Global Supply Chain Horizons – September 2025 | Eversheds Sutherland (US) LLP

[co-author: Westley Trimble, Paola Paccani, Claire Webb*]

Welcome to the latest edition of our quarterly global supply chain horizons providing you with an update on the key developments from around the world.

• Cross-Border

• Asia

• Europe

• UK

• US

Cross-Border

UK new trade measures with emerging economies

On 10 July, the UK Government announced new measures to simplify imports from emerging economies and make it easier for businesses to trade with the UK. Goods from countries such as Nigeria, Sri Lanka and the Philippines will enter tariff free. Bangladesh and Cambodia will continue to benefit from zero tariffs on clothing and electronics. The measures are facilitated via the ‘Developing Countries Trading Scheme’. They aim to build resilience into supply chains and open up new opportunities. The updated rules are part of the UK’s Trade for Development offer. This is designed to boost partner countries’ economies and provide UK businesses and consumers with access to quality, affordable goods.

Impact: The announcement could help businesses secure existing supply chains, particularly in clothing and electronics. It could also provide new supply routes and opportunities with emerging markets.

UK-France industrial strategy partnership

On 11 July, the UK and France announced a new Industrial Strategy Partnership, the first initiative of its kind in Europe. It is intended to enhance economic cooperation and attract significant investment. Over £1 billion in confirmed investment deals were secured, which are expected to generate thousands of highly skilled jobs within the UK. This initiative aligns with the UK’s Modern Industrial Strategy, the ten-year plan designed to foster a resilient, high-skilled economy.

The partnership will prioritise key growth sectors such as technology, clean energy, and advanced manufacturing. Advancing the green and digital transition and reinforce economic resilience.

Impact: A key component of the partnership is strengthening co-operation to secure supply chains around critical minerals. This is expected to increase methodologies for supply chain analysis and mapping in shared priority sectors of interest. For businesses using critical minerals in their products, this partnership could be a welcome development.

UK-India trade deal signed

On 24 July, the UK and India signed a trade deal, first announced on 6 May. It aims to create trading opportunities between the countries. The deal strives for job creation as a result of Indian investment, export wins, and liberalised tariffs. Commitments have also been made for closer collaboration in the fields of defence, education, climate, technology and innovation. Alongside cooperating on matters of national security and organised crime.

Impact: Indian businesses could benefit from greater access to UK markets, particularly in competitive sectors such as textiles and food processing. The deal could provide new opportunities in global supply chains. The UK Government states that in the long term the deal is expected to increase bilateral trade by £25.5 billion, UK GDP by £4.8 billion and wages by £2.2 billion each year.

EU-US trade deal

On 27 July, the European Commission and US Administration agreed a new EU-US trade deal.

A 15% US tariff ceiling will apply to nearly all EU exports currently subject to reciprocal tariffs. Where the Most Favoured Nation (MFN) tariff exceeds 15%, the MFN rate will apply.

Strategic EU products like aircraft and aircraft parts, certain chemicals, certain drug generics or natural resources will benefit from reduced tariffs to pre-2025 levels. Pharmaceuticals and semiconductors are temporarily subject to MFN tariffs pending the outcome of US Section 232 investigations. Alcohol tariffs remain unresolved.

The EU plans to spend $750 billion over three years on US LNG, oil, and nuclear energy to replace Russian supplies. It also plans to buy €40 billion in US AI chips to safeguard its technological leadership. EU companies have expressed intentions of $600 billion in additional investment in US sectors by 2029, alongside commitments to purchase US military equipment.

Impact: EU carmakers could benefit from a 15% US tariff cap, down from 25%, boosting supply chain stability. In pharmaceuticals, 15% US tariff may potentially raise costs. This is estimated to be between $13 billion and $19 billion. US tariffs on EU steel and aluminium imports will remain at 50%. Steel, aluminium, and copper sectors could be protected through joint tariff rate quotas and fair competition measures. Non-tariff barriers may be reduced via cooperation on mutual recognition of assessments in various industrial sectors. US agricultural producers gain €7.5 billion in improved EU access, while EU farmers retain protections for sensitive products. Enhanced cooperation on LNG and renewables could strengthen EU energy security.

For more insight on what businesses need to know see our EU–US Trade Deal briefing.

EU mutual recognition agreement with Canada

On 1 August, the EU-Canada AEO Mutual Recognition Agreement (MRA) officially entered into force, aiming to enhance trade security.

