Global Supply Chain Horizons – January 2026

In our latest update we highlight key areas of change that have happened over the last quarter. These include:

• Cross-Border – UK-US pharmaceuticals deal; US-China trade deal; China-ASEAN upgraded trade agreement; US trade deals with Southeast Asian countries; EU–Indonesia trade agreement
• Asia – China: Improving the reliability and security of domestically produced automotive chips; China: Some rare earth export controls eased; China: 15th Five-Year Plan; China: Aligning export controls on electric passenger vehicles with those on conventional vehicles; China: MOFCOM seeks public comments on revised draft Foreign Trade Law
• Europe – GPSR guidance published; ECHA recommends four substances for REACH authorization; Safeguard measures on ferroalloy imports; Critical Chemicals Alliance launched; EU adopts 19th sanctions package against Russia; Council agrees Russian gas phase-out Regulation; New tool for Mineral Supply Chain Transparency launched; Strategic projects to boost raw materials security
• UK – Critical minerals strategy; Cyber Security and Resilience (Network and Information Systems) Bill published; Tackling modern slavery in NHS supply chains; Cabinet Offices issues Anti-slavery Risk Tiering Tool; Government considers stronger measures on forced labor in supply chains; UK imposes a new wave of sanctions against Russia
• US – Amended Biosecure Act advances; Federal hemp ban to take effect in 2026; Proposed change to PFAS reporting for business; Expanded critical minerals list; Tariffs on heavy truck imports; New tariffs on specific wood products

Cross-Border

UK-US pharmaceuticals deal

On December 1, the UK Government announced a deal to secure a zero percent tariff on pharmaceuticals exports to the US. The deal guarantees zero tariffs on UK pharmaceutical exports to the US for at least three years. In return the government will increase the National Institute for Health and Care Excellence (NICE) cost-effectiveness threshold by 25% for new US drugs. It will also cut the cap on revenue the National Health Service (NHS) can reclaim from pharmaceutical businesses to no more than 15%.

Impact: Pharmaceutical businesses could benefit from early launches due to tariff-free exports and improved pricing frameworks. Investment in UK-based research and manufacturing could benefit from government incentives. This could boost the UK's role in global pharmaceutical supply chains. US businesses could benefit from higher NHS spending and revised NICE thresholds.

EU: Clean trade and investment partnership with South Africa

On November 20, the EU and South Africa signed the first Clean Trade and Investment Partnership. The initiative strengthens clean supply chains in renewable energy, clean fuels, raw materials, and technologies.

The Memorandum of Understanding on minerals and metals value chains aims to develop joint industrial projects across extraction, refining, and recycling. Under Global Gateway, nearly €12 billion will fund green hydrogen, e-batteries, and critical raw materials projects. The partnership seeks to create jobs, diversify supply chains, and accelerate the clean transition while reinforcing EU-South Africa ties.

Impact: Energy and raw materials industries may benefit from increased investment in renewable energy, green hydrogen, and critical minerals projects. Transport and logistics may gain from infrastructure modernization supported by European Investment Bank loans. Manufacturing and recycling may see growth through joint industrial projects on metals value chains. Healthcare may benefit from expanded vaccine production and improved supply chains for medical technologies.

US-China trade deal

On November 1, the US Administration released a fact sheet outlining a deal struck between the US and China on their economic and trade relations. It sets out China’s commitments to halt the exports of fentanyl precursors, lift certain rare earth export controls, and resume purchases of soybeans and other agricultural goods of the US. According to the US, China will also suspend or remove retaliatory tariffs and non-tariff countermeasures taken against the US since March 4, 2025. In return, the US will (among others) lower “fentanyl” related tariffs, extend certain tariff exclusions, and suspend the implementation of the BIS’s “Affiliates Rule” for one year.

China issued corresponding announcements setting out the relaxation and/or suspension of certain of its measures relating to tariffs and export controls. 

