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India Trade Alert: Navigating EU's CBAM Phase 2, New Customs Rules, and Global Freight Volatility

20 November 2025 by
Himanshu Gupta
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India Trade Alert: Navigating EU's CBAM Phase 2, New Customs Rules, and Global Freight Volatility

By Sanskriti Global Exports by Himanshu Gupta

Trade Winds of Change: Your November 20, 2025 Briefing on CBAM, Customs, and Supply Chain Shocks

By our Senior Trade Analyst

In the dynamic theatre of global commerce, standing still is moving backwards. Today's trade landscape is a complex interplay of ambitious domestic policy, stringent international regulations, and volatile market forces. For Indian import-export professionals, the ability to anticipate and adapt is no longer just a competitive advantage; it is a prerequisite for survival. This roundup cuts through the noise, providing a focused analysis of the day's most critical developments and their direct impact on your operations.

From the formalization of the EU's carbon tax regime to a landmark customs facilitation scheme by New Delhi, and from renewed supply chain pressures to geopolitical tech manoeuvres, the events of today will shape the balance sheets of tomorrow. Let's delve into the key headlines and, more importantly, what they mean for the Indian trade community.

Today's Global Trade Roundup: A Factual Summary

The global trade environment presented a mixed bag of opportunities and challenges today. Here are the four key developments that demand your immediate attention:

1. EU Releases Detailed Guidelines for CBAM Phase 2 Implementation

The European Commission has published its much-anticipated detailed procedural guidelines for the second phase of the Carbon Border Adjustment Mechanism (CBAM), set to begin in January 2026. While the transitional phase focused on reporting, these new regulations outline the precise methodologies for calculating embedded emissions, the process for purchasing CBAM certificates, and the stringent penalties for non-compliance. The guidelines confirm that there will be limited exemptions, putting the onus squarely on exporters from countries like India to have their carbon accounting in order.

2. India Launches 'Green Channel Plus' for Electronics Component Imports

In a significant boost to the 'Make in India' and Production-Linked Incentive (PLI) schemes for electronics, the Central Board of Indirect Taxes and Customs (CBIC) announced the launch of the 'Green Channel Plus' (GCP) initiative. This AEO (Authorized Economic Operator) tiered program is designed to provide near-instantaneous customs clearance for pre-approved, high-value electronics components. Qualified importers under the electronics PLI scheme will see their consignments cleared based on simplified digital documentation, drastically reducing dwell time at ports and airports.

3. Asia-Europe Container Freight Rates Spike by 15%

Major shipping indices are reporting a sudden 15% week-on-week spike in spot rates for 40-foot containers on key Asia-Europe trade lanes. Analysts attribute the surge to a confluence of factors: a pre-Chinese New Year inventory rush, renewed congestion at several Northern European transhipment hubs, and a strategic blanking of sailings by major carrier alliances to manage capacity. This unexpected volatility is disrupting budget forecasts and raising concerns about a potential return to the supply chain instability seen in previous years.

4. US Commerce Department Expands 'Dual-Use' Technology Scrutiny

The United States has further tightened its export control regime, with the Bureau of Industry and Security (BIS) adding a new list of foreign entities and specific sub-categories of semiconductor and AI-related technologies to its 'Dual-Use' watch list. The move, aimed at curbing technology transfer, will increase compliance burdens for Indian companies importing these sensitive components for integration into finished products, even if the final goods are not destined for the US market. The regulations require more rigorous end-user verification and licensing.

Implications for Indian Import-Export Professionals

Understanding these developments is the first step. The next is to translate them into actionable strategy. Here are the immediate implications for your business:

  • Regarding the EU's CBAM Phase 2 Guidelines:
    • Urgent Action on Carbon Accounting: If you are a steel, aluminium, cement, fertilizer, hydrogen, or electricity exporter to the EU, the time for theoretical planning is over. You must immediately implement robust, verifiable systems for calculating the embedded carbon in your products. This is now a core compliance cost.
    • Price Re-negotiation: The cost of CBAM certificates will directly impact your landing cost in the EU. Proactively open discussions with your European buyers about price adjustments and shared responsibility for these new carbon-linked tariffs.
    • Invest in Decarbonization: The long-term strategic imperative is clear: invest in greener manufacturing processes. This is no longer just a sustainability goal but a critical factor for maintaining market access in Europe.
  • Regarding India's 'Green Channel Plus' Scheme:
    • Competitive Edge for Electronics Manufacturers: This is a game-changer for electronics assembly in India. Eligible firms can significantly shorten their production cycles, reduce inventory carrying costs, and improve overall supply chain efficiency, making Indian assembly more competitive globally.
    • AEO Status is Key: To leverage GCP, achieving and maintaining a high-tier AEO status is paramount. This requires impeccable compliance records and robust internal process controls. Businesses should prioritize their AEO certification process if they haven't already.
    • Potential for Component Hubbing: The efficiency of GCP could position India as a more attractive location for 'hub-and-spoke' models, where components are imported and then re-exported as part of sub-assemblies to other regions.
  • Regarding Shipping Rate Volatility:
    • Recalibrate Freight Budgets: Immediately review and update your freight cost assumptions for Q1 2026. The current spike could signal a period of higher-than-expected costs, impacting your CIF/CFR and DDP pricing models.
    • Strengthen Forwarder Relationships: In volatile markets, a strong relationship with your freight forwarder or 3PL partner is invaluable. They can provide access to secured space, better rates, and critical market intelligence.
    • Explore Contract vs. Spot Market: Assess the balance of your cargo between long-term contracts and the spot market. While contracts offer stability, a flexible approach might be needed to navigate the current peaks and troughs.
  • Regarding US 'Dual-Use' Tech Scrutiny:
    • Mandatory Supply Chain Due Diligence: For tech importers, it is now non-negotiable to conduct thorough due diligence on your suppliers and the specific components you are buying. You must verify that they are not on any restricted entity list.
    • Diversify Sourcing: Over-reliance on a single geography for critical tech components is a significant risk. Begin exploring and qualifying alternative suppliers from other countries to mitigate potential disruptions from US policy shifts.
    • Compliance is Non-Negotiable: Ensure your internal compliance teams are fully briefed on the updated regulations. The penalties for inadvertently re-exporting controlled US technology can be severe, including fines and inclusion on denial lists.

Conclusion: Thriving in an Era of Complexity

The message from today's developments is unequivocal: the global trade ecosystem is becoming more complex, not less. Success is no longer just about finding the best price; it's about mastering compliance, building resilient supply chains, and strategically leveraging policy initiatives. The launch of 'Green Channel Plus' is a welcome tailwind from the Indian government, but headwinds from EU regulations and market volatility require careful navigation. The agile, informed, and compliant Indian trader is the one who will not only weather these changes but find new avenues for growth within them.

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Himanshu Gupta 20 November 2025
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