Insights
Dated notes on the regulatory and supply shifts our clients are working through. Each is sourced, and each ends with what to check.
CBAM’s first real year. The bill is small; the data is not.
The EU carbon border adjustment has charged for embedded emissions since 1 January. Certificates for 2026 imports go on sale in February 2027 and must be surrendered by 30 September 2027. The 2026 charge is small, but it rises every year, and what it costs depends on data most importers do not yet hold.
China’s rare earth pause has two more months. Plan as if it ends.
China’s suspension of its October 2025 rare earth controls was due to end on 10 November. The US–China truce behind it now runs to 10 January 2027. The April 2025 licensing on seven medium and heavy rare earths never stopped. Magnet-dependent supply chains should plan for both.
EUDR applies on 30 December. There will be no further delay.
After two postponements, the EU Deforestation Regulation applies to large and medium operators on 30 December 2026. The Commission’s May review simplified the guidance but confirmed the date. Geolocation for every plot is still the requirement most supply chains cannot meet.
Failure to prevent fraud, one year on. What “reasonable procedures” means for your third parties
Since 1 September 2025, large organisations are liable for fraud committed by employees, agents and subsidiaries for their benefit. The main defence is reasonable procedures, and third parties are where most organisations are thinnest.
The US “affiliates rule” is paused, not gone. Check who owns your customers.
Washington’s pause on the BIS affiliates rule was due to end on 9 November and is expected to follow the US–China truce to 10 January 2027. When it returns, companies 50% or more owned by listed parties face the same restrictions as their owners, whether or not they appear on any list.
The largest UFLPA expansion yet reaches aluminium and copper
Forty-three companies joined the UFLPA Entity List in August, taking it to 187. Aluminium and copper now sit beside cotton and tomatoes, which brings transformer, cable and busbar supply chains into scope.
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