Impact: Businesses should use the truce period to evaluate the potential implications of these currently removed or suspended trade controls on their key operations and third party relationships. They may want to take pre-emptive steps to ensure supply chain resilience and business continuity in the event of any of these controls being reinstated.

China-ASEAN upgraded trade agreement

On October 28, China announced that it had signed an upgraded free trade agreement with the Association of Southeast Asian Nations (ASEAN). The agreement seeks to broaden cooperation in the areas of digital economy, green economy, supply chain connectivity, and competition and consumer protection, as well as in existing fields of cooperation such as customs procedures and trade facilitation. The agreement follows negotiations that began in November 2022 and concluded in May 2025.

Impact: The agreement aims to reduce trade barriers between China and ASEAN countries, strengthen supply chain connectivity, encourage industrial development, and unlock opportunities in emerging sectors. Thereby supporting regional resilience amid tariff-related disruptions and other uncertainties in global trade.

US trade deals with Southeast Asian countries

On October 26, the US Administration announced agreements with Malaysia, Thailand, Cambodia, and Vietnam, respectively, on reciprocal trade, including agreements with Malaysia and Thailand, respectively, which are aimed at diversifying supply chains concerning critical minerals and promoting investments. The deals include tariff reductions, commitments to reduce trade barriers, and enhanced market access for US goods. For example, according to the US’s announcement:

• Malaysia has committed to refrain from banning or imposing quotas on exports of critical minerals or rare earth elements to the US;

• Thailand has agreed to eliminate tariffs on approximately 99% of US industrial goods and agricultural products, and to relax foreign ownership restrictions for US investment in the telecommunications sector; and

• Vietnam plans to increase US purchases to address its trade surplus, including providing preferential market access for substantially all US industrial and agricultural exports to Vietnam.

The agreements also include provisions promoting digital trade, labor rights, and environmental protection.

Impact: US businesses could benefit as the administration seeks to broaden and secure the supply of key components from these partnering countries. Suppliers of these materials in Southeast Asia may also benefit from greater access to US markets.

EU: Cross-Regional Connectivity Agenda launched

On October 20, the EU convened ministers from Europe, the South Caucasus, and Central Asia to launch the Cross-Regional Connectivity Agenda. The initiative aims to strengthen transport, energy, digital, and trade links across regions, promoting resilience and sustainable development. The agenda prioritizes the Trans-Caspian Transport Corridor (TCTC), renewable energy deployment, and digital innovation.

Impact: Businesses could benefit from improved transport, energy, and digital infrastructure under the Cross-Regional Connectivity Agenda. Trade facilitation may reduce costs and increase market access. Logistics and supply chains could be affected by the development of TCTC. Businesses may need to adapt operations to new transport routes and renewable energy priorities.

EU-Ukraine: New agri-food trade initiative

On October 13, the Council of the EU agreed to reduce or eliminate customs duties on selected Ukrainian agri-food products. This decision supports the EU-Ukraine Deep and Comprehensive Free Trade Area review, aiming for a stable, reciprocal trade framework. Market access will depend on Ukraine aligning with EU standards on animal welfare, pesticides, and veterinary medicines. Sensitive EU sectors are protected by safeguard mechanisms and gradual liberalization for products like sugar and poultry. Full liberalization is reserved for non-sensitive items such as milk and dairy products.

Impact: European businesses may benefit from expanded access to Ukrainian agri-food products, potentially lowering input costs and diversifying supply chains. Gradual liberalization and safeguard mechanisms help mitigate risks for EU producers, maintaining market stability. The EU-Ukraine Association Committee will formalize the decision.

EU–Indonesia trade agreement signed

On September 23, the EU and Indonesia finalized the Comprehensive Economic Partnership Agreement (CEPA), concluding nearly a decade of negotiations. The agreement plans to eliminate tariffs on approximately 80% of Indonesian exports to the EU, including palm oil, footwear, textiles, and fisheries.

Impact: The deal is expected to be implemented by 2027. It includes provisions to strengthen supply chains for critical raw materials and incorporates commitments on environmental and labor standards.

