President Trump Announces New Travel Ban
On June 4, 2025, President Trump announced a new travel ban through a proclamation titled “Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists and Other National Security and Public Safety Threats.” The ban, which echoes his 2017 efforts to restrict entry to the United States for nationals of certain countries deemed to be national security risks, expands the number of affected countries and divides them into two categories: Full Suspension of Entry and Partial Suspension of Entry. It will go into effect on June 9, 2025 with no announced end date.
Key provisions include:
Full Entry Bans: Nationals from the following 12 countries are barred from entering the United States: Afghanistan, Burma (Myanmar), Chad, Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, and Yemen.
Partial Entry Ban: Seven additional countries—Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela—face the following partial entry restrictions: halting issuance of new visitor (B1/B2), student (F, M), and exchange (J) visas and reduction in validity for nearly all other nonimmigrant visa categories, including all employment visa categories (subject to the exceptions listed below).
Justification: The proclamation cites the following national security concerns as the basis for the new ban, with varied reasons listed for each suspended country: sponsorship of terrorism, lack of sufficient government to issue passports and civil documents, lack of appropriate vetting and screening measures, high overstay rates for past visa recipients, and refusal to accept back nationals being removed from the United States, among others.
Applicability: The travel ban only applies to nationals of the designated countries who, on June 9, 2025: (1) are outside the U.S. and (2) do not hold a valid, issued U.S. visa.
Exceptions and Waivers:
Categorical Exceptions: The ban does not apply to the following:
U.S. Lawful Permanent Residents (LPR or green card holder).
Dual nationals of the restricted countries traveling on the passport of an unrestricted country (e.g., Haitian/French dual national entering the U.S. on their French passport).
Individuals traveling on most diplomatic visas.
Athletes and related personnel and families entering to participate in the World Cup, Olympics, or other “major sporting event.”
Immediate family members seeking to enter on immigrant visas (i.e., applying for LPR status from outside the US).
Most applicants for adoption.
Certain Special Immigrant Visas (Afghan and US Government employees).
Immigrant visas for certain ethnic and religious minorities form Iran.
Those granted asylum or protections under the Convention Against Torture (CAT), and those admitted to the US as a refugee.
Case-by-case Waivers: The Attorney General and Secretary of State may designate individual exceptions for those entering in the national interest of the US. Mechanisms for these waivers have not been announced and will likely be implemented through U.S. embassies and consulates as during President Trumps first term.
The new travel ban is expected to face legal challenges, likely even before it’s effective date five days after its issuance. It is drafted to narrow the scope and reasons for the restrictions, so it remains to be seen whether the courts will allow it to go into full or partial effect on June 9, 2025.
CODEX ALIMENTARIUS: Main Outcome of the 44th Committee on Methods of Analysis and Sampling (CCMAS44)
The 44th session of the Codex Alimentarius Committee on Methods of Analysis and Sampling (CCMAS44) successfully addressed all topics on its agenda. CCMAS44 endorsed methods of analysis from commodity standards and recommended approval of others e.g., on chocolate, chocolate products and other cocoa-based products, fruits juices and nectars, fish products, follow-up formulas, food grade salt. CCMAS44 held intense discussions on methods of analysis for the protein content in quinoa and on the method for the determination of the moisture content in whey powder. CCMAS44 agreed also to establish an expert group under the auspice of the IFU to inform the work on the methods proposed for fruit juices and nectars. CCMAS44 finally agreed on rounded numeric performance criteria for the determination of nitrate and nitrite ions in food matrices. CCMAS44 decided also to start working on methods for the identity of “sugars and honey”. It also endorsed the method discussed during the last CCNFSDU44 meeting on dietary fiber with a further question back to CCNFSDU with a proposed amendment to a more comprehensive footnote. CCMAS44 adopted a comprehensively amended information document about sampling plans (with an entire new part 3 on Bayesian sampling plans) to inform the implementation of the current guidelines on sampling. CCMAS44 advanced the work on a consolidated list of methods for the presence of allergens that would be subject to another intersessional work. CCMAS44 re-established EWGs (including one to advance the harmonization of names for principles in the general standard of methods of analysis) and agreed to convene a working group in person immediately prior its CCMAS45 session (2026) [ii].
See more information available about CCMAS44 working documents quoted in this article [iii], as well as in the official report of the CCMAS44 meeting [iv]. Codex standards, guidelines, codes of practices and related miscellaneous texts quoted in this article are readily and freely available [v].
