Global Trade Compliance Updates

📢 EU CBAM is Now Fully Operational: What You Need to Know On January 1, the EU’s Carbon Border Adjustment Mechanism (CBAM) came into full effect. Here are the key things sustainability, finance, and strategy teams should understand: 🔹 An overview CBAM is the first fully operational border carbon pricing system designed to prevent carbon leakage, the shifting of emissions-intensive production outside the EU, while protecting EU firms subject to internal carbon costs. 🔹 What has changed? Unlike prior pilots, the 2026 implementation bases costs on actual emissions intensity of imports. The EU has “externalized” carbon pricing beyond its borders, which has implications for supply chains and global trade flows, especially for goods like steel, aluminum, cement, electricity, fertilizers, and certain chemicals. 🔹 What do companies need to do? Importers and their non-EU suppliers will need to: - Map supply chains and embedded emissions - Coordinate with suppliers on verified emissions data - Assess carbon cost exposure and potential downstream price impacts 📈 The big picture CBAM goes beyond a compliance issue for firms and has real implications for supply chains and operating costs. Investors and businesses are beginning to factor in carbon pricing and supply-chain decarbonization into their financial decisions. We’ve been helping firms manage these shifts and respond strategically. Send me a message if you’d like to learn more. Visual courtesy of Carbonwise #CBAM #EURegulations #CarbonPricing #ClimatePolicy #SustainableTrade #ClimateRisk #SupplyChainEmissions #NetZero #ESG #ClimateFinance #Decarbonization

The European Commission has introduced a new carbon tax on imported goods called the Carbon Border Adjustment Mechanism (CBAM). This is meant to make sure that European companies and companies from other parts of the world are on the same page when it comes to carbon pricing and environmental commitments. Here are the main changes: 🔴 Emissions Reporting: Starting in October this year, companies have to start keeping track of how much carbon is linked to the goods they import. They need to start reporting this data by January 2024. This reporting will continue until the end of 2025. 🔴 Carbon Leakage Prevention: CBAM is a way to prevent companies from moving their production to places with weaker environmental rules to avoid carbon costs. It makes sure that European products and products made outside of Europe have similar carbon costs. 🔴 CBAM Certificates: Importers have to get CBAM certificates to match the carbon pricing between EU and non-EU products. They need to provide details about the product's carbon footprint, where it's from, how it's made, and its emissions data. This includes emissions during production and indirect emissions, like electricity use. 🔴 Covered Sectors: CBAM applies to industries with high carbon emissions like iron and steel, cement, fertilisers, aluminium, electricity, hydrogen, and some downstream products like screws and bolts. It also covers certain indirect emissions under certain conditions. Importers mainly need to report emissions during the transition phase until 2026. To help importers and producers outside of the EU adapt, the EU Commission is providing guidelines and tools to calculate emissions. They're also offering training materials and webinars. Some important data points to consider: 🟢 Carbon Leakage: A study by the European Environmental Bureau warns that unchecked carbon leakage could cause a 15% increase in global emissions, undermining climate efforts. CBAM aims to prevent this. 🟢 Emissions Differences: The World Trade Organization says that different countries have different emissions rules, leading to different carbon costs. CBAM aims to make this fairer. 🟢 Economic Impact: The European Commission estimates that the global carbon allowance market could be worth €4.5 billion per year by 2030. CBAM will significantly affect international trade and revenues. 🟢 Industry Shift: A study by the European Parliament Research Service shows that without CBAM, high-emission industries might move to places with weaker rules, leading to job losses and less competitiveness in the EU. 🟢 Green Transition: The International Monetary Fund says that well-designed carbon pricing like CBAM can encourage industries to become more environmentally friendly, contributing to a greener global economy. 🟢 Regulatory Challenges: CBAM's reporting requirements might be tough for importers initially. However, the long-term benefits of fair carbon pricing are expected to outweigh the challenges.