Asia

China: Improving the reliability and security of domestically produced automotive chips

Based on an article shared by the State Administration for Market Regulation on November 20, the Chinese authorities acknowledge the importance of coordinated standards, certification and industry collaboration in enhancing the quality control and reliability of domestically produced automotive chips. With an aim of increasing their global competitiveness, and reducing reliance on imported products in the automative sector. This forms part of government backed initiatives for domestically sourced chips in vehicles.

Impact: Domestic automakers could benefit from shorter research and development cycles, driven by anticipated governmental and regulatory support. A transition to domestically produced chips could reshape automotive electronics supply chains, enabling Chinese automakers to reduce reliance on foreign suppliers and mitigate the impact of global trade tensions on their operations.

China: Some rare earth export controls eased

On October 9, the Ministry of Commerce introduced a range of rare earth export measures, including expanded export controls on rare earth items and equipment, tightened restrictions on rare earth-related technologies, limitations on re-exports, transfers, and end-uses of specific rare earth items, and export controls on lithium batteries and superhard materials.

On November 7, the Ministry of Commerce announced an immediate suspension of the abovementioned measures, until November 10, 2026.

On November 9, the Ministry of Commerce also announced an immediate suspension of certain US-specific export controls introduced in December 2024, including a ban on exports of dual-use items related to gallium, germanium, antimony and superhard materials, and stricter end-user and end-use reviews as regards exports of dual-use items related to graphite. The suspension is in effect until November 27, 2026.

Based on the announcements to date, it appears that export controls on specific medium and heavy rare earth materials announced in April 2025 remain in place.

Impact: The announced suspensions come in the wake of an easing of US-China trade tensions and the agreement to lower tariffs. Any development that helps alleviate potential supply chain strains would be welcome news for businesses. However, delays and shortages may persist pending further clarity on certain rare earth export controls. Businesses relying on Chinese rare earth should, if not already, assess the potential implications of these controls on their operations, and develop alternative sourcing plans if needed.

China: 15th Five-Year Plan

On October 23, the Central Committee of the Communist Party of China passed its official recommendations for the 15th Five-Year Plan for National Economic and Social Development (the Plan). The Plan underscores green industrial development as central to its modernization strategy. It commits to achieving peak carbon emissions by 2030 and accelerating the transition to a clean, low-carbon, safe, and efficient new energy system. Industrial policy emphasizes upgrading traditional sectors through digital, smart, and green manufacturing, while enhancing the national infrastructure system and sector competitiveness.

Impact: The Plan continues to reflect the national policy of promoting greater self-reliance and industrial upgrading, particularly in strategic emerging sectors such as new energy, new materials, aviation and aerospace, and the low-altitude economy. Export controls and security reviews aligned to these policy objectives are expected to be introduced or strengthened. The Plan is expected to be formally released and implemented in March 2026.

China: Aligning export controls on electric passenger vehicles with those on conventional vehicles

On September 26, the Ministry of Commerce, the State Administration for Market Regulation, the Ministry of Industry and Information Technology and the General Administration of Customs jointly announced that effective from January 2026, the export of purely electric motor-powered passenger vehicles from China will require a license. The new rules align the requirements for electric cars with those for conventional cars and motorcycles introduced in 2012.

Impact:  Businesses engaged in the export of EVs out of China should ensure compliance with the new export controls, and prepare for scrutiny of relevant license applications.

China: MOFCOM seeks public comments on revised draft Foreign Trade Law

On September 12, the Standing Committee of the National People’s Congress issued a notice seeking comments from the public on a revised draft of the Foreign Trade Law. The consultation period ended on October 11.