ENDORSEMENT OF METHODS OF ANALYSIS AND SAMPLING AND REVIEW OF METHODS INCLUDED IN THE GENERAL STANDARD FOR METHODS OF ANALYSIS (CXS 234, 2024 version)
Methods applicable cocoa products and chocolate; fish and fishery products; foods for special dietary uses; fruit juices and nectars; milk and milk products; and miscellaneous products such as dried meat and food grade salt
CCMAS44 agreed to (i) endorse all the methods and amended methods resulting from the work of pre-session VWG and an in-Session WG (IWG as summarized in CCMAS44’s CRD02 Rev.1 working document); (ii) revoke and retype the methods, as included in Appendix II of CCMAS44 report); (iii) inform the CCNFSDU that the methods of analysis submitted by it to CCMAS were forwarded for adoption by CAC48 and all the relevant methods of analysis be revoked consequentially. CCMAS44 agreed to re-establish its EWG on methods chaired by Canada (and not customarily by Australia), for further consideration on (a) cocoa products and chocolate; (b) foods for special dietary uses; and (c) fruit juices and nectars. CCMAS44 praised the work of Dr Richard Coghlan (Australia), as the outgoing chair of the EWG, VWG and IWG. CCMAS44 also agreed to re-establish a Physical Working Group (PWG) on methods endorsement led by the USA and co-led by Hungary, Japan and Uruguay to meet immediately prior to CCMAS45, to (a) consider all methods of analysis and sampling submitted by Codex Committees for endorsement, (b) the outcomes of the work of the EWGs on methods including retyping of the ISO 1871 method for determining protein in quinoa (see further below); the proposals on the workable packages on chocolate and cocoa-based products as well as on sugars and honey, and any other matters referred by other Codex Committees or submitted by Members and Observers.
CCMAS44 concluded favorably its work on methods applicable to (a) cocoa products and chocolate; (b) fish and fishery products; (c) foods for special dietary uses; (d) fruit juices and nectars; (e) milk and milk products; and (f) miscellaneous products such as dried meat and food grade salt. CCMAS44 did not propose changes to existing methods already included in CXS 234 applicable to (a) cereals, pulses and legumes and derived products; (b) fruit juices and nectars; (c) milk and milk products; and (d) miscellaneous products (e.g., dried meat and food grade salt). CCMAS44 also revoked methods as consequential changes from other adopted for the same standardized food [vi].
In order to advance the technical discussions on the remaining work package of methods in fruit juices and nectars, CCMAS44 agreed to convene an expert group under the auspices of the International Fruit and Vegetable Juices and Nectars Association (IFU) to (a) determine the ranges of parameters relevant for quality and authenticity; (b) determine the range of measurements or maximum LOD; (c) evaluate the list of endorsed methods included in CXS 234 and those listed in the commodity standard CXS 247 (2024 version) ; (d) determine/consider if the presently endorsed methods are still appropriate and “fit-for-purpose” to control the “quality and authenticity” of fruit juices; (e) determine/consider if any of the presently endorsed methods should be revoked and eliminated from CXS 234 and CXS 247; (f) assess whether any new method(s) could be considered by the CCMAS endorsement working group in the future, for addition to CXS 234 for the general provision of juice “quality and authenticity”; and (g) collate relevant validation data for any new procedures that CCMAS could consider in the future. In particular, the expert group shall identify clearly which methods should be maintained in CXS 234, revoked, or replaced. Codex Members were invited in contributing to this work by contacting directly IFU and nominate nationally relevant fruit juice experts to participate eventually to the work of that IFU-led expert group, in their individual capacity. CCMAS44 praised the coordinating work ensured by Dr David Hammond [vii] at IFU.
With regards the work package on methods for chocolate and chocolate products and other cocoa-based products, CCMAS44 agreed to re-establish an EWG chaired by Serbia and co-chaired by USA to continue reviewing the relevant methods listed. With regards to the work package of relevant methods for sugars and honey, CCMAS44 agreed to establish an EWG chaired by Uruguay to review these methods applicable to sugars and honey. Both EWGs should submit their report sufficiently in advance to CCMAS45.
As examples of methods endorsed, CCMAS44 agreed to retain the method for determination of amino acid nitrogen in fish sauce, AOAC 920.04 and AOAC 920.03, in CXS 234. CCMAS44 endorsed AOAC 935.47 and AOAC 937.09B as Type III methods. CCMAS44 agreed to transfer the method for the determination of sodium chloride in food grade salt as described in the Standard for food grade salt (CXS 150) with editorial amendments to CXS 234. CCMAS44 also agreed with an update to the hyperlink in the footnote referencing the method for iodine in food grade salt in CXS 234. In addition, CCMAS44 agreed to transfer the related sampling plan to CXS 234. CCMAS44 noted that the sampling plan was currently incompatible with the provision for sodium chloride and would require further review and agreed that such review could be taken up later under the work on the review of sampling plans and inform CCFA accordingly. CCMAS44 also noted the editorial amendment to the principle for the example methods AOAC 2015.06 / ISO 21424 |IDF 243 that meet the numeric performance criteria for copper in milk fat products and agreed to the removal of ISO 5738 | IDF 76 and AOAC 960.40 as example methods. All relevant commodity committees will be informed accordingly.
