The increased political focus on climate and environmental protection has a particular impact on trade with chemicals. In an amendment to the REACH Regulation at the end of 2024, the European Commission banned the use of certain chemicals due to the risk of contamination. In this part of our ESG Briefing series, we provide an overview of the key provisions of the REACH Regulation and its latest amendments.

In view of the increasingly acute threat situation, driven in particular by growing doubts about the US' loyalty to NATO and the resulting restriction of the conventional and nuclear deterrence, the question arises: How well prepared is Germany for a further escalation of conflicts, especially that with Russia? Should asymmetric warfare - including against Germany - have even more far-reaching consequences, what legal instruments are available to the state in order to remain capable of acting in an external or internal emergency (innerer oder äußerer Notstand)? This briefing sheds light on the security and precautionary laws (Sicherstellungs- und Vorsorgegesetze), which have been rather neglected to date, and which (should) provide the necessary instruments for such situations.

Already the first Trump administration has restricted international trade by imposing tariffs of up to 25% on imports of steel and aluminium from the European Union (EU), provoking countermeasures by the EU. In 2021, these measures ceased to apply after the EU and United States (US) reached a corresponding agreement. On 12 March 2025, the US revived the tariffs. Again, the action has prompted the EU to implement countermeasures.

Trump is back and so are his tariffs (see our previous briefing on his return to office). As the EU has once again entered his crosshairs, the trading bloc is gearing up to defend its economy. For instance, President Trump has announced 25 % tariffs on steel and aluminium imports (set to kick in early March) as well as “reciprocal” tariffs, likely implying tariff hikes to match trading partners’ tariff rates for US goods. Meanwhile, domestic EU industries are already under considerable pressure, notably due to Chinese imports such as electric vehicles (EVs).

On the third anniversary of Russia's large-scale invasion of Ukraine, the EU has once again tightened its sanctions regime against Russia and Belarus. The most important amendments concern Regulation (EU) No 833/2014 (the Russia Regulation) and Regulation (EC) No 765/2006 (the Belarus Regulation). The respective amending Regulation (EU) 2025/395 and Regulation (EU) 2025/392 introduce additional and largely parallel restrictions on Russia and Belarus. While the extension of sanctions against the Russian “shadow fleet” or the import ban on Russian aluminium was already reported in the press, the sanctions package includes additional measures that deserve closer attention. We detail the most important aspects of these changes below.

Up until this point, there has been a strong emphasis on collaboration and unison for the EU and U.S. sanctions issued to address Russia’s aggression towards Ukraine. Now, while U.S. sanctions will not disappear overnight, there appears to be some increasing daylight in the approaches taken by the U.S. versus the EU, chiefly due to the new Trump administration’s dramatic shift in foreign policy and diplomacy. We provide highlights of the changed dynamics and potential trajectory for U.S. sanctions with respect to Russia below.

Im Dickicht des Außenwirtschaftsrechts fliegt so manches Regelwerk „unter dem Radar“ – so auch die Verordnung (EU) 649/2012 (PIC-Verordnung) über die Aus- und Einfuhr gefährlicher Chemikalien. In dieser Ausgabe unserer ESG-Briefing-Reihe stellen wir die Anforderungen an den Ex- und Import gefährlicher Chemikalien im Überblick dar.

Donald Trump is once again president of the United States. Reactions and expectations range from optimism, driven by hopes for an anti-regulatory agenda, to fears of a trade war with China. While it is a common refrain that uncertainty is bad for business, Trump has practically made unpredictability his trademark. In some cases, events can happen so quickly that they pass each other by the hour; a rate announced one day may be temporarily suspended the next. He has made it clear repeatedly that one of his priorities during his second term would be to protect the US economy and combat the US trade deficit. Time and again, the newly sworn-in president has publicly emphasised that he will not shy away from using trade policy measures to achieve domestic and foreign policy goals.

Reporting obligations under foreign trade law often place substantial bureaucratic burdens on companies and individuals. The changes and clarifications that took effect on 1 January 2025 are therefore particularly welcome: for instance, reporting thresholds have been significantly raised and reporting deadlines harmonised. In addition, the Foreign Trade and Payments Ordinance (Außenwirtschaftsverordnung – AWV) now explicitly stipulates that the transfer of crypto assets constitutes a reportable payment once the thresholds are met; moreover, new classification numbers for crypto assets have been introduced. We provide a summary of the key changes.

On 21 November, the European Court of Justice (CJEU) issued a far-reaching ruling on the legal treatment of production relocations under the Union Customs Code (Harley-Davidson Europe – C-297/23 P). The decision has been rendered against the backdrop of globally growing protectionist tendencies in international trade policy.

BLOMSTEIN hat den Hersteller für textile Hochleistungsmaterialien Outlast Technologies GmbH bei seinem Verkauf an den chinesischen Textilhersteller Shanghai Sunwin Industry Group Co., Ltd. zu investitionskontrollrechtlichen Aspekten beraten. Die Transaktion wurde zwischenzeitlich von den zuständigen Behörden, insbesondere dem Bundesministerium für Wirtschaft und Klimaschutz, genehmigt.