2025 Key Dates for EU Trade and Regulatory Developments

Key Points

• 2025 will be a busy year for EU trade and regulatory developments.
• Key obligations under several existing regulations will become enforceable in 2025.
• Significant revisions to existing regulations and the conclusion of negotiations for new regulations are also anticipated.
• Bookmark this Alert to stay up-to-date on key dates in 2025.

This year will be an active one for trade and regulatory developments in the European Union (EU). During the 2019–2024 term of the European Commission, the EU introduced a wide range of regulations impacting various sectors. Many of these regulations were designed with a phased implementation approach, with obligations rolled out progressively over several years. Now, many of those significant obligations will enter into effect. In addition, with the new EU Parliament and Commission in place, significant revisions to existing regulations, along with the adoption of new regulations, are expected this year. Below, we provide an overview of key dates to watch in important trade and regulatory areas. Further details on specific initiatives and deadlines will be provided in the Commission’s 2025 work programme, which is expected on 11 February.

Competitiveness

• The Commission plans to unveil a new “Competitiveness Compass” together with its Annual Single Market and Competitiveness Report in January 2025. It was initially set to debut on 15 January but may be delayed due to President Ursula von der Leyen’s illness in early January. This initiative intends to build off the report authored by Mario Draghi, “The future of European competitiveness – A competitiveness strategy for Europe”. The Compass will provide a framework to increase EU competitiveness, focusing on boosting productivity and innovation, and increasing security through reduced dependencies.
• The Commission is expected to unveil an “Omnibus” bill in February 2025 that reportedly will reduce administrative procedures and reporting requirements under the Corporate Sustainability Due Diligence Directive (CS3D), the Corporate Sustainability Reporting Directive (CSRD) and the Green Taxonomy Regulation. This follows the November 2024 Budapest Declaration by EU member states’ leaders that requested the Commission make “concrete proposals on reducing reporting requirements by at least 25% in the first half of 2025.”
• On 26 February 2025, the Commission is expected to unveil a draft of the Clean Industrial Deal, which is expected to include proposals to lower energy costs, support companies in energy-intensive sectors and promote clean technologies. This will be a key initiative of this Commission (2024-2029), similar to the European Green Deal of the last Commission (2019-2024).
• The European Green Deal set up mandatory targets and related fines for the automotive sector. New stricter CO2 emission limits start applying in 2025 and European automakers will be subject to fines if their fleet of sold cars exceeds these. Ultimately, these limits are aiming at banning the sale of new cars with internal combustion engines in 2035. However, in late 2024, a number of stakeholders and lawmakers issued calls to the Commission to re-think this legislation. In January, the European Parliament will debate a proposal by its strongest political fraction, the European People’s Party (EPP), and the Commission President in parallel will set up a Strategic Dialogue on the Future of the European Automotive Industry, which she will chair.

Trade Agreements

• A tense political debate is expected to begin in January 2025 as the Commission begins the process of seeking approval for the recently concluded EU-MERCOSUR (Argentina, Brazil, Paraguay and Uruguay) free trade agreement (FTA), one of the most significant deals negotiated by the EU in recent years. Tense debates are expected in the Council, where a qualified majority (at least 15 countries representing at least 65% of EU population) is required, with several member states, including France and Poland, expected to oppose this FTA. The Commission is also expected to continue FTA negotiations in 2025 with India, Indonesia and the Philippines, as well as pursue digital agreements with some pre-existing trade partners.

Tariff Retaliation

• On 31 March 2025, the EU’s decision to suspend retaliatory tariffs on US imports in connection with the US Section 232 steel and aluminum tariffs will expire. If not renewed or otherwise addressed as part of a broader tariff deal, it could result in higher tariffs on a wide range of imports from the United States.

Climate and Environment

• 2025 is the final phase of the provisional period of the Carbon Border Adjustment Mechanism (CBAM), before financial charges on imports begin to apply in 2026. Starting 1 January 2025, companies no longer have the option to select their reporting method for embedded emissions; only the “EU method” will be allowed. Also on 1 January 2025, a new section of the CBAM Registry portal was launched, enabling installation operators outside the EU to upload and share their installation and emissions data directly with reporting declarants in a more streamlined process, eliminating the need for separate submissions to individual declarants. From early 2025, CBAM declarants will be able to apply for “authorised CBAM declarant” status through the CBAM Registry. The European Commission is expected to publish a report on the implementation of the CBAM Regulation before the end of the year. This report will assess several aspects of the regulation, including the potential expansion of its scope to cover additional goods, such as organic chemicals and polymers, as well as the inclusion of embedded indirect emissions for iron and steel, aluminum and hydrogen.
• On 19 February, the Commission is expected to present a “Vision on Agriculture and Food,” which will look at how to ensure the long-term competitiveness and sustainability of Europe’s farming sector within the boundaries of the planet.
• The Regulation on Deforestation-Free Products, commonly referred to as the Deforestation Regulation (EUDR), aims to combat deforestation by ensuring that products sold in the EU are not sourced from deforested land. The EUDR was initially set to apply at the end of 2024, but the Commission and the co-legislators recently agreed to postpone its application by 12 months. As a result, the regulation’s key obligations will now take effect on 30 December 2025. The Commission is required to classify countries into different risk categories under the regulation by 30 June 2025.
• The EU Emissions Trading System (EU ETS) was extended to maritime transport in January 2024. Shipping companies must surrender (use) their first ETS allowances by 30 September 2025 for emissions reported in 2024. This includes emissions for large ships (of 5,000 gross tonnage and above) entering EU ports, regardless of their flag.
• The Packaging and Packaging Waste Regulation (PPWR) is awaiting publication in the EU Official Journal and is expected to enter into force in January 2025. This regulation introduces strict rules regarding packaging placed on the EU market. Key measures included in the regulation require all packaging to be recyclable, set minimum recycled plastic content requirements for plastic packaging and ban certain types of single-use packaging. However, the regulation’s requirements will be implemented gradually over several years.
• In March 2023, the Commission adopted a proposal for a directive on substantiation and communication of explicit environmental claims, known as the Green Claims Directive. This directive aims to combat “greenwashing” by establishing rules for environmental claims and labels used by companies to market their products. Both the Council and the European Parliament adopted their positions on the proposal in 2024, and interinstitutional negotiations on the final text are set to begin in January 2025.