Key proposed amendments include:

• authorizing the implementation of any necessary measures concerning (i) imports and exports of goods and technology and (ii) international trade in services, on broader grounds including in response to ‘emergency situations arising from international relations’;

• where any foreign entities or individuals are determined to jeopardize China’s national security, violate conventional market trading principles, or implement discriminatory measures against Chinese entities and persons, authorizing the State Council to prohibit or restrict their involvement in foreign trade activities with China. Any acts of facilitation to evade the above prohibitions or restrictions will also be prohibited;

• establishing a negative list for managing cross-border trade in services;

• establishing China’s trade policy compliance mechanism and aligning it with international standards;

• establishing a trade adjustment assistance system to stabilize industrial and supply chains; and

• promoting digital trade and establishing a green trade system.

Impact: The draft underscores China’s intention to expand trade controls in line with international practices, to safeguard national interests with the use of export controls and other trade measures on broader legal grounds. Should these draft amendments take effect, more specific trade controls may be introduced.

Europe

EU: GPSR guidance published

On November 21, the European Commission published guidelines on the application of the EU General Product Safety Regulation (GPSR) for businesses. It also published guidelines for the practical implementation of the Safety Business Gateway.

The GPSR sets out product safety requirements for manufacturers, authorized representatives, importers, distributors, fulfilment service providers, online market places and persons responsible for putting products on the EU market. It aims to ensure that only safe products are made available. The guidelines contain a risk analysis template that can be used before placing a product on the market.

The Safety Business Gateway is a portal for informing market surveillance authorities about unsafe products and accidents. Under the GPSR such reporting is mandatory.

Impact: The guidelines set out which businesses and which products are within scope of the GPSR. They list the responsibilities of each party within supply chains. Businesses that are subject to the GPSR should review this guidance to aid their compliance with the GPSR regime.

EU: ECHA recommends four substances for REACH authorization

On 18 November, the European Chemicals Agency advised adding four substances to the REACH Authorization List. The recommendation aims to protect health and the environment by requiring companies to seek authorization for continued use. Selected from the Candidate List of substances of very high concern, these chemicals pose significant risks requiring regulatory oversight.

The European Commission will decide on inclusion and conditions.

Impact: Businesses may need to apply for authorization, which can be time-consuming and resource-intensive. This may lead to supply chain adjustments and potential substitution with safer alternatives.

EU: Safeguard measures on ferroalloy imports

On November 18, the European Commission imposed definitive safeguard measures on certain ferroalloy imports to protect EU industry. Measures include country-specific tariff rate quotas per alloy type, limiting duty-free volumes and applying duties below price thresholds. The annual tariff-rate quota is split into four three-month periods, starting each year on November 18. Countries exceeding 5% of imports for a product type over three years receive dedicated quotas, following the steel safeguard model. Other origins access remaining quotas on a first-come basis, determined by the order customs declarations for free circulation are accepted. They apply to all third countries, including Norway and Iceland, while aiming to minimize disruption to integrated EU supply chains.

Impact: Ferroalloys are vital for steel production, supporting sectors like construction, automotive, aerospace, and defense. Businesses involved in importing, trading, or using ferroalloys should evaluate how the new safeguard measures affect sourcing plans and supply stability. EU importers of covered products should verify the goods’ non-preferential origin and calculate the impact of safeguard tariffs on overall costs. Existing contracts, delivery timelines, and customs procedures may require adjustments to remain compliant and mitigate potential disruptions. The measures will last until November 2028.

EU: High-Speed Rail Action Plan to boost cross-border connectivity

On November 5, the European Commission (EC) adopted a High-Speed Rail Action Plan to accelerate rail connectivity across Europe. It sets binding timelines by 2027 to remove cross-border bottlenecks and explore speeds above 250 km/h where viable. It aims to improve conditions for rail operators via better regulation, digital systems, cross-border ticketing, and support for innovation and second-hand rolling stock. EU-level governance should be strengthened by requiring infrastructure managers to coordinate long-distance services and facilitate standardization and authorization.

Impact: Improved cross-border connectivity may enhance supply chain efficiency and regional logistics. Businesses in rail infrastructure, technology, and services may see new investment and partnership opportunities.