The agreement enables mutual recognition of the EU’s Authorised Economic Operator (AEO) and Canada’s Partners in Protection (PIP) programmes. With the intention of streamlining customs procedures for compliant businesses.

Impact: Businesses could benefit from faster customs clearance, and simplified compliance.

Automated data exchange improves supply chain transparency and reduces delays. The agreement may also enhance business continuity during disruptions, allowing priority clearance for certified operators in emergencies.

UK-EU deal to reduce border checks

On 18 August, the UK Government announced the suspension of extra border checks on live animal imports from the EU and specific animal and plant products from Ireland / Northern Ireland.

This comes ahead of a new sanitary and phytosanitary (SPS) deal with the EU (first unveiled at the UK-EU summit in May). It will establish a UK-EU SPS zone and aims to make the trading of food both cheaper and easier. This could strengthen food supply chains.

A risk-based approach is being adopted to manage biosecurity and the position will be reviewable.

This suspension follows from the announcement in June that checks on medium risk fruit and vegetables from the EU would not be brought into force in July 2025 but suspended until end of January 2027.

Impact: The precise terms of the SPS agreement are still to be finalised. Businesses involved in food and agricultural supply could ultimately benefit from reduced costs.

US-Japan trade agreement implemented

On 5 September President Trump signed an Executive Order implementing a US-Japan trade framework. It confirms that a 15% tariff rate will apply to most imported Japanese goods. Where higher rate tariffs already apply they will continue to apply, with some sector-specific exceptions including for automotive and aerospace sectors. The order also makes generic pharmaceuticals, including ingredients and chemical precursors eligible for zero rate tariffs. Also detailed in the Executive Order are commitments made by Japan to invest $550 billion in critical industries the United States.

Impact: Exemptions to the new baseline tariffs aim to address supply chain vulnerabilities in key industries. Businesses in the automotive sector will benefit from the new baseline rate, as Japanese automobiles and auto-parts were previously subject to 25% tariffs.

Asia

China: First national standard for hazardous chemicals in electrical products

On 22 August, the Ministry of Industry and Information Technology (MIIT) announced a new mandatory national standard. Requirements for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products will be effective 1 August 2027. The standard restricts four heavy metals (lead, mercury, cadmium, hexavalent chromium) and six persistent organic pollutants (including polybrominated biphenyls, diphenyl ethers, and four phthalates). Requirements cover labelling, disclosure, and traceability of hazardous substances.

MIIT’s stated aims include promotion of green supply chains, consumer health protection and encouraging digital labelling. The standard will form part of China’s broader Restriction of Hazardous Substances framework and aims to align with international standards.

Impact: Businesses that manufacture, import, or sell electrical and electronic products in China should take advantage of the transition period until August 2027. They may consider reviewing supply chains to ensure compliant materials, substance testing, and maintenance of detailed technical documentation. Failure to comply may result in exclusion from the market.

China: New guidelines for strengthening financial support for industrialization issued

On 5 August 2025, the People’s Bank of China and six other authorities published guidelines to strengthen financial support for new industrialization. The stated aim is to establish a financial system tailored to support the development of the advanced manufacturing sector by 2027. Support measures focus on industry innovation, developing modern industry systems, balanced regional growth, and improving financial institutions. The guidelines call for optimized financial tools to support emerging industries such as connected vehicles, semiconductors and advanced manufacturing. Upgrading of traditional industries, and financing of supply chains is also addressed.

Impact: The guidelines are intended to encourage and accelerate investment. Critical and emerging industries may benefit from strengthened measures to support supply chains. Businesses in traditional industries may be able to access increased financial support to develop their strategies in digitalization and sustainable operations.

China: Battery technology export restrictions amended

On 15 July, the Ministry of Commerce and Ministry of Technology (MOFCOM) updated the Catalogue of Technologies Subject to Export Prohibitions and Restrictions. Now included are key technologies related to:

• battery cathode materials, including lithium iron phosphate (LFP)
• lithium extraction and processing
• non-ferrous metal smelting and rolling technologies, including gallium extraction technologies

These technologies are critical to the clean energy, electric vehicle (EV), and semiconductor industries. LFP cathode materials technology is central to the production of cost-effective and high-performance EV batteries. Gallium extraction technologies are used to produce a critical material used in semiconductors.

MOFCOM’s stated aim is to balance technological development of technologies used in sensitive sectors with national economic security.

