What to expect in 2025 - New trade regulations impacting European supply chains

To prepare for 2025, businesses are setting critical dates and timelines for their operations. Among these, it is essential to account for key customs and trade regulation deadlines, as well as updates to compliance requirements that could affect businesses engaged in cross-border trade.

Recent years have shown that keeping pace with evolving compliance standards can be challenging, often leading to supply chain disruptions and businesses incurring excess customs duties.

To keep you updated with some of the key changes, in this article we outline crucial changes in customs and international trade going into effect throughout 2025 and offer insights into what these changes mean for European businesses.

Staying on top of these regulatory changes is not anymore just about staying compliant and avoiding penalties – it is about realising a strategic value that proper customs procedures and diligence will have on your business.

Carbon Border Adjustment Mechanism

Carbon Border Adjustment Mechanism (CBAM) is the EU's tool that puts a price on carbon intensive products, such as cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen, imported into the EU.

Throughout 2024, companies have had to submit quarterly CBAM reports, which has come with its own set of challenges. While companies could previously submit their reports on default values, only the full reporting according to the EU method will be accepted as of 1 January 2025.

Other additions to the process will be a new portal section of the CBAM Registry, which will allow installation operators outside the EU to upload and share their installations and emissions data with reporting declarants in a streamlined manner. Throughout the year, CBAM declarants will be able to apply for the ‘authorised CBAM declarant’ status via the CBAM Registry, which will become mandatory as of 1 January 2026.

European Union Deforestation Regulation

EU Deforestation Regulation (EUDR) aims to guarantee that the products EU citizens consume do not contribute to deforestation or forest degradation worldwide. The regulation has a goal to reduce carbon emissions caused by EU consumption and production of the relevant commodities, and address deforestation driven by agricultural expansion.

For businesses dealing with goods under the scope of EUDR, this will mean putting due diligence systems in place that will allow them to collect information and documents showing their products are deforestation-free. It will also mean that companies need to assess whether there is a risk that their products are non-compliant, as well as adopt risk mitigation procedures, if this risk exists.

While the EUDR rules were set to apply for medium & large operators and traders as of 30 December 2024, this date has now been moved to 30 December 2025 for large companies and 30 June 2026 for micro- and small enterprises.

While this postponement will give businesses extra time to prepare, it should not be seen as an opportunity for prolonged inaction, but as one to get ahead of the compliance.

Ecodesign for Sustainable Products Regulation

The Ecodesign for Sustainable Products Regulation (ESPR) is part of a package of measures to foster the transition to a circular, sustainable, and competitive economy. The regulation sets the so-called “ecodesign requirements” for physical goods, as well as a number of other new measures, such as a Digital Product Passport and rules to address destruction of unsold consumer products.

The technical preparation for the roll-out of the Digital Product Passport is currently underway, while the first ESPR working plan that sets out which products will be prioritised over the coming years, will be adopted in the first half of 2025.

Once more information is available on the specific requirements that businesses need to fulfil to stay compliant, our teams will inform our customers accordingly.

To meet the challenges posed by the upcoming regulations, customers need to implement a robust compliance strategy. Find out more about preparing your business for the changing trade and customs regulations.

Safety and Security declarations for EU imports into the UK

The Safety and Security import requirements for goods from the EU were due to be implemented in 2022, but the implementation timeline was extended until 31 January 2025. From that date, any goods imported from the EU to Great Britain must be covered by a safety and security declaration – also known as entry summary declaration (ENS).

From 31 January 2025, the amount of data required on an ENS will be reduced to 20 mandatory fields, eight conditional ones, and 9 optional fields. The responsibility for submitting safety and security declarations lies with carriers or hauliers bringing goods into the UK, however third parties, such as customs agents, can submit the declarations on carrier’s behalf.

Although the carrier has the responsibility to make sure the entry summary declaration is submitted within the legal time limits, some of the data required may be held by the business or other parties. This means that collaboration and visibility between all parties in the supply chain will be needed to avoid compliance issues and delays at the border.

European Union Combined Nomenclature

A new version of the EU Combined Nomenclature (CN) takes effect on January 1, 2025. The Combined Nomenclature forms the basis for the declaration of goods at importation or exportation, or when subject to intra-Union trade statistics. This determines which rate of customs duty applies and how the goods are treated for statistical purposes.

Businesses trading products with updated or new CN codes, need to ensure they're reflected in customs declarations to avoid errors, potential fines, and delays due to goods stuck in customs. Businesses need to take action to ensure accuracy by checking and updating master data and templates. Find out more about the latest version of Combined Nomenclature.

Working with a trusted customs partner can help take the burden of staying on top of new regulations away from the business. Our customs consultants have a deep understanding of European regulations and can help you attain value from your customs procedures and move away from purely transactional customs. To find out more about Maersk Customs Services, click here or get in touch with our team.