With trade war between China and the US on the doorsteps, implications for EU companies will be manyfold. One possible consequence could be heavily subsidised Chinese products flooding the EU market. Particularly for medical devices, there is an increased probability that this might happen. However, such a development would not meat European companies defenceless.

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.

Last week it became official: Germany’ will not implement the Directive (EU) 2022/2555 (known as the NIS-2 Directive) to improve cybersecurity in the EU under the current administration. See below for some guidance on what that means:

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.

With the 15th amendment of the Foreign Trade and Payments Ordinance (AWV), the Federal Ministry for Economic Affairs and Energy will soon extend its control over acquisitions of German companies by EU foreign companies. The amendment is perceived as the Federal Government’s direct reaction to the COVID-19 crisis, due to its concern in large part to protect the healthcare sector. The case of the Tübingen-based company CureVac, involving a US purchaser and raising the question of the right of prohibition, may have also contributed to this development. The 16th amendment to the AWV is expected to comprehensively expand and adapt investment control in foreign trade law. It is aimed at uniformly implementing Regulation (EU) 2019/452 (*_EU Screening Regulation*_), which came into force in April 2019, and the amendment to the Foreign Trade and Payments Act (AWG) adopted already by the Cabinet on 8th April 2020. Since the latter remains under discussion in the committees of the Bundestag, the Federal Ministry for Economic Affairs and Energy has brought forward what it considers to be particularly urgent adjustments.

27 March 2020
The current Covid 19 pandemic has long since developed into an economic crisis, the full impact of which cannot yet be predicted. The crisis also affects those companies that are active in so-called systemically important areas and whose commitment is particularly important for the protection of public health. In the opinion of the EU Commission, it is therefore particularly important to prevent a “sell-out” of companies and technologies that are critical and key to the health sector.