Impact: Since 15 July 2025, manufacturers exporting these technologies are required to obtain a government licence. Businesses that engage in joint ventures, licensing, or technical services agreements may also require licences. There are several steps to gaining approval for exporting restricted technologies, with applications potentially subject to multiple reviews.

Europe

EU: Safety of products online – first sweep to check compliance

On 18 July, EU Consumer Safety Network published the results of its first product safety sweep under the General Product Safety Regulation (GPSR). This focussed on childcare articles (such as baby carriers, bottles, soothers and highchairs). It covered online marketplaces’ compliance with obligations under the GPSR. It focussed on the very large online platforms (under the Digital Services Act) in addition to smaller providers and assessed them against the criteria of:

• display of minimum product safety information and traceability
• enforcement activities of the market surveillance authorities
• registration with the Safety Gate Portal

Impact: As these sweeps commence, now could be a good time for businesses to check compliance with the requirements of the GPSR. Any supply chain issues identified with third party suppliers could help avoid potential regulatory action and reputational damage.

EU: Strategies for stockpiling and medical countermeasures

On 9 July 2025, the European Commission unveiled its first-ever EU strategies for stockpiling and medical countermeasures. The plan calls for building and coordinating reserves of essential items for crises like pandemics, natural disasters, or military threats. It includes doubling funding for the Health Emergency Preparedness and Response Authority (HERA) to €200 million by 2027 and creating a Medical Countermeasures Accelerator.

Impact: This strategy could prompt businesses to reassess supply chain resilience and inventory management. Demand for medical and safety supplies may raise. Businesses working in logistics and warehousing could see demand rise for specialist storage and distribution. Collaboration between civil and defence sectors may open new procurement avenues. UK

EU: 18^th package of sanctions against Russia adopted

On 18 July, the EU adopted its 18th package of sanctions against Russia. It expands restrictions on finance, energy, and trade in advanced military and industrial goods. New measures aim to prevent circumvention via third countries, introducing a ‘catch-all’ authorisation for certain exports if they might end up in Russia. Bans on “Economically Critical Goods” used in construction and transport are extended, and new designations include third-country entities involved in supplying military goods to Russia. Similar restrictions now apply to Belarus, with additional sanctions designations targeting its military sector. These changes are designed to disrupt Russia’s military-industrial complex and increase the overall effectiveness of EU sanctions.

Impact: It is anticipated that there will be an increasing focus on ensuring the effectiveness of the sanctions imposed against Russia, and therefore greater emphasis on extraterritorial measures. Accordingly, businesses will need to be even more mindful of potential stakeholder risks, and step up compliance measures across all stages of the supply chain. Businesses should also look out for the 19^th package of sanctions – its presentation is currently delayed due to negotiations between EU Member States as to how be to respond to the Trump administration’s demand that the EU be more proactive in depriving Russia of energy revenues.

For a more detailed overview of the 18^th package, please see our briefing here.

EU: Updates to EU Dual-Use Export Control List

On 8 September, the European Commission announced updates to the EU Dual-Use List (as set out in Annex I of Regulation 2021/821).

The 2025 amendments include a number of new entries to the EU Dual-Use List, including:

• quantum technology (including quantum computers, cryogenic components, parametric signal amplifiers, cryogenic cooling systems and cryogenic wafer probes)
• semiconductor equipment (including manufacturing, testing equipment and materials)
• advanced computing components
• high-temperature application coatings
• peptide synthesisers (that are automated and capable of generating peptides at a system synthesis scale of 1mmol or greater)

The new controls will enter into force following the usual two-month scrutiny period for the European Council and European Parliament, allowing stakeholders to assess the impact and prepare for compliance.

Impact: Exporters across the EU should review the updated list to determine whether their products now fall under the revised controls. This is particularly relevant for companies operating in quantum computing, semiconductor manufacturing and biotechnology fields. It is important to emphasize that some of the new control entries represent unilateral controls by the EU on items, including certain semiconductor manufacturing equipment, which are not currently subject to UK export controls. This misalignment may reflect a broader shift away from streamlining controls across jurisdictions to unilateral and protectionist measures impacting emerging technologies. For businesses trading globally and impacted by these new entries, it will be important to identify the differences between the relevant control lists and to obtain appropriate licences to continue cross-border trade.