Forced Labour

• The Regulation on Prohibiting Products Made with Forced Labour on the Union Market entered into force on 13 December 2024 and implementation will start in 2025. member states must designate the competent authority or authorities who will be responsible for enforcing the Forced Labour Regulation by 14 December 2025. The Commission is expected to begin work on the database required under the Regulation, which will, among other things, eventually identify high risk geographic areas and economic sectors.
• The Regulation’s obligations on economic operators will apply from 14 December 2027.

Sustainability Reporting

• The Corporate Sustainability Reporting Directive (CSRD), which came into effect in 2023, requires companies to report on their sustainability efforts. The implementation is being phased-in based on company size and type. Starting in 2025, the first group of companies—i.e. certain large public-interest entities—must publish reports covering their 2024 financial year. For other large undertakings that are not public-interest entities, the new reporting rules will apply to the 2025 financial year, with publication required in 2026.

Cosmetics

• The Commission has been expected to publish a proposal for the revision of the Cosmetics Product Regulation since 2022, following the completion of an impact assessment and public consultations. However, the proposal has faced delays. It is now anticipated that the Commission will publish a proposal for the revised regulation in the first quarter of 2025. Alternatively, the Commission may choose to restart the process entirely, initiating new consultations and conducting a fresh impact assessment during 2025.

Chemicals

• A revision of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation, the EU’s chemicals regulation, is also expected in 2025. This revision was originally promised as part of the European Green Deal but has faced repeated delays. The Commission has indicated plans to introduce a new chemicals industrial package aimed at simplifying REACH.
• Two committees of the European Chemicals Agency (ECHA)—the Risk Assessment Committee (RAC) and the Socio-Economic Assessment Committee (SEAC)—are currently reviewing a proposal submitted by six member states in 2023 to introduce an EU-wide ban on the use and production of per- and polyfluoroalkyl substances (PFAS), also known as “forever chemicals”. This proposal targets a group of over 10,000 substances and, if implemented, would have significant implications for many industrial sectors. The review process will advance further throughout 2025 and is expected to result in an opinion from the RAC and a draft opinion from the SEAC. Following this, a consultation will be held on SEAC’s draft opinion. Once ECHA finalizes its opinions, the Commission will take over responsibility for drafting a definitive proposal on PFAS for a vote by the member states. This proposal may include restrictions or an outright prohibition of PFAS, along with sector-specific exemptions.

Eco-design

• The Ecodesign for Sustainable Products Regulation (ESPR) entered into force in July 2024. This regulation enables the establishment of performance and information requirements—referred to as “ecodesign requirements”—for nearly all physical goods. The Commission will set specific ecodesign requirements for products through delegated acts in the coming years. In the first half of 2025, the Commission will adopt the ESPR working plan, which will outline the priority products to be targeted in the years ahead.

AI

• The European Artificial Intelligence Act (AI Act) entered into force on 1 August 2024, with its provisions being implemented progressively between 2025 and 2027.
• The rules on prohibited AI systems, outlined in Article 5, will apply starting 2 February 2025. Additionally, on 2 August 2027, other key provisions will come into effect, including those related to high-risk and general-purpose AI models, governance frameworks and penalties. Member states must also designate competent authorities by this date.
• Experts drawing up the General-Purpose AI Code of Practice will hold meetings during January-March 2025. The final version is expected to be completed by 2 May 2025.

Digital

• The Digital Operational Resilience Act (DORA) entered into force in January 2023 and will apply as of 17 January 2025. DORA aims at strengthening the information technology (IT) security of financial entities such as banks, insurance companies and investment firms. By this date, financial entities covered under DORA must comply with several requirements related to the security of their network and information systems supporting business processes. These include implementing an information and communication technology (ICT) risk management framework, establishing a system for monitoring and reporting major ICT-related incidents, conducting digital operational resilience testing, and maintaining a comprehensive register of contractual arrangements with third-party ICT service providers.

Our team will be watching developments in these areas closely. Do not hesitate to reach out to our lawyers and advisors if you have any questions.