Review of Regulation (EU) 2025/2649 Amending Regulations (EU) 2021/2115 and (EU) 2021/2116
Regulation (EU) 2025/2649 is a significant overhaul of the Common Agricultural Policy (CAP). Think of it as a legislative tune-up designed to make the CAP more farmer-friendly and efficient. It makes key adjustments to two core regulations, aiming to slash red tape, boost flexibility for both EU Member States and farmers, and better target the specific needs of different agricultural players, especially smaller farms, organic producers, and young entrants to the sector.
Firstly, the regulation grants more leeway in defining permanent grasslands, letting Member States extend the classification period. It also introduces a safety net in the form of crisis payments for farmers hit by natural disasters or other severe events.
For smaller farmers, it brings welcome relief by exempting them from the full weight of the conditionality system, simplifying their compliance requirements. The rules around Good Agricultural and Environmental Condition (GAEC) standards are also clarified, with specific carve-outs for organic farmers and temporary exemptions during plant disease or pest outbreaks.
The act also tinkers with the financial aspects, modifying how Member States can contribute to risk management tools, and increasing the financial assistance available under the simplified payment scheme for small farmers.
Eco-schemes are also revamped, now allowing support for actions that help farmers comply with national laws. Plus, rural development gets a boost with added support for small farm business development.
On the administrative side, the rules for amending CAP Strategic Plans are streamlined, distinguishing between major strategic changes and minor tweaks. Reporting requirements are also adjusted to reduce the burden on Member States.
Finally, the Regulation touches on the nuts and bolts of CAP financing. It tweaks rules for payments, including increased advance payment rates, and adjusts the control and penalty system, with more exemptions for small farmers and refined risk analysis processes.
Review of Decision No 1/2025 of the EU-Morocco Association Council
Decision No 1/2025 of the EU-Morocco Association Council is a crucial update to the trade rules between the EU and Morocco. This decision tweaks Protocol 4 of the Euro-Mediterranean Agreement, which governs the ‘rules of origin’ for goods traded between the two. In essence, it’s about determining which products qualify for preferential treatment, like reduced tariffs, based on where they were produced or substantially transformed.
The core change is the introduction of an alternative set of rules of origin, valid until the end of 2027. Think of it as a temporary shortcut to meeting the origin requirements. It also establishes a quota system for specific vegetable oils and tobacco products. If you’re dealing with these goods, you’ll need to be aware of the volume limits.
Furthermore, the decision updates the reference to the Regional Convention on pan-Euro-Mediterranean preferential rules of origin, ensuring the latest version always applies. This convention sets the standard for origin rules across a wider region.
In practical terms, businesses now have the option to use these alternative rules for a limited period. However, if you’re exporting specific oils and tobacco, you need to stay within the defined quota limits to benefit from preferential treatment. It also continues to allow cumulation of origin with other applying Contracting Parties, meaning that materials originating in those countries can be considered as originating in the exporting country.
Review of each of legal acts published today:
Commission Implementing Regulation (EU) 2025/2621 of 16 December 2025 laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and the Council as regards the establishment of default values
Okay, I can help you with a detailed description of the provisions of the provided act. Please note that due to the extensive amount of data, I will focus on the key aspects and structure.
**1. Essence of the Act:**
This legal act specifies default values for greenhouse gas emissions associated with the production of various goods imported from Japan, Kenya, Korea, Kosovo, Kuwait, Kyrgyzstan, Laos, Lebanon, Libya, Madagascar and Malaysia. These values are essential for calculating the carbon border adjustment mechanism (CBAM) levies on imports into the European Union. The act covers goods within the categories of cement, fertilizers, aluminum, hydrogen, and iron and steel. It provides distinct emission factors for direct and indirect emissions, as well as total emissions, and includes mark-ups for the years 2026, 2027, and 2028 onwards.
**2. Structure and Main Provisions:**
The act is structured as a table, with each row specifying a particular type of good identified by its CN code (Combined Nomenclature code, an EU system for classifying goods). For each good, the table provides:
* **CN Code:** The customs classification code for the product.
* **Description:** A textual description of the product.
* **Default Values (Direct Emissions):** The default emission factor for direct emissions during the production process, measured in tonnes of CO2 equivalent per tonne of product.
* **Default Values (Indirect Emissions):** The default emission factor for indirect emissions (e.g., from electricity consumption), measured in tonnes of CO2 equivalent per tonne of product.
