicycle parts imported from China
The CJEU clarifies the conditions for exemption from anti-dumping duties on bicycle parts imported from China for small-scale operators. It states that importers can benefit from multiple exemptions, the 300-unit rule is a strict limit per month, and exceeding the limit disqualifies the importer.
CJEU Judgment regarding the right to an effective remedy in the context of EU funds
The CJEU emphasizes that national courts must be able to grant interim relief to ensure the full effectiveness of EU law and to interpret national law in conformity with EU law.
CJEU Judgment regarding the termination of the contract of a temporary agent in case of a breach of the relationship of trust
The Court of Justice confirms the possibility of terminating the contract of a temporary agent in case of a breach of the relationship of trust, and also confirms the high level of evidence that the applicant must provide to prove moral harassment.
CJEU Judgment regarding restrictive measures against Gennady Nikolayevich Timchenko and Elena Petrovna Timchenko
The judgment confirms the EU’s broad powers to implement restrictive measures in response to the situation in Ukraine, including imposing obligations on individuals subject to sanctions to report their assets. This has direct implications for individuals and entities listed in Annex I of Regulation No 269/2014.
CJEU Judgment regarding Spanish regional legislation on games of chance
The judgment reaffirms that Member States have a wide discretion in regulating gambling activities to protect public health and social order, but these regulations must be non-discriminatory, justified by overriding reasons of public interest, and proportionate.
CJEU Judgment regarding taxation of electricity producers from renewable sources in Romania
The CJEU’s judgment provides Member States with some flexibility in designing their energy taxation policies, even if those policies differentiate between renewable and non-renewable energy sources, as long as they are consistent with the overall objectives of EU law.
CJEU Judgment regarding State aid case involving the Kingdom of the Netherlands and the European Gaming and Betting Association (EGBA)
The Court finds that the Commission should have examined whether the measure at issue conferred an indirect advantage on bodies that serve the common interest and that the failure to examine that question in the decision at issue did not make it possible to rule out the existence of serious difficulties.
CJEU Judgment regarding the interpretation of the EU Directive 2014/24/EU on public procurement
The Court rules that a modification to the remuneration model does not automatically alter the overall nature of the framework agreement unless it leads to a fundamental change in the balance of the agreement, providing guidance on how to interpret modifications to public contracts.
CJEU Judgment regarding cabotage operations for coach and bus services in Denmark
The Court confirms that Member States have a margin of discretion to implement national measures clarifying the scope of ‘cabotage operations’ but emphasizes that any such measures must adhere to the principle of proportionality.
Commission Implementing Regulation (EU) 2025/2123
The EU amends the sanctions list against individuals and entities associated with ISIL (Da’esh) and Al-Qaida, updating the entries for two individuals, including information on their reported deaths or imprisonments.
Commission Implementing Regulation (EU) 2025/2067
The EU modifies fees and charges payable to the European Chemicals Agency (ECHA) under REACH, adjusting standard fees for inflation, introducing an ex-ante SME verification process, and permitting a charge for this verification. Companies claiming SME status must apply for recognition two months before submitting information.
Commission Implementing Regulation (EU) 2025/2068
The EU renews the approval of milbemectin for use in plant protection products, amending Implementing Regulation (EU) No 540/2011 accordingly. It sets conditions for use to protect the environment and human health, including measures for bees, pollinators, and aquatic organisms, and requires the submission of confirmatory information on substance safety by November 5, 2027.
Commission Implementing Regulation (EU) 2025/2048
The EU grants Union authorization to Schuelke & Mayr GmbH for the biocidal product family ‘3025’ for use as disinfectants and algaecides, excluding direct application to humans or animals, and including use in food and feed areas. Adherence to these instructions is important for ensuring the safe and effective use of the product and to minimize potential risks to human health and the environment.
Regulation (EU) 2025/2083
The EU has updated the Carbon Border Adjustment Mechanism (CBAM), introducing a “de minimis” exemption for importers of small quantities of goods, simplifying the calculation of embedded emissions for certain goods, clarifying procedures for authorized CBAM declarants, extending the deadline for submitting the CBAM declaration to September 30th of each year, specifying the registration process for operators and installations in third countries and introduces fees payable by authorised CBAM declarants to cover the costs of the common central platform.
Regulation (EU) 2025/2073
The EU updates the lists of insolvency proceedings and insolvency practitioners recognized by EU Member States under Regulation (EU) 2015/848 on insolvency proceedings. The changes are essential for the cross-border recognition and cooperation in insolvency matters within the EU.
Regulation (EU) 2025/1958 of the European Central Bank
The ECB amends Regulation (EU) 2015/534, focusing on the reporting of supervisory financial information by supervised entities. The key aim is to enhance the oversight of the Single Supervisory Mechanism (SSM) by requiring less significant credit institutions to provide additional data points concerning performing and non-performing exposures, as well as forborne exposures.
Judgment of the Court (Third Chamber) of 16 October 2025 (Air passenger rights)
The CJEU rules that a lightning strike on an aircraft, which necessitates mandatory safety inspections, does indeed constitute an ‘extraordinary circumstance’. However, the air carrier must still demonstrate that it took all reasonable measures to mitigate the consequences of the delay.