EU: New guidance on “best efforts obligations”

In August, the EU Sanctions Helpdesk published an article, ‘The “Best Efforts” Rule under sanctions targeting Russia and Belarus’, providing new guidance on the obligation that EU parents to undertake ‘best efforts’ to ensure that its non-EU subsidiaries do not undermine EU sanctions targeting Russia and Belarus. This requirement was introduced in June 2024.

Importantly, it encourages EU parents to apply the ‘best efforts’ obligation to all EU sanctions, even if the legal requirement only applies to EU sanctions on Russia and Belarus. It also clarifies:

• the act of ‘undermining’ sanctions refers to actions that weaken the effectiveness of sanctions without (in)directly violating them, which is different to a breach or circumvention of sanctions
• ‘best efforts’ involves a higher standard than ‘reasonable efforts’, and comprises all actions that are necessary and feasible in the context of the particular situation and business.

Impact: Businesses should review this guidance carefully to understand its obligations under EU law. Businesses are encouraged to plan ahead – the ‘best efforts’ obligation may only apply to EU sanctions on Russia and Belarus, but sanctions compliance programmes should prepare for the event that this is extended to all EU sanctions.

EU: New import rules apply from 1st September 2025

As of 1st September 2025, the Import Control System 2 (ICS2) is fully deployed across all transport modes, including road and rail. ICS2 is the EU system for collecting cargo details on all goods entering or passing through its borders.

ICS2 demands detailed cargo data before arrival, replacing the former system to improve risk analysis and border security. Timely and accurate Entry Summary Declarations (ENS) are now mandatory. Some Member States and Northern Ireland requested temporary derogations to ease transition for small businesses.

Impact: All businesses shipping in and through the EU must comply with the new rules. Inaccurate data may trigger shipment holds, investigation and potential fines.

UK

UK: Proposals to address late payment culture

On 30 July, the UK Government announced the Small Business Plan, with a focus on a package of proposals aimed at tackling late payment culture, in particular for SME suppliers.

Key proposals include:

• limiting payment terms to 60 days, with the possibility of reducing this to 45 days after 5 years
• a 30-day invoice verification period, so that invoices cannot be disputed once this has expired
• statutory interest on late payment mandatory, removing the ability for parties to use a lower interest rate and making the interest payment automatic
• reporting requirements on statutory interest both owed and paid, in order to aid transparency
• financial penalties to businesses that persistently pay their suppliers late
• investigations into poor payment practices, including acting as arbitrator in disputes and imposing arbitration awards
• enhance scrutiny of large companies’ payment practices at audit committee and board level

A consultation on these proposals closes on 23 October 2025.

Impact: If implemented the proposals would supplement the voluntary Fair Payment Code. They could impact all businesses, but particularly large businesses within scope of the payment practices reporting regime. Businesses should review these proposals and consider the impact that the proposed reforms would have on their payment practices and contract terms.

UK: Report on inquiry into forced labour in international supply chains published

On 24 July, the UK Joint Committee on Human Rights published its report on its inquiry into forced labour in international supply chains.

The purpose of the inquiry was to consider the UK legal and voluntary framework. It aimed to check its effectiveness in managing the risks of exposure to forced labour in the UK market.

Key findings and recommendations include:

• goods that are produced or part-produced using forced labour are being sold in the UK
• the UK is falling behind international partners in its approach to forced labour in supply chains
• the reporting duty in Section 54 of the Modern Slavery Act 2015 should be strengthened
• there is a willingness in the UK business sector to implement mandatory human rights due diligence; to do so would create a level playing field without putting responsible businesses at a disadvantage
• new legislation is needed to establish
• whilst the UK includes provisions on human rights and labour rights in some of its international agreements, there is no official policy on approach to this and no mechanisms to assess the impact of these clauses, and this should be addressed
• the green energy transition creates specific risks of forced labour in supply chains because of the reliance on critical minerals and polysilicon

Impact: The inquiry will help inform the Government’s review of measures to tackle forced labour and increase transparency in global supply chains. This was promised in the December 2024 response to the House of Lords Modern Slavery Act 2015 Committee report. The Government now has two months to respond to the report. It is unclear whether it will commit to take legislative action in this area, and if it is likely to see a shift towards mandatory human rights due diligence.

UK: Product Regulation and Metrology Act 2025

On 21 July, the Product Regulation and Metrology Bill received Royal Assent, becoming the Product Regulation and Metrology Act 2025 (PRM Act). It aims to create a framework that gives the Secretary of State powers to make regulations to reduce or mitigate risks posed by products. This includes holding online marketplaces to account for unsafe products sold via their platforms. Certain categories of product are excluded from the scope of the PRM Act, including food, plants, animal by-products and products of animal origin, aircraft and their components, military equipment and medicines and medical devices.