EU: Critical Chemicals Alliance launched

On October 28, the European Commission launched the Critical Chemicals Alliance to reinforce Europe’s chemical sector resilience and sustainability. It aims to identify essential chemical productions and molecules for strategic sectors and improve trade monitoring via EU Customs Surveillance. The Alliance seeks to coordinate investments by aligning EU and national funding tools to support key industrial projects.

Impact: Chemical industry stakeholders may sign up to the Alliance. Businesses could benefit from clearer investment signals and coordinated funding for strategic chemical production. Improved trade monitoring may help businesses anticipate supply chain disruptions and adjust sourcing strategies.

EU adopts 19th sanctions package against Russia

On October 23, the EU Council adopted the 19th sanctions package against Russia, focusing on energy, finance, and military sectors, reinforcing energy, financial, and military restrictions. It bans Russian LNG imports from January 2027 and lowers the crude oil price cap to $47.6. Sanctions target refineries and traders in third countries breaching oil restrictions, including entities based in China. Export restrictions apply to battlefield technologies, especially drones, and list 45 companies supporting Russia’s military industry. They also cover advanced tech and metals. AI, space-based, and tourism services to Russia are restricted. Belarus faces mirrored sanctions, including crypto and software bans.

Impact: Businesses should assess supply chain exposure to the new sanctions, especially in energy, finance, maritime, and dual-use goods sectors. Expanded financial sanctions could impact businesses linked to Russian banks and crypto platforms. Export controls on drone-related and battlefield technologies require compliance checks for manufacturers and suppliers. The LNG import ban and lower oil price cap may affect shipping, trading, and insurance operations.

EU publishes 19th sanctions package against Russia and Belarus | Eversheds Sutherland

EU: Anti-dumping duty on Chinese steel track shoes

On October 20, the European Commission imposed a 62.5% anti-dumping duty on steel track shoes from China. Provisional duties had been in place since April 2025. Steel track shoes are used in tracked construction and mining equipment, such as bulldozers and excavators. The affected EU sector is mainly based in Italy.

Impact: Anti-dumping duties may reduce competition from low-priced imports, offering EU producers market stability. Some disruption to existing supply chains for manufacturers of construction and mining equipment could occur.

EU: Council agrees Russian gas phase-out Regulation

On October 20, the Council of the EU agreed its position on phasing out Russian gas imports under the REPowerEU plan, and this was provisionally agreed with representatives from the EU Parliament on December 3. The Regulation introduces a binding ban on pipeline and LNG imports from Russia, effective fully by  January 1, 2028. A transition phase allows short-term contracts until mid-2026 and long-term ones until 2028, with strict amendment limits.

Member states must submit national diversification plans unless they prove no Russian gas imports.

Monitoring mechanisms aim to prevent Russian gas entering via transit routes or indirect means. The Council also clarified suspension clauses and strengthened information exchange and review provisions. Negotiations with the European Parliament will follow to finalize the Regulation.

Impact: Businesses may benefit from simplified customs procedures for non-Russian gas. However, stricter documentation and prior authorization for Russian imports may increase burdens and risk of shipment rejection. Mixed LNG cargos must declare Russian and non-Russian shares, with only non-Russian gas allowed entry, which may complicate logistics. Businesses relying on Russian gas may face supply disruptions and should consider revising contracts or diversifying sources quickly.

EU proposal to reinforce steel industry amid global overcapacity

On October 7, the European Commission proposed new measures to shield the EU steel industry from global overcapacity. The proposal limits tariff-free steel imports to 18.3 million tons annually, a 47% cut from 2024 quotas. Out-of-quota duties will double to 50%, and a melt and pour rule aims to enhance traceability and to prevent circumvention. It aims to support decarbonization, job protection, and fair global trade, responding to industry and stakeholder demands.

It follows the March 2025 Steel and Metals Action Plan and a broad stakeholder consultation.