* **Default Values (Total Emissions):** The sum of direct and indirect emissions.
* **Default Values (Including Mark-up):** Emission values with a 10% mark-up for 2026, a 20% mark-up for 2027, and a 30% mark-up for 2028 onwards. These mark-ups likely account for additional factors or are part of the CBAM calculation methodology.
* **Underlying production route determining CBAM BM:** This indicates the benchmark production route used to determine the CBAM benchmark.
**3. Main Provisions Important for Use:**
* **Emission Factors:** The core of the act lies in the emission factors provided for each type of good. Importers will use these values (unless they can prove lower actual emissions) to calculate the CBAM liability.
* **Mark-up Values:** The inclusion of increasing mark-up values over the years (2026-2028) suggests a phased implementation or adjustment of the CBAM mechanism. Businesses need to be aware of these escalating costs.
* **Product Scope:** The act is very specific in defining the goods covered, using CN codes and descriptions. It is crucial to accurately classify imported goods to determine the applicable emission factors.
* **Production Route:** The underlying production route is important because it defines the CBAM benchmark. This benchmark is used to determine the level of CBAM levies.
Regulation (EU) 2025/2649 of the European Parliament and of the Council of 19 December 2025 amending Regulation (EU) 2021/2115 as regards the conditionality system, types of intervention in the form of direct payment, types of intervention in certain sectors and rural development and annual performance reports and Regulation (EU) 2021/2116 as regards suspensions of payments, annual performance clearance and controls and penalties
Here is the description of the provisions of Regulation (EU) 2025/2649.
**1. Essence of the Act:**
Regulation (EU) 2025/2649 amends Regulations (EU) 2021/2115 and (EU) 2021/2116, focusing on simplifying and improving the Common Agricultural Policy (CAP). The amendments address issues related to the conditionality system, direct payments, sector-specific interventions, rural development, and annual performance reports. The goal is to reduce administrative burdens, enhance flexibility for Member States and farmers, and better align the CAP with the needs of various agricultural stakeholders, including small farmers, organic farmers, and young farmers.
**2. Structure and Main Provisions:**
The Regulation is structured as an amending act, modifying specific articles and annexes of the two primary regulations it addresses:
* **Amendments to Regulation (EU) 2021/2115 (CAP Strategic Plans):**
* **Permanent Grassland:** Allows Member States to extend the period for classifying land as permanent grassland from five to seven years and to decide that land remains arable land even after the five or seven-year period.
* **Crisis Payments:** Introduces crisis payments to farmers following natural disasters, adverse climatic events, or catastrophic events.
* **Conditionality:** Exempts small farmers from the conditionality system.
* **GAEC Standards:** Clarifies the implementation of Good Agricultural and Environmental Condition (GAEC) standards, including exemptions for organic farmers and temporary derogations for plant diseases or pest infestations.
* **Risk Management Tools:** Modifies the rules for Member States to contribute to risk management tools.
* **Small Farmers Scheme:** Increases the maximum amount that can be received under the simplified payment scheme for small farmers.
* **Eco-schemes:** Modifies the requirements for eco-schemes, including support for commitments contributing to compliance with national legislation.
* **Rural Development:** Includes business development of small farms among the interventions that Member States can support and provides for lump sum support for that intervention.
* **Financial Instruments:** Modifies the rules for implementing financial instruments in the CAP, including eligibility of expenditure and gross grant equivalent ceilings.
* **Amendments of CAP Strategic Plans:** Simplifies the amendment procedures for CAP Strategic Plans, distinguishing between strategic and non-strategic amendments.
* **Annual Performance Reports:** Modifies the content and procedure for annual performance reports.
* **Amendments to Regulation (EU) 2021/2116 (Financing, Management and Monitoring of the CAP):**
* **Monthly and Interim Payments:** Modifies the rules for monthly and interim payments by the Commission.
* **Suspension of Payments:** Amends the rules on suspension of payments.
* **Advance Payments:** Increases the maximum rates for advance payments.
* **Clearance of Accounts:** Deletes the annual performance clearance procedure.
* **Controls and Penalties:** Modifies the control and penalty system, including exemptions for small farmers and adjustments to the risk analysis process.
**3. Main Provisions for Practical Use:**
* **Flexibility in Land Classification:** The extended period for classifying land as permanent grassland and the option to keep land classified as arable land provide farmers with greater flexibility in managing their agronomic rotations.
