Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

Germany's Lieferkettensorgfaltspflichtengesetz (LkSG), promulgated 16 July 2021 (BGBl. I 2021 S. 2959), requires German-headquartered companies to conduct mandatory human-rights and environmental due diligence across their own operations and direct suppliers (with cause-based obligations extending to indirect suppliers). Enforced by BAFA with administrative fines up to EUR 8 million or 2% of global annual turnover for firms with revenue ≥ EUR 400 million. The act applies to ~3,000 German corporates from 1 January 2023 (≥3,000 employees) and was extended to ~5,000 firms from 1 January 2024 (≥1,000 employees). A September 2025 cabinet amendment removed the annual-reporting obligation and narrowed sanctionable omissions to serious violations.

The German Federal Government adopted the 17th amendment to the Außenwirtschaftsverordnung (AWV, Foreign Trade and Payments Ordinance), published 30 April 2021 and entering into force 1 May 2021, aligning Germany's FDI screening regime with EU Regulation 2019/452. The amendment adds 16 further sectors to the sector-specific mandatory-notification regime, on top of the 11 already covered, bringing the total to 27 -- including AI, robotics, autonomous vehicles/drones, semiconductors, quantum technology, satellite systems, cybersecurity, and critical raw materials. Filing thresholds are voting-rights acquisitions of 10% or more by a non-EU/EFTA investor in the newly added sectors, with subsequent review triggers at 20%, 25%, 40%, 50% and 75%.

The US Bureau of Industry and Security added 14 entities across Russia, Germany, and Switzerland to the Entity List under 15 CFR Part 744, effective March 4, 2021. Ten Russian entities — including the 27th Scientific Center of the Russian Ministry of Defense (associated with Russia's chemical weapons activities) and nine members of the Chimmed Group distribution network (Chimmed Group, Femteco, Interlab, LabInvest, OOO Analit Products, OOO Intertech Instruments, Pharmcontract GC, Rau Farm, Regionsnab) — were listed for proliferation activities supporting Russia's WMD programs. Three German entities (Chimconnect GmbH, Pharmcontract GmbH, Riol-Chemie) and one Swiss entity (Chimconnect AG) were simultaneously listed as foreign-front nodes in the same procurement network. A license is required for all EAR-subject items; no license exceptions apply. The rule also corrects six pre-existing entries (one Germany, five China).

The Bureau of Industry and Security (BIS) removed three persons from the Unverified List (UVL) effective January 11, 2021 after completing successful end-use checks that verified their bona fides under §744.15(c)(2) of the Export Administration Regulations (EAR). The three removed parties are DMA Logistics GmbH (Germany), Halm Elektronik GmbH (Germany), and Integrated Production and Test Engineering / IPTE (Mexico). Removal restores eligibility for EAR license exceptions and eliminates the requirement for US exporters to obtain a signed UVL Statement before shipping items subject to the EAR to these parties.