Impact: European steel producers could benefit from reduced competition from cheaper imports. The new measures aim to counteract low-priced imports and support the sector. They aim to address high energy costs and stricter environmental standards. However, steel users could face increased supply chain disruption. The measure replaces the current safeguard expiring in June 2026 and aligns with WTO rules. It excludes Norway, Iceland, Liechtenstein, and considers Ukraine’s situation in quota allocations.

Next steps include adoption by the Council and Parliament.

EU: New tool for Mineral Supply Chain Transparency launched

On October 2, the European Commission launched Responsible Mineral Information System (ReMIS) to improve transparency in mineral supply chains. ReMIS enables businesses to share due diligence policies and responsible sourcing practices publicly. It supports the EU’s Conflict Minerals Regulation but does not alter legal obligations.

Impact: Participation is voluntary and open to all stakeholders in mineral and metal supply chains. Registered users can upload initiatives, the public can view them via a portal.

EU: Strategic projects to boost raw materials security

On September 25, the European Commission (EC) launched its second call for strategic projects under the Critical Raw Materials Act. It aims to secure sustainable raw material supply for green and digital transitions, building on 60 projects from the first call. Projects must enhance supply security, be technically feasible, and ensure sustainability to qualify for fast-track permitting and financing. The initiative aims to boost domestic production, diversifies supply, and strengthens partnerships with countries outside the EU.

Impact: Businesses supplying raw materials, mining, and recycling sectors may benefit from faster permitting and easier access to EU funding. Strategic project status offers visibility, regulatory support, and potential partnerships across the EU and globally.

The call is open until January 15, 2026.

UK

UK: Critical minerals strategy

On November 22, the UK Government released the policy paper Vision 2035 Critical Minerals Strategy. This aims to secure vital resources for industrial growth sectors. The government anticipates demand for minerals like lithium and copper will surge by 2035. They want to secure domestic production, recycling, and diversified global supply chains. The strategy sets the following targets: 10% of demand met through UK production, 20% through recycling, and no more than 60% reliance on any single country. Key measures include funding up to £50 million for projects, energy cost relief from 2027, streamlined permitting, and international partnerships. The approach supports advanced manufacturing, defense, and clean energy industries.

Impact: If fully implemented the policy could help diversify critical mineral sourcing to reduce reliance on dominant global players. Businesses that align their supply chain strategies with the 2035 diversification target could see the benefits of secure domestic sourcing at a time of increased global tensions.

UK: Cyber Security and Resilience (Network and Information Systems) Bill published

 On  November 12, the Cyber Security and Resilience (Network and Information Systems) Bill had its first reading in the House of Commons. It aims to strengthen the cyber security of essential UK public services, including those in the healthcare, transport, energy, drinking water and digital infrastructure sectors. The Bill plans to amend the Network Information Systems Regulations 2018 (UK NIS).

Planned changes include:

• bringing data centers, large load controllers and managed service providers into scope
• clarifying which cloud computing services are in scope
• enabling regulators to designate persons as critical suppliers to entities subject to UK NIS
• expanding incident reporting duties
• strengthening regulators' enforcement powers and updating provisions relating to costs recovery and information sharing

Impact: If enacted these reforms could have a wide impact. They could bring many businesses, such as IT managed service providers and critical suppliers to essential UK service providers,  within the scope of the UK NIS regime. This could mean that they have to comply with security and incident reporting duties. It could have an onward impact on supply chains, as compliance obligations are reflected in downstream contracts.

Eversheds Sutherland Partners Paula Barrett and Nicolette Sanders shared their insights on the challenges and opportunities presented by this Bill on LinkedIn.

England: Tackling modern slavery in NHS supply chains

The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 will come into force on May 17, 2026. On October 17, (then updated on October 24), NHS England published draft guidance on tackling modern slavery in NHS procurement. It followed the outcome of a consultation.