CCMAS44 further requested CCNFSDU to consider (a) whether it would be appropriate to develop numeric performance criteria (NPC) for methods of analysis for Type II and Type III methods; or (b) develop additional methods for follow-up formula to align with those for infant formula for common provisions (see Part 3.2 of Appendix II of CCMAS44 report). With regard to the recommendation for CCNFSDU to consider developing NPC, the chair of the VWG clarified that CCMAS’s preference was for committees to consider this approach. CCMAS44 noted that this approach would provide flexibility for countries to choose methods that meet these criteria. This approach was in accordance with the Procedural Manual that preference should be given to set NPC. CCMAS44 further agreed that the name and format for principles for the corresponding methods for infant formula included in CXS 234 would not be aligned with those agreed for follow-up formula at this stage pending ongoing discussion on the harmonization of names and format for principles. It was noted that CCNFSDU was also in the process of reviewing all methods for provisions in standards under their purview to assess their fitness-for-purpose and to identify additional/replacement methods, or other corrections.
Dietary fibre reference in Table 6 of CXS 234 “Methods of analysis for dietary fibre: Guidelines for use of nutrition and health claims (CXG 23, 2013 version): Tables of conditions for claims”
CCMAS44 endorsed the methods proposed by the outcome of the EWG and VWG (as presented in CCMAS44 CRD02 Rev.1 working document), together with the footnote proposed by CCNFSDU44 which reads “Isolated, purified, and/or synthetic fibres captured by AOAC 2022.01/ICC Standard 191/AACC 32-61.01 that do not meet the Codex definition of dietary fibre in the Guidelines on nutrition labelling (CXG 2-1985) should be subtracted from the final measurement, where deemed appropriate by competent authorities.” CCMAS44 also agreed to request CCNFSDU to clarify whether the footnote was only applicable to the methods AOAC 2022.01/AACC 32-61.01/ICC Standard No. 191. If not, the footnote should then apply to all methods for dietary fibers included in Table 6 of CXS 234, or a subset of these methods listed in that Table 6. Should CCNFSDU agrees, then CCMAS would delete the footnote applied only to AOAC 2022.01/AACC 32-61.01/ICC Standard No. 191.
CCNFSDU was further asked to consider a proposed amendment to the current footnote 2 included in Table 6 of CXS 234. Such proposed amendment would address the concerns raised that the footnote forwarded by CCNFSDU should be consistently applied to all methods in CXS 234, Table 6. Should CCNFSDU agree to amend footnote two, then the footnote forwarded by CCNFSDU to accompany AOAC 2022.01/AACC 32.61.01/ICC Standard No. 191 could then be deleted. The recommended additional phrase to existing footnote 2 is shown in bold as follows: « Two issues are left for national authorities: to include monomeric units 3-9 and which isolated or synthetic compounds have physiological benefit. (Refer to the Guidelines on nutrition labelling (CXG 2-1985)). Isolated, purified, and/or synthetic fibres captured by the analysis that do not meet the Codex definition of dietary fibre in CXG 2-1985 should be subtracted from the final measurement, where deemed appropriate by competent authorities. »
SPECIFIC DISCUSSIONS ON SOME METHODS
Determination of the protein content in quinoa products (conforming to CXS 333, 2020 version)
This agenda was very much disputed. CCMAS44 however agreed to retain the method for determining protein in quinoa already in CXS 234 as a Type IV method (method ISO 1871), noting the reservation of Peru. CCMAS44 requested the re-established PWG on endorsement to consider retyping of ISO 1871 method for determining protein in quinoa based on the information provided in CCMAS44’s CRD19, referring to a comprehensive comparative analytical work performed by several national metrological institutes based in Latin America in this matter. Brazil also suggested an extension of Extension of the ISO 20483 method to quinoa offered as an alternative method. It was suggested that the necessary validation studies could be performed and discussed again within ISO to determine if this method could be extended from cereals and pulses to a pseudocereal such as quinoa. ISO indicated that a decision to extend ISO 20483 to quinoa should be subject to a formal request according to ISO procedures. In that regard, it was also noted that ISO might even end up validating a dedicated method (to Quinoa) instead of extending the existing ISO 20483 to Quinoa [viii].