From my expertise working inside the FDA and alongside CBP, I can tell you this — what just happened isn’t a trade adjustment, it’s a regulatory upheaval. New import taxes are being introduced under the guise of fairness, but they’re about to trigger a domino effect that affects everyone moving products across borders — especially those regulated by federal agencies. Costs won’t just rise. Risk will. Businesses operating in highly controlled industries will now face a triple-threat: 🔸 Unpredictable border interventions 🔸 Shifting agency priorities 🔸 Higher stakes for even minor missteps I’ve seen this kind of pressure play out from the inside. It’s not just about what you bring into the country — it’s about whether your business is built to survive these shifts. If you're responsible for compliance, legal strategy, or product movement — especially in food, supplements, drugs, devices, cosmetics, or even pet goods — now’s the time to act, not react. #TradePolicy #RegulatoryStrategy #FDACompliance #TariffImpact #USImports #GlobalTrade #CBPEnforcement #SupplyChainRisks #ExecutiveLeadership #LegalStrategy #FoodLaw #PharmaCompliance #MedicalDeviceRegulations #PetIndustryRegulations #CrossBorderTrade #ProductSafety #RiskMitigation #ThoughtLeadership #USDA #LinkedInCreators

🚨 BREAKING: The EU Commission has just published the Digital Omnibus [HINT: Yes, the Washington Effect is here]. These are some of the changes being proposed to the EU AI Act: 1. Linking the implementation timeline of high-risk rules to the availability of standards or other support tools; 2. Extending regulatory simplifications granted to small and medium-sized enterprises to small mid-caps, including simplified technical documentation requirements and special consideration in the application of penalties; 3. Requiring the Commission and the Member States to foster AI literacy instead of enforcing this obligation on providers and deployers of AI systems; 4. Removing the prescription of a harmonized post-market monitoring plan; 5. Removing the registration obligation for providers of AI systems that are used in high-risk areas, but for which the provider has concluded that they are not high-risk; 6. Centralizing oversight over a large number of AI systems built on general-purpose AI models or embedded in very large online platforms and very large search engines with the AI Office; 7. Allowing providers and deployers of all AI systems and models to process special categories of personal data for ensuring bias detection and correction, with the appropriate safeguards; 8. A broader use of AI regulatory sandboxes and real-world testing; 9. Targeted changes clarifying the interplay between the AI Act and other EU legislation and adjusting the AI Act’s procedures to improve its overall implementation and operation. - These changes reflect the EU's narrative shift, which we have been observing since the Draghi report on European Competitiveness, published in September 2024. Over the past 11 months, especially after Trump's election, the EU has been scrambling to appear more "business-friendly" and deregulatory to Washington (watch videos of the AI Summit in February, especially JD Vance's speech). Its recent publications seem to highlight its new focus on innovation and an "AI-first" mentality - even when it does not make sense, as a recently posted video of Ursula von der Leyen made clear. The digital omnibus seems to be the coronation of this new European mentality, but it's still unclear to me how these changes will foster innovation or improve European competitiveness. Lastly, negotiations will now begin, and it's unclear when they will finish. At the same time, there is an upcoming EU AI Act milestone on August 2nd, 2026. Perhaps unsurprisingly, this might lead to MUCH MORE legal uncertainty than before. Europe is changing, and Europeans who care about protecting fundamental rights in the digital sphere should share their thoughts loudly and clearly, and act before it's too late. 👉 Read my full analysis of the proposed changes to the AI Act and join my newsletter's 86,300 subscribers below.