The regulations will apply to public bodies that procure goods or services for the NHS in England, who will need to:

• carry out a modern slavery risk assessment before advertising a contract or framework if a competitive procedure is used, or before awarding the contract if a competitive procedure is not used
• take reasonable and proportionate steps, throughout the procurement and contract lifecycle, to address and, where practical, eliminate any risks that are identified
• regularly reassess the extent of the risk when managing a framework or dynamic market

Impact: All in-scope public bodies should use the next six month period to prepare for the new regime coming into force. They should use the guidance to ensure their supply chains meet all requirements to tackle modern slavery.

UK: Cabinet Offices issues Anti-slavery Risk Tiering Tool

On October 16, the Cabinet Office updated its Anti-slavery Risk Tiering Tool and associated guidance (previously the Modern Slavey Risk Assessment Tool). These are fully aligned with Procurement Policy Note 009, on tackling modern slavery in government supply chains. The tool is intended to assist contracting authorities in making high-level modern slavery risk assessments for procurements and contracts.

It is a separate tool to the Modern Slavery Assessment Tool which is designed for use by public sector organizations working with existing suppliers.

Impact: Contracting authorities should use the tool to help make sure their supply chain operations remain free of modern slavery.

UK: Government considers stronger measures on forced labor in supply chains

On October 16, the Government’s response to the Joint Committee on Human Rights’ report on forced labor in UK supply chains outlined ongoing and planned actions. The Government is reviewing its approach to responsible business conduct, considering new legislation, mandatory human rights due diligence, and potential import bans on goods linked to forced labor. Coordination across departments is being strengthened, and reforms to the Modern Slavery Act 2015 are under consideration. The response also addresses procurement, trade agreements, critical minerals, and ethical supply chains in sectors like energy and solar.

Impact: The Government says it’s committed to further stakeholder engagement. Businesses should engage with the process to ensure any challenges to their supply chains are taken into consideration with this developing policy.

UK imposes a new wave of sanctions against Russia

On  October 15, the UK announced sanctions measures on a range of individuals and entities active in the Russian energy sector (including Rosneft, Lukoil, as well as Indian and Chinese refineries). Some of the designations also encompass persons operating in the Russian defense and financial sectors. Furthermore, the UK Government targeted a number of vessels involved in transporting Russian oil and gas, ultimately targeting 90 individuals, entities and vessels in total.

Impact: Businesses should assess supply chain exposure to the new sanctions, especially in energy, finance, maritime, and dual-use goods sectors. Additionally, the UK is now actively exercising its “secondary sanctions” powers against third-country entities and accordingly there is likely to be a heightened risk of secondary sanctions for third-country businesses who are active in the energy, defense and financial institutions sectors, and have exposure to Russia and/or designated parties. The UK has also indicated it will follow in the EU’s footsteps in banning imports of oil products refined in third countries from Russian-origin crude oil, though further detail in relation to this ban is awaited.

US

US: Amended Biosecure Act advances in Senate

On December 10, the House of Representatives passed the National Defense Authorization Act 2026, which includes a new version of the Biosecure Act. The Act restricts federal funding for biotech firms linked to foreign adversaries. Unlike earlier versions, it avoids naming specific Chinese companies. It now uses a broader definition for Biotechnology Companies of Concern, based on national security risks and foreign influence. It calls for the Office of Management and Budget to publish a list of entities one year after enactment.

Impact: An agreed House and Senate version of the Biosecure Act needs to be passed before it’s signed into law. The Act could impact businesses in several ways. These include businesses with US Government contracts, those in receipt of federal funding or with extensive supply chain dependency on identified Biotechnology Companies of Concern. Businesses may want to start reviewing processes and supply chains to ensure they would be compliant with the potential consequences of the Act. They may need to diversify partnerships and manufacturing locations.

US: Federal hemp ban to take effect in 2026

On November 12, the US Administration signed into law H.R. 5371, the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026. Within the Act are measures to ban hemp-derived cannabinoids, such as delta-8 and delta-10 THC, from November 2026. It moves to close the 2018 Farm Bill loopholes for intoxicating cannabinoids.

