2025

On 17 December 2025, the European Commission published an amendment proposal (COM 2025/0419) to the Carbon Border Adjustment Mechanism (CBAM) Regulation (Regulation (EU) 2023/956), which proposes to expand CBAM to certain downstream goods and strengthen anti-circumvention provisions. The proposal also refines operational rules, including for electricity imports, exemptions, and market-stability safeguards.

Key takeaways:

  • EU and UK sanctions now increasingly target the full maritime logistics chain, including third country actors
  • Shadow-fleet measures have intensified scrutiny on vessels and operators
  • Compliance has become central to commercial decision-making
Continue Reading How sanctions transformed the shipping industry in 2025

The European Parliament and Council have reached a provisional political agreement to permanently end all imports of Russian natural gas into the EU on an accelerated timetable. The deal brings forward key deadlines for LNG and pipeline gas, tightens limits on contract amendments, enhances anti-circumvention and origin-tracking rules, and strengthens enforcement with significant penalties. Member…

During the Supreme Court’s oral argument in Learning Resources v. Trump last month, Justice Barrett asked counsel for the private plaintiffs about the tariff refund process if his clients prevail. After some back and forth, she summarized: “So a mess?”

Although the Court has not yet announced when an opinion may be released, entries subject…

Following the EU’s existing embargo on Russian crude oil and petroleum products, the European Commission has proposed, and the Council has now agreed in principle, a complementary Regulation designed to end the remaining inflows of Russian natural gas into the Union. The measure gives legal effect to the Commission’s May 2025 Roadmap towards ending Russian…

Key Takeaways

  • The measure seeks to close remaining ‘loopholes’ in the EU’s Russian oil embargo and maintain consistency with allied sanctions.
  • The safe-harbour country presumption eases compliance for imports from established crude exporters but can be rebutted by competent Member State authorities.
  • Risk-based due diligence remains essential: importers must be ready to demonstrate non-Russian origin if challenged.
  • Companies should now review supply chains, update contractual clauses, and ensure they can substantiate origin claims in due course.
  • On 15 October 2025, the UK announced intent to impose similar measures in due course.
Continue Reading New requirements for importing CN code 2710 cargo into the EU from 21 January 2026

In continuation of the UK’s sanctions restrictions against Russia, on 15 October 2025, the UK imposed further sanctions on various entities and vessels.

The headline designations include:

  • PJSC Rosneft Oil Company
  • Nayara Energy Limited (which was already subject to EU asset freeze restrictions)
  • Alghaf Marine DMCC
  • PJSC Lukoil

In some regards, these designations mirror the intent of the EU (noting their upcoming 19th sanctions package is intended to impose a full transaction ban on Russian oil majors), signaling joint efforts on the sanctions efforts against Russia between the UK and EU in recent months.

Continue Reading UK Sanctions – Rosneft, Lukoil and others 

China’s Ministry of Transport will impose a new “Special Port Service Fee” on U.S. linked vessels from 14 October 2025, aligning with U.S. Section 301 measures taking effect the same day. In its announcement, the Chinese Ministry of Transport criticises the U.S. actions announced in April this year and warns of significant disruption to maritime…