Judgment of the Court (Seventh Chamber) of 16 October 2025 (loss of a pet during air travel)
The CJEU clarifies that pets are considered ‘baggage’ under the Montreal Convention, meaning that the loss of a pet during air travel falls under the liability rules for baggage.
Judgment of the Court (Seventh Chamber) of 16 October 2025 (anti-dumping duties on bicycle parts)
The CJEU provides guidance on exemptions from anti-dumping duties on bicycle parts imported from China, confirming that the ‘less than 300 units’ rule is a strict limit that applies to the total number of parts imported per month.
Judgment of the Court (Seventh Chamber) of 16 October 2025 (right to an effective remedy in the context of EU funds)
The CJEU emphasizes that national courts must be able to grant interim relief to ensure the full effectiveness of EU law, requiring courts to set aside national law if it prevents such relief.
Arrêt de la Cour (sixième chambre) du 16 octobre 2025. (Termination of the contract of a temporary agent in case of a breach of the relationship of trust)
The most important provisions for its use are that the Court of Justice confirms the possibility of terminating the contract of a temporary agent in case of a breach of the relationship of trust, and also confirms the high level of evidence that the applicant must provide to prove moral harassment.
Judgment of the Court (Third Chamber) of 16 October 2025. (Restrictive measures against Gennady Nikolayevich Timchenko and Elena Petrovna Timchenko)
This judgment confirms the EU’s broad powers to implement restrictive measures in response to the situation in Ukraine, including imposing obligations on individuals subject to sanctions to report their assets.
Judgment of the Court (Eighth Chamber) of 16 October 2025. (Spanish regional legislation on games of chance)
The judgment reaffirms that Member States have a wide discretion in regulating gambling activities to protect public health and social order, but these regulations must be non-discriminatory, justified by overriding reasons of public interest, and proportionate.
Judgment of the Court (Ninth Chamber) of 16 October 2025. (Taxation of electricity producers from renewable sources in Romania)
The CJEU’s judgment provides Member States with some flexibility in designing their energy taxation policies, even if those policies differentiate between renewable and non-renewable energy sources, as long as they are consistent with the overall objectives of EU law.
Judgment of the Court (Eighth Chamber) of 16 October 2025. (State aid case involving the Kingdom of the Netherlands and the European Gaming and Betting Association (EGBA))
The Court finds that the Commission should have examined whether the measure at issue conferred an indirect advantage on bodies that serve the common interest.
Judgment of the Court (Third Chamber) of 16 October 2025. (Interpretation of the EU Directive 2014/24/EU on public procurement)
The Court rules that a modification to the remuneration model does not automatically alter the overall nature of the framework agreement unless it leads to a fundamental change in the balance of the agreement.
Judgment of the Court (Second Chamber) of 16 October 2025. (Cabotage operations for coach and bus services in Denmark)
The most important provision of the judgment is the Court’s confirmation that Member States have a margin of discretion to implement national measures clarifying the scope of ‘cabotage operations’ under Regulation No 1073/2009.
Commission Delegated Regulation (EU) 2025/1801
This Directive updates the rules for roadside checks on the transport of dangerous goods by road, revising the checklist and updating how infringements are classified.
Commission Delegated Regulation (EU) 2025/1311
This Regulation specifies how credit institutions should assess the significance of changes to their internal models, setting criteria for when approval is required.
Commission Delegated Regulation (EU) 2025/1265
This Regulation defines how credit institutions should identify the main risk driver and determine if a transaction is ‘long’ or ‘short’ for capital requirement calculations.
Commission Implementing Regulation (EU) 2025/2085
This Regulation modifies the list of countries authorized to export poultry and poultry products to the EU, adjusting zones due to avian influenza outbreaks in Canada, the UK, and the US.
Commission Implementing Regulation (EU) 2025/2070
This Regulation corrects errors in the Slovak language version of Implementing Regulation (EU) 2019/317, related to the Single European Sky framework.
Commission Implementing Regulation (EU) 2025/2061
This Regulation provides emergency financial support to farmers in Bulgaria, Latvia, Lithuania, Hungary, Poland, and Romania affected by adverse weather events.
Commission Implementing Regulation (EU) 2025/2043
This Regulation establishes rules for Member States to submit evidence about the impact of climate change on organic soils.
Commission Implementing Regulation (EU) 2025/2045
This Regulation corrects an error in the Slovak language version of Implementing Regulation (EU) 2019/317, related to the performance and charging scheme within the Single European Sky framework.
Commission Implementing Regulation (EU) 2025/2046
This Regulation amends the authorization of the feed additive canthaxanthin, approving a new production method using fermentation with Yarrowia lipolytica.
Regulation (EU) 2025/2077
This Regulation amends Regulation (EU) No 1026/2012 to improve the conservation of fish stocks by refining the definition of ‘failure to cooperate’ and clarifying the criteria for identifying countries allowing non-sustainable fishing practices.
Regulation (EU) 2025/2075
This Regulation amends Regulation (EU) No 909/2014 to shorten the settlement cycle for transactions in transferable securities within the EU, mandating a T+1 settlement cycle.