The Government has announced its intention to use the PRM Act to introduce new requirements on online marketplaces to:

• prevent unsafe products being made available to consumers
• ensure that their sellers comply with product safety laws
• provide consumers with relevant product information
• cooperate with regulators

Impact: The actions of manufacturers, importers and distributors along a supply chain could come under increased regulatory scrutiny. The UK Government has indicated that they are prepared to enact further legislation as global supply chains get more complex and interconnected.

UK: Tax implications for umbrella companies

On 21 July, the UK Government announced draft legislation forming part of the draft Finance Bill, amending Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003). It aims to make recruitment agencies accountable for Pay As You Earn (PAYE) on payments made on or after 6 April 2026 to workers supplied through umbrella companies (or the end client, where there is no agency).

The legislation aims to make the agency and umbrella company jointly and severally liable. Allowing HMRC to pursue either or both. If there is more than one agency in the supply chain, the rules will apply to the agency that has the direct contract with the end client to supply the worker.

Impact: Businesses should ensure their supply chain documentation and due diligence meet UFLPA compliance. Transparent supply chain documentation, meeting all import requirements, should help mitigate enforcement risks and subsequent reputational damage.

For more insight on the draft legislation, see our briefing.

GB/Northern Ireland: New powers to impose ‘not for EU’ labelling on goods on the GB market

On 1 July, the Marking of Retail Goods Regulations 2025 came into force. The Northern Ireland Retail Movement Scheme (Scheme) makes it easier to move goods from Great Britain (GB) to Northern Ireland (NI). In order to come within scope of the scheme, goods have to be individually labelled as “not for EU”.

These new regulations are intended to stop businesses from pulling out of the NI market because of these labelling requirements. Empowering the Secretary of State for Environment, Food & Rural Affairs to introduce ‘not for EU’ labelling for specified categories of retail goods that are placed on the GB market. In other words, the labelling requirements become the same for those goods in both the NI and GB markets. This can only happen if there is evidence that the supply of a retail good is, or is likely to be, seriously adversely affected by relevant business operators withdrawing from the NI market because of the ‘not for EU’ labelling requirements under the Scheme.

Impact: These regulations will impact all businesses selling retail goods in GB and/or NI. These businesses could see supply chain disruption, but the Secretary of State has stated that the risks will be monitored.

UK: Office of Trade Sanctions Implementation publishes guidance on sanctions circumvention

On 4 August, the Office of Trade Sanctions Implementation (OTSI) published ‘Countering Russian sanctions evasion – guidance for businesses’, which aims to support UK businesses in identifying export control and sanctions circumvention practices. The guidance sets out key circumvention data, including a list of goods that are seen to be at a generally greater risk of being diverted and re-exported to Russia, and a list of third-countries where entities continue to sell sensitive goods to Russia. It also identifies a number of potential red flag indicators of export control and sanctions evasion.

The guidance also shares best practice in relation to due diligence. This is split into four categories: product, customer, transaction, and export destination.

Impact: Businesses are responsible for determining its specific sanctions risk exposure and implementing an appropriate set of safeguards and controls to mitigate such risk. These safeguards and controls, especially relating to due diligence practices, should be informed by the suggestions set out in this guidance to protect against emerging methods of circumvention.

UK: New sanctions targeting Russia’s oil fleet

On 12 September, the UK launched a new round of sanctions that target 70 ships transporting Russian oil, as well as 30 entities and individuals identified to be supplying the Russian military with equipment used in weapon systems. The UK Government states this is in response to Russian air strikes violating NATO airspace in Poland. Impact: Businesses should continue to review the lists of sanctioned entities and individuals and manage dealings accordingly to ensure compliance with all UK sanctions on Russia.

US

US: New tariffs on copper imports announced

On 30 July, the US Administration announced increased tariffs of 50% on imported copper products. The increased rate applies from 1 August 2025. It applies to semi-finished copper products, including copper pipes, wires, rods and sheets. It also applies to copper-intensive derivative goods, such as cables and electrical components. The new rate does not apply to raw forms of copper, anode and cathode material or copper scrap.