* **Crisis Payments for Farmers:** The introduction of crisis payments offers a new avenue for Member States to support farmers affected by natural disasters or other catastrophic events.
* **Exemption from Conditionality for Small Farmers:** The exemption of small farmers from the conditionality system reduces administrative burdens and compliance costs.
* **Simplified Amendment Procedures for CAP Strategic Plans:** The distinction between strategic and non-strategic amendments simplifies the process for Member States to adapt their CAP Strategic Plans to changing circumstances.
* **Increased Support for Small Farmers:** The increased maximum amount under the small farmers scheme and the inclusion of business development as a supported intervention enhance the attractiveness of the scheme.
Decision No 1/2025 of the EU-Morocco Association Council of 2 October 2025 amending Protocol 4 to the Euro-Mediterranean Agreement establishing an association between the European Communities and their Member States, of the one part, and the Kingdom of Morocco, of the other part, concerning the definition of the concept of ‘originating products’ and methods of administrative cooperation [2025/2664]
Here’s a breakdown of Decision No 1/2025 of the EU-Morocco Association Council:
**1. Essence of the Act:**
This decision amends Protocol 4 of the Euro-Mediterranean Agreement between the EU and Morocco, which concerns the rules of origin for products traded between the two parties. The amendment introduces an alternative set of rules of origin that can be used until the end of 2027, establishes a quota system for certain vegetable oils and tobacco products, and updates the reference to the Regional Convention on pan-Euro-Mediterranean preferential rules of origin to ensure it always refers to the most current version.
**2. Structure and Main Provisions:**
* **Replacement of Titles and Annexes:** The core of the decision replaces Titles I to VII of Protocol 4, along with Annexes I to VI and Joint Declarations, with a new set of provisions.
* **Title I: General Provisions**
* Article 1: Specifies that Appendix I and relevant provisions of Appendix II to the Regional Convention on pan-Euro-Mediterranean preferential rules of origin apply for implementing the Agreement.
* Article 2: Introduces alternative applicable rules of origin, outlined in Appendix A (“transitional rules”), valid until December 31, 2027, or until the Convention is published in Morocco’s Official Gazette, whichever comes first.
* Article 3: Establishes quotas for specific products listed in Appendix B, where only the provisions of Appendix B apply for five years from the Protocol’s entry into force.
* Article 4: Allows for retrospective issuance of proofs of origin for exports between January 1, 2025, and the date of the Protocol’s entry into force.
* **Title II: Final Provisions**
* Article 5: Affirms the Association Council’s power to amend the Protocol.
* Article 6: Sets up a process for settling disputes related to verification procedures.
* Article 7: Addresses the scenario where either the EU or Morocco withdraws from the Convention, mandating negotiations on new rules of origin.
* **Appendices:**
* Appendix A: Contains the “alternative applicable rules of origin” (transitional rules), detailing definitions, general requirements for originating products, territorial requirements, rules for drawback or exemption, proof of origin procedures, and administrative cooperation.
* Appendix B: Lists products subject to quotas and specifies the applicable rules of origin within those quotas.
* **Amendments to Title VIII:** Title VIII is amended to become Title II, containing final provisions regarding amendments to the Protocol and dispute settlement.
**3. Main Provisions for Practical Use:**
* **Alternative Rules of Origin (Appendix A):** Businesses have the option to use these rules instead of the standard pan-Euro-Mediterranean rules for a limited time. This could offer more flexibility in meeting origin requirements.
* **Quota System (Appendix B):** For specific vegetable oils and tobacco products, preferential treatment is limited to the quantities defined in Appendix B. Businesses exporting these products need to be aware of these quotas and how they are managed.
* **Transitional Period:** The alternative rules of origin are temporary, expiring at the end of 2027. Businesses should monitor the situation and be prepared to comply with the standard pan-Euro-Mediterranean rules after this date.
* **Cumulation of Origin:** The decision allows for cumulation of origin with other applying Contracting Parties, meaning that materials originating in those countries can be considered as originating in the exporting country when determining the origin of the final product.
* **Proof of Origin:** The decision specifies the requirements for proof of origin, including the use of movement certificates EUR.1 and origin declarations.
: This act may have implications for Ukrainian businesses that have trade relations with the EU and Morocco, as it changes the rules of origin for products traded between these countries. Ukrainians residing in EU may be involved in the trade between EU and Morocco.
