Industrial Policy & Trade Monitor· 2673 actions· ✨ 90 recent

On 11 December 2025 the Council of the EU presidency, the European Parliament, and the European Commission reached provisional political (trilogue) agreement on the revision of Regulation (EU) 2019/452 establishing a framework for the screening of foreign direct investments into the Union, concluding interinstitutional negotiations on the Commission's proposal of 24 January 2024. The revised regime upgrades the 2019 cooperation-mechanism-only framework into a hybrid harmonised/mandatory regime: all 27 Member States must establish FDI screening mechanisms (replacing the current patchwork in which some Member States have no mechanism at all); mandatory minimum sectoral scope is set EU-wide and covers dual-use items, military equipment, hyper-critical technologies (general-purpose AI with space/defence relevance, quantum technologies, semiconductors), critical raw materials, critical entities in energy/transport/digital infrastructure, electoral infrastructure, and certain financial-system entities; foreign investments routed through EU subsidiaries fall within the perimeter; a shared database prevents Member-State arbitrage; and an optional single electronic-filing portal becomes available if requested by at least nine Member States. Screening decisions remain the exclusive responsibility of the Member State in which the investment is made. Once the Regulation enters into force (after Council and Parliament formal adoption and OJ publication, both pending as of the political-agreement date), the new rules will apply after an 18-month transition period — implementation expected toward the end of 2027.

On October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.

On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.

On 18 September 2025 the Bundestag adopted the Gesetz zur Errichtung eines Sondervermögens "Infrastruktur und Klimaneutralität" (SVIKG), authorising up to EUR 500 bn of additional federal borrowing over a twelve-year horizon outside the constitutional debt brake, on the basis of the new Article 143h Grundgesetz inserted by the March 2025 constitutional amendment. The envelope splits into up to EUR 100 bn for Länder and municipal infrastructure (channelled via the companion Länder- und Kommunal-Infrastrukturfinanzierungsgesetz, LuKIFG, passed 9 October 2025), EUR 100 bn transferred to the Klima- und Trans- formationsfonds (KTF) in annual instalments through 2034, and up to EUR 300 bn for additional federal investments in transport, energy/ heat, hospital, education, digitalisation, civil protection and R&D infrastructure. Investments are eligible retroactively from 1 January 2025 and may be approved through 31 December 2036; loan repayment begins no later than 1 January 2044. SVIKG is the largest single industrial-finance instrument launched by an EU member state in the post-2022 industrial-policy cycle.

President Trump signed Executive Order 14323, "Addressing Threats to the United States by the Government of Brazil," on 30 July 2025 (published in the Federal Register on 5 August 2025 as FR doc 2025-14896). Invoking IEEPA and the National Emergencies Act, the order declared a country- specific national emergency citing "policies, practices, and actions" of the Lula government — including the criminal prosecution of former president Jair Bolsonaro, asserted infringement of the free-expression rights of US persons via DSA-style platform-content rules, and retaliatory measures targeting US digital firms — as constituting an "unusual and extraordinary threat" to US national security, foreign policy, and economy. The EO imposed a 40% additional ad valorem duty on Brazilian-origin goods effective for entries on or after 12:01 a.m. EDT on 6 August 2025; stacked on top of the 10% baseline reciprocal rate from EO 14257/14326, the cumulative rate reached 50% for non- exempt goods. Annex I exempted civil aircraft and parts, orange juice, certain machinery, certain metals, and energy/energy products. The EO was amended on 20 November 2025 (effective for entries on or after 13 November 2025) to exempt 238+ HTSUS codes for agricultural products (beef, tropical produce, nuts, coffee, cocoa, cassava derivatives, etc.) following initial Trump-Lula bilateral negotiations on 6 October 2025. The IEEPA-tariff component was terminated by EO of 20 February 2026 ("Ending Certain Tariff Actions") within hours of the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* holding that IEEPA does not authorize the imposition of tariffs.

President Trump signed Proclamation 10962 on 30 July 2025, imposing a 50% Section 232 tariff on imports of semi-finished copper products (pipes, wires, rods, sheets, tubes, foils) and copper-intensive derivative products (cables, connectors, electrical components, pipe fittings) effective 12:01 a.m. ET on 1 August 2025. The proclamation also authorises the Commerce Secretary to impose a 25% domestic-sales requirement and export controls on high-quality copper scrap, and lays out a phased schedule for refined-copper tariffs (15% from 1 Jan 2027, 30% from 1 Jan 2028) contingent on a Commerce review report due 30 June 2026. Copper input materials (ores, concentrates, cathodes, anodes) and copper scrap itself are exempt from the 50% tariff. The original 90-day "inclusions" process for expanding the derivative list was terminated by a follow-on April 2026 proclamation that consolidated authority with Commerce + USTR.