In a panel discussion some months ago, I said that anonymising personal data (PD) was a promising means of facilitating cross-border data flows, because once you can no longer identify an individual from the data, it should no longer fall within many countries' definition of PD, and would not be subject to export requirements. Someone asked if it was worth talking about anonymisation since it is reversible. I wasn't sure if it was a rhetorical question or philosophical question (if anonymisation is reversible, has there really been anonymisation?), or maybe we ascribed different meanings to the term, as do many jurisdictions. But in one of my LI posts I said that I would write more about it. This is what this post is about. When I use the term "anonymisation", I'm referring to the PDPC's definition of it i.e. the process of converting PD into data that cannot identify any particular individual, and can be reversible or irreversible. And to me, anonymisation is not like flipping a light switch such that you get light or no light, 1 or 0. There are factors that can affect re-identification of a person, e.g. - the number of direct and indirect identifiers in the dataset - what other data the organisation has access to (including publicly accessible info), which, when combined with the dataset, could re-identify the individual - what measures the organisation takes to reduce the possibility of re-identification e.g. restricting access to / disclosure of the dataset. So I think it is not so useful to think about anonymisation in binary terms. What I suggest we should think about is the possibility of re-identification. Think of a dimmer switch instead. When you see the cleartext dataset, that's when the light is on. When you start turning the dial down - the more direct and indirect identifiers you remove, the more safeguards you implement vis-a-vis the dataset - the dimmer the light gets, the possibility of re-identification is reduced. If you (a) remove all direct and indirect identifiers from a dataset, (b) encrypt it, and (c) only give need-to-know employees read access, I think the light's going to be pretty dim. It might no longer be PD, meaning that you can export it without being subject to export requirements. So yes, I think that anonymisation is a promising means of facilitating CBDF. Do note that you should also apply the "motivated intruder" test and consider if someone who has the motive to attempt re-identification, is reasonably competent, has access to appropriate resources e.g. internet, and uses investigative techniques, could re-identify the individual (see the ICO's excellent draft guidance https://lnkd.in/gmRfXj-W, and The Guardian's 2019 article https://lnkd.in/gZXfkHVC).

ESG Regulations Map 🌍 The latest Global Regulations Radar – 3rd Edition developed by ERM provides a snapshot of the fast-evolving ESG and EHS regulatory landscape, offering insight into global developments with growing relevance for multinational companies. The European Union remains the global benchmark. Its Packaging and Packaging Waste Regulation and Urban Wastewater Treatment Directive are pushing mandatory circularity, reuse targets, and polluter-pays models. These regulations will reshape operations for sectors from manufacturing to food and pharmaceuticals. At the same time, the EU Omnibus proposal introduces delays and simplifications to several flagship regulations, including CSRD, CSDDD, the EU Taxonomy, and CBAM. While the proposal aims to reduce administrative burden, it has raised concerns about weakening the EU’s leadership in sustainability and slowing momentum at a critical time. The United States is experiencing a regulatory reversal at the federal level. Key climate and disclosure policies have been rolled back, including EPA emissions rules and the SEC climate disclosure rule. Yet, states like California are advancing their own mandates, with SB 253 and SB 261 requiring emissions and climate risk disclosures as early as 2026. Mexico has introduced new Sustainability Information Standards with the first reporting wave set for 2026 using 2025 data. These standards represent a step toward greater alignment with international disclosure frameworks and will impact companies with operations or supply chains in the country. Japan is taking a leading role in the Asia-Pacific region. The release of the SSBJ sustainability disclosure standards, aligned with ISSB’s global frameworks, marks a significant step in improving ESG reporting. Voluntary adoption is already encouraged, with phased mandatory application expected based on company size. Kenya and the UAE are emerging as regional leaders. Kenya’s carbon market regulations establish rules for both voluntary and compliance markets. The UAE’s new federal law mandates GHG tracking, climate risk disclosures, and introduces a national carbon credit registry, reinforcing its Net Zero 2050 ambition. The timeline is accelerating. With multiple obligations coming into force between 2025 and 2027, companies must navigate a growing patchwork of requirements. Early alignment with leading standards and proactive adaptation of internal systems will be critical for legal compliance, investor confidence, and competitive positioning. #sustainability #sustainable #business #esg

