Trade & Export

Germany NIS2 Cybersecurity Law Implementation Deadline

Germany's implementation law for the NIS2 Directive, effective December 2025, expands cybersecurity requirements to new sectors including digital services and manufacturing. Covered entities must register with the BSI by March 6, 2026, and comply with new security and incident reporting obligations.

USITC Launches Investigations into China Trade Relations and Biotech Support

The US International Trade Commission (ITC) has launched two Section 332 investigations: one examining the economic effects of revoking China's permanent normal trade relations status, and another reviewing China's state support and pricing practices in the biotechnology sector. These investigations will provide an analytical record for Congress and the administration regarding future trade and industrial policy measures targeting China.

OFAC Fines IMG Academy for Sanctions Violations

The Office of Foreign Assets Control (OFAC) has fined IMG Academy $XXX,XXX for accepting tuition payments from parents designated under sanctions. The enforcement action highlights the pervasive nature of sanctions risk across various sectors, including educational institutions.

USITC Investigates Chinese Biotech State Support and Pricing

The U.S. International Trade Commission (USITC) has launched an investigation into Chinese state support and pricing practices within the biotechnology sector. The investigation aims to assess the impact on U.S. industry competitiveness and market share, with a report due by January 2027.

Court Orders Customs to Refund IEEPA Duties to Importers

The Court of International Trade has ordered U.S. Customs and Border Protection (CBP) to refund International Emergency Economic Powers Act (IEEPA) duties to all importers. CBP must liquidate unliquidated entries and reliquidate final entries without these duties.

Supreme Court Rules IEEPA Lacks Authority for Reciprocal Tariffs

The Supreme Court ruled in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) does not grant the President authority to impose reciprocal tariffs. This decision impacts an estimated $175 billion in collected tariff revenues, raising questions about potential refunds.

CIT Orders Refunds of IEEPA Tariffs on Unliquidated Entries

The Court of International Trade (CIT) has ordered U.S. Customs and Border Protection (CBP) to refund tariffs collected under the International Emergency Economic Powers Act (IEEPA) on unliquidated and not finally liquidated entries. This ruling benefits all importers who paid these tariffs.

Supreme Court Invalidates Tariffs Imposed Under IEEPA

The U.S. Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs, invalidating recent "reciprocal" tariffs and fentanyl-related country measures. The decision will reshape the tariff landscape, with the Court of International Trade and U.S. Customs and Border Protection expected to establish refund procedures for duties paid.

UK ICO Guidance on Agentic AI and UK GDPR Compliance

The UK ICO has released a Tech Futures report analyzing agentic AI systems and their compliance with UK GDPR. The report emphasizes that developers and deployers of these systems must adhere to existing UK GDPR requirements, including those related to automated decision-making, data minimization, and accuracy.

Mideast War Disrupts LNG Contracts and Raises Supply Security Questions

The escalating conflict in the Middle East has disrupted LNG contracts, particularly due to the de facto closure of the Strait of Hormuz and attacks on Qatari facilities. This has led to record-high spot prices and is raising urgent questions about supply security and contractual performance for energy companies.