Impact: The federal ban comes at a period of state and court backlash against hemp-derived products. It effectively overrules state led frameworks which saw the hemp sector expand over the last several years. Businesses using these products should use the next 12 months to evaluate supply chain commitments. The ban could also impact non-intoxicating products in the wellness and medical sectors.

US: Proposed change to PFAS reporting for business

On November 10, the Environmental Protection Agency (EPA) released proposed changes to perfluoroalkyl and polyfluoroalkyl substances (PFAS) reporting regulations under the Toxic Substances Control Act. The changes aim to reduce compliance burdens while ensuring essential PFAS data collection. The original 2023 rule required manufacturers and importers to report PFAS data from 2011–2022. The new proposal introduces exemptions for low-concentration mixtures (under 0.1%), imported articles, certain byproducts, impurities, research chemicals, and non-isolated intermediates. Technical corrections will clarify reporting requirements and adjust submission timelines.

Impact: The EPA is taking comments for 45 days after publication in the Federal Register. Businesses may want to review supply chain operations in preparation for new reporting rules. Heavy users of PFAS should be aware that individual states may still have their own reporting rules.

US: Expanded critical minerals list

On November 7, the Department of the Interior announced the expansion of the critical minerals list to include copper and metallurgical coal. The final list of 2025 identifies 60 minerals. It aims to strengthen domestic supply chains for materials vital to defense, manufacturing, and clean energy technologies.

Copper is essential for electric vehicles, power grids, and electronics, whereas metallurgical coal supports steel production. The move seeks to reduce reliance on imports from countries which dominate global supply. The update also includes potash, rhenium, silicon, and lead, reinforcing efforts to secure resources critical for economic and national security.

Impact: The list is reviewed at least every three years. Heavy users of materials on the current list may want to consider reviewing their supply chains to reduce disruption risks. Domestic mining and supply of critical minerals is a priority policy area for the current US Administration. Businesses may want to explore eligibility of any federal incentives to expand domestic mineral production or switch to domestic supply.

US: Tariffs on heavy truck imports

On October 17, an Executive Order announced the introduction of a 25% heavy trucks and parts tariff on national security grounds. The Order took effect from November 1, 2025. It is aimed at protecting the domestic industry. The Commerce Department is conducting a Section 232 of the Trade Expansion Act of 1962 investigation into the sector. Investigations are also underway for pharmaceuticals and furniture.

Impact: Supply chains for heavy duty vehicles are highly integrated across geographic regions. The tariffs could impact foreign manufacturers and businesses involved in the supply chain of components for these products. Potential impacts could include manufacturers shifting some production to domestic sites.

US: New tariffs on specific wood products

On September 29, new tariffs on timber, lumber and their derivative products were introduced by Presidential proclamation. The following tariffs took effect from October 14, 2025:

• 10% on softwood timber and lumber (increasing to 30% on January 1, 2026)

• 25% on certain upholstered wooden products and kitchen cabinets/vanities (increasing to 50% on January 1, 2026)

The new tariff rates will not apply to imports from certain countries where the US has existing bilateral trade agreements. These include imports from the United Kingdom which will not exceed a rate of 10%. While tariffs on imported wood products from the European Union and Japan will not exceed 15%. The new tariffs are intended to strengthen the domestic wood industry, and promote industrial resilience.

Impact: Businesses should evaluate their supply chain exposure, as tariffs could pose potential risks of operational disruption. Financial penalties and delays may occur if customs documentation is not updated, or correct classifications are not applied.

Further reading

Global Industrials bulletin - November 2025 | Eversheds Sutherland

Global Sustainability & ESG Insights - November 2025 

UK Defence Offset Agreements: Government signals a step change | Eversheds Sutherland

German Bundestag passes NIS2 Implementation Act: What Entities Need to Know | Eversheds Sutherland

FDI in Europe: are Member States prioritising investment over national security? | Eversheds Sutherland

2025 US National Security Compliance Risk and Readiness Report | Eversheds Sutherland

Co-authored by Westley Trimble, Paola Paccani and Claire Webb (Knowledge)