H.R.1, the "One Big Beautiful Bill Act" (Public Law 119-21), was signed into law by President Trump on 4 July 2025. The budget-reconciliation statute is the single largest reversal of the 2022 Inflation Reduction Act (IRA) industrial-policy framework: it accelerates the termination of IRA-era clean- energy tax credits and overlays a new "Foreign Entity of Concern" (FEOC) / "Prohibited Foreign Entity" (PFE) regime on the credits that survive. The §25E used-EV credit, the §30D new clean-vehicle credit, the §45W commercial clean-vehicle credit, and the §30C alternative-fuel-refueling-property credit terminate for vehicles or property placed in service after 30 September 2025. The §25C energy-efficient home improvement credit and the §25D residential clean-energy credit terminate for property placed in service after 31 December 2025. The §45Y clean-electricity production credit and §48E clean-electricity investment credit are eliminated for wind and solar facilities placed in service after 31 December 2027, with a safe harbour for projects whose construction begins on or before 4 July 2026. From 1 January 2026, projects beginning construction must satisfy "material assistance" thresholds limiting the share of components, subcomponents and critical minerals sourced from prohibited foreign entities (PRC, Russia, Iran, DPRK and entities controlled by them). For §45Y/§48E facilities the threshold starts at 40% non-PFE content in 2026 and steps up by 5 percentage points per year through 2030; for §45X advanced manufacturing PTC the analogous schedule begins at 50% in 2026 and rises through the decade. CBO scored the package's energy-credit terminations as generating roughly USD 280bn of revenue (gross), of which USD 77.4bn from §25D termination, USD 21.2bn from §25C, USD 77.8bn from §30D, USD 104.5bn from §45W, and USD 2bn from §30C, partially offsetting the bill's other tax cuts. The bill simultaneously re-authorises and broadens the §48D advanced manufacturing investment tax credit for semiconductor fabs, raising the credit rate from 25% to 35% for property placed in service after 31 December 2025 (preserving the CHIPS Act-aligned semiconductor leg of the IRA-era stack). The OBBBA therefore reshapes the IRA from a broad-based clean-energy + EV + manufacturing pull-through into a narrower, China-decoupling industrial policy concentrated on semiconductors and (residually) §45X battery / critical- mineral processing.

On 4 February 2025, President Donald J. Trump signed National Security Presidential Memorandum/NSPM-2, "Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran's Malign Influence." The memorandum reimposes the first- term "maximum pressure" framework, directing the Secretaries of State and Treasury and the Attorney General to (i) drive Iran's exports of crude oil and petroleum products — including to the People's Republic of China — to zero; (ii) review and modify or rescind sanctions waivers and general licences (notably the Chabahar port waiver benefiting India); (iii) sanction shadow-fleet vessels, intermediaries, refineries (including PRC "teapot" refiners) and oil traders facilitating Iranian energy exports; and (iv) lead a diplomatic isolation campaign including a snapback of UN Security Council sanctions under JCPOA Resolution 2231 paragraph 11. Since promulgation, OFAC has designated 1,000+ Iran-related persons, vessels and aircraft and four PRC independent ("teapot") refiners alleged to have processed sanctioned Iranian crude. The DOJ is also directed to pursue impoundment of Iranian oil cargoes and seizure of Iranian assets to satisfy US-court terrorism-victim judgments.

President Trump signed three Executive Orders on 1 February 2025 (EO 14193, 14194, 14195) declaring national emergencies under IEEPA over the cross-border flow of fentanyl + illegal migration, and using that authority to impose new tariffs: 25% on imports from Canada (with a reduced 10% rate on Canadian energy products), 25% on imports from Mexico, and an additional 10% on imports from China (separate from pre-existing Section 301 + Section 232 tariffs). The tariffs took effect 4 February 2025. On 3 February 2025 the administration announced a 30-day pause for both Canada and Mexico following bilateral border-enforcement commitments; the China tariff was not paused. China responded 4 February with retaliatory tariffs of 15% on US LNG/coal/farm equipment and additional measures. The package set the precedent for the broader 2 April 2025 "Liberation Day" reciprocal-tariff regime (filed: 2025-04-02-us-trump-reciprocal-tariff-regime).

On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.

The US Treasury and IRS published the final regulations implementing §45V of the Inflation Reduction Act, establishing the Clean Hydrogen Production Tax Credit. The rule codifies the 45VH2-GREET lifecycle-emissions methodology and three electricity-sourcing pillars — additionality (new-build requirement within 36 months), temporal matching (annual until 2030, then hourly), and deliverability (same grid-balancing region) — that determine credit eligibility for electrolytic pathways. Credits range from $0.60/kg (2.5–4.0 kg CO₂e/kg H₂) to $3.00/kg (below 0.45 kg CO₂e/kg H₂), representing the primary US hydrogen industrial-policy instrument for the 2025–2034 cycle and the global benchmark for green-hydrogen additionality rules.