The proclamation also directs the Secretary of Commerce to take steps to boost the US domestic copper industry. This includes a requirement that 25% of high-quality copper scrap produced in the US must be sold in the US. Additionally, from 2027 25% of copper input materials produced in the US will be required to be sold domestically. The requirement will rise to 30% in 2028 and 40% in 2029. Copper input materials include products such as copper ores, concentrates, mattes, cathodes, and anodes.

Impact: Businesses importing affected copper products may experience price increases and disruption to their supply chains. Electric vehicle manufacturers, defence, electronics and AI industries could be particularly affected. The housebuilding sector may also be impacted, with potential increased construction costs.

US: Draft Ensuring Safe and Toxic-Free Foods Act of 2025

On 17 July, a Senate bill was introduced which aims to end the Generally Recognized as Safe (GRAS) self-affirming pathway for food substances. It would require Food and Drug Administration (FDA) review for all GRAS determinations, including food ingredients, packaging and contact materials.

If enacted it would introduce public posting of GRAS notices and a 60-day comment period. It would also expand the FDA’s Food Chemical Reassessment Program. This would introduce reassessment of 10 substances every three years. Substances relying solely on industry self-GRAS determinations would be considered unsafe two years after enactment.

Impact: Businesses involved in food manufacture, packaging and contact materials may want to proactively assess their processes and supply chains. Businesses could expect increased scrutiny and reassessment of ingredients. Several large food and beverage companies have recently announced reformulation of popular products, particularly in relation to synthetic dyes.

US: Export Control Transparency Act becomes law

On 19 August 2025, the Maintaining American Superiority by Improving Export Control Transparency Act was signed into law. The new law aims to increase transparency in the US Department of Commerce export control system. The Department must now provide Congress with annual reports on all export license requests to covered entities.

In addition to aggregated statistics, the report must contain information on all license applications, including:

• the name of the entity submitting the application
• a brief description of the item (including the Export Control Classification Number (ECCN) and reason for control, if applicable)
• the name and location of the end-user
• a value estimate
• decision with respect to the license application or authorization
• the date of submission
• the date, location, and result of any end-use checks

Impact: Affected businesses may face increased scrutiny of their due diligence processes, including historic license applications. Significant penalties may apply if businesses are found to be in breach of export control rules. US businesses may consider reviewing their compliance practices, specifically those relating to end-user and end-use verification.

US: 407 product categories added to steel and aluminium tariffs

On August 19, the Department of Commerce announced an additional list of products to be covered by tariffs. The steel and aluminium content of these products will now be subject to a 50% duty rate. Among the 407 additional product categories now included are:

• wind turbines and their parts and components
• mobile cranes
• bulldozers and other heavy equipment
• railcars
• furniture
• compressors and pumps

The affected product list now encompasses industrial and chemical products, as well as consumer and personal care goods. There are three annual periods for public steel and aluminium product inclusion requests. The next opportunity opens in September and will be announced in the Federal Register.

Impact: Businesses should review the full list of affected product categories, and evaluate their sourcing strategies and pricing models if required. Importers will need to comply with new requirements, including verifying the origin and processing of affected products. Businesses may also consider preparing submissions for any products they believe should be excluded in the next inclusions request window.

US: Updated forced labour in China strategy

On August 19, the Forced Labor Enforcement Task Force of the Department of Homeland Security and other agencies, announced a new strategy to strengthen enforcement of the Uyghur Forced Labor Prevention Act (UFLPA). This is aimed at preventing goods made with forced labour in China from entering the domestic market.

The new strategy adds five new high-risk sectors:

• caustic soda
• jujubes
• copper
• lithium
• steel

The UFLPA Entity List now includes 144 banned entities. The update strengthens Customs and Border Protection’s ability to detect and stop such imports. It also aims to help domestic businesses reduce reputational and regulatory risks in their supply chains.

Impact: Businesses should ensure their supply chain documentation and due diligence meet UFLPA requirements. Transparent supply chain documentation could help prevent enforcement risks and any ensuing reputational damage.

Further reading

Global Sustainability & ESG Insights – July 2025 | Eversheds Sutherland

EU–US Trade Deal: What Businesses Need to Know | Eversheds Sutherland

EU Publishes 18th Package of Sanctions Against Russia and Belarus | Eversheds Sutherland

Tariffs and Trade Webinar: Key Highlights | Eversheds Sutherland

UK: Property (Digital Assets etc) Bill set to become law | Eversheds Sutherland

*Knowledge

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