The EU Parliament has given the final green light to the revised 'Waste Framework Directive'. It sets new rules to cut food waste and requires producers to take full responsibility for textile waste, from collection to recycling. 🔹 Textiles: Producers selling textiles in the EU must cover the costs of collection, sorting, and recycling. EU countries must introduce an Extended Producer Responsibility (EPR) scheme to enforce the new rules. All producers are covered, including e-commerce sellers, whether based in the EU or outside. Producers must disclose data on volumes of waste and their handling. The new rules apply to clothing, footwear, accessories, hats, blankets, bed & kitchen linen, curtains. 🔹 Food waste: Binding reduction targets by 2030: 10% in processing/manufacturing and 30% per capita in retail, restaurants, food services, and households. Key business players must help prevent food waste and ensure safe, unsold food is made available for donation. 👉 Yes, some sustainability regulations (like CSRD and CSDDD) face headwinds. But let’s not forget: progress continues in other key areas. === Press Release: https://lnkd.in/dkYnNzvT

🚨 Exclusive: Russian Navy Escorts Shadow Fleet Tankers Through English Channel A major step in sanctions evasion. For the first time, we now have confirmation of Russian naval escorts accompanying unflagged, sanctioned tankers through European waters. 🎥 The video below shows AIS movements since 16 June — revealing how two shadow fleet tankers and a Russian warship coordinated to enter the English Channel together. Their movements suggest deliberate timing to allow all three vessels to transit simultaneously, en route to load oil in Russia. - BOIKIY, a Steregushchy-class Russian Navy corvette. - SELVA (aka NOSTOS/NAXOS) — UK sanctioned, transmitting AIS as Panama-flagged, but listed as flag unknown in the IMO database. (UPDATE: as of 22 June 17:00 UTC Palau flagged) - SIERRA (aka SUVOROVSKY PROSPECT) — UK & EU sanctioned, falsely flagged to Malawi, confirmed by Lloyd's List. 🇫🇮 Finland’s Defence Minister warned these escorts were coming, calling them “unprecedented.” These new actions confirm what many suspected: following Estonia’s boardings and growing scrutiny from EU states, Russia is now openly protecting the shadow fleet with naval force. 🛰️ Huge credit to OSINT experts on Bluesky — especially Christian Panton 🚀 — for first identifying the vessels. At Starboard Maritime Intelligence, we’re continuing to track these tankers and flag evolving behaviour. This isn’t a grey zone anymore. It’s a test of whether enforcement and international resolve are ready for what comes next. #ShadowFleet #RussianNavy #SanctionsEvasion #MaritimeSecurity #EnglishChannel #BalticSea #MDA #OSINT #AIS #Starboard

April 2025 has ushered in a fresh test for India’s yarn industry: a 26% US tariff on our imports. Having spent decades scaling businesses and navigating market shifts, here’s my take on what this means and how we can turn it to our advantage. India is in a stronger position than its rivals. With China facing 34%, Bangladesh at 37%, and Vietnam hit with a steep 46%, our 26% tariff offers a competitive edge in the US market. American buyers might shift toward Indian yarn, boosting demand and potentially growing our share—if we act strategically. That said, challenges loom. The 26% tariff still raises costs, and US consumers may not absorb the hike. Our edge could erode unless we streamline logistics and boost operational efficiency. Rerouted trade flows might also strain infrastructure. And if the US market contracts, we’ll need other global buyers—fast. So, what’s the play? •First, India should negotiate smarter US trade terms, perhaps securing zero-duty cotton imports. •Second, diversify markets; over-reliance on one is risky. •Finally, double down on efficiency—cut costs, maintain quality, and stay agile. This tariff isn’t just a barrier—it’s a wake-up call. India’s yarn sector has the talent and grit to make this a win. What’s your view—where should we focus to adapt and thrive? #ustariffs #textile #textileindustry #leadwithrajeev #leadership #globalmarket