Determination of the moisture content in whey powders (conforming to CXS 289, 2022 version)
CCMAS44 agreed to forward the 102NP method with the footnote as amended in paragraph 41 to CAC48 for adoption as a Type IV method (Appendix II, Part 1.5), for whey powder, on an exceptional basis, in line with Section 3.9 (v) of the information document “Comprehensive guidance for the process of submission, consideration and endorsement of methods for inclusion in CXS 234” and to make the consequential amendments to Appendix XI of CXS 234 (2024 version).
Determination of the particle size of milling products using sieve analysis for use on edible cassava flour and gari
CCMAS44 acknowledged that no amendment to CXS 234 was necessary for the moment, despite some technical elements presented in CCMAS44’s CRD9 document by the International Association for Cereal Science and Technology (ICC) about the revision of ICC Recommendation N. 207, to render it applicable to edible cassava flour and to gari (in particular to include appropriate sieve sizes). CCMAS noted that the ICC revision work was in its final approval stage at ICC level. It was recalled that the current ICC Recommendation N. 207 had already been endorsed by CCMAS43.
SAMPLING PLANS
Information document to the General guidelines on sampling (CXG 50, 2023 version) – e-book with sampling plans applications
CCMAS44 considered the outcome of an inter-sessional EWG chaired by New Zealand and co-chaired by Germany to develop an information document on how implementing the revised Codex Alimenta-rius General guidelines on sampling (CXG 50, 2023 version). Such information document should not be considered as an official Codex text, but simply there to inform countries and food business operators for internal use by CCMAS and other Codex commodity committees. CCMAS44 agreed to publish the revised information document (as presenting in CCMAS44 report’s Appendix IV) and inform Codex committees of the publication of this document. It also agreed to remove the current information document titled “Practical examples of sampling plans” from the Codex website. Finally, it was noted that as other applications (Apps) were being developed, they would be forwarded to the Codex Secretariat for inclusion to the list of applications in the information document and that CCMAS would be informed accordingly. Other supporting resources, such as webinars, would be made available on the CCMAS webpage as well. The agreed information document should also be considered a living document, meaning CCMAS could update it when needed and where warranted [ix].
Review of sampling plans in the general standard for methods of analysis (CXS 234, 2024 version) and development of sampling plans for lots consisting of bulk material/heterogenous lots, including for mycotoxins
CCMAS44 agreed to continue developing the various discussion papers on (a) the review of sampling plans in CXS 234, particularly the various approaches to placing the sampling plans in the standard(s), the format and content of the presentation of sampling plans, and the responsibility for assessing the parameters that determine the selection of the appropriate sampling plan for a given commodity/provision combination; and (b) the development of sampling plans for bulk materials/heterogenous lots, including mycotoxins, including proposed sampling plans for consideration by CCMAS45, and to inform CCCF of this decision. CCMAS44 also noted that work on sampling plans for bulk materials/heterogenous lots, including for mycotoxins, should be conducted in close collaboration with CCCF; and noted the possible need for CCMAS to provide support to commodity committees in their review of sampling plans. CCMAS44 agreed to re-establish an EWG, chaired by New Zealand and co-chaired by Germany to advance the revisions of these discussion papers and prepare a dedicated discussion paper on sampling plans for bulk materials/heterogenous lots, including for mycotoxins, to be discussed by CCMAS45.
OTHER ASPECTS
Numeric performance criteria for the determination of nitrate and nitrite ions in food matrices
CCMAS44 considered the outcome of an intersessional EWG work led by Australia and co-chaired by the USA, including discussions held by the in session VWG. CCMAS44 agreed with the Numeric Performance Criteria (NPC) elaborated (and rounded up during the session) for nitrate and nitrite in three food matrices (i.e., ripened cheeses; processed comminuted meat, poultry, and game products; and, heat-treated processed meat, poultry, and game products in whole pieces of cuts) and agreed to forward these NPC back to CCFA for information. Initial CCFA request was for CCMAS to establish NPC for methods of analysis in these specified food matrices; provide information on available analytical methods suitable for both the adopted MLs and the lowest proposed residue levels; and clarify whether the methods measured nitrate and nitrite ions separately or in combination [x].
Methods of analysis for precautionary allergen labelling
CCMAS44 considered the outcome of an EWG led by the USA and its prior consideration by the IWG. Due to several factors related to the presentation of the list of methods, the need for further consideration, and new method validation guidelines, CCMAS44 agreed to re-establish an EWG chaired by USA and co-chaired by UK to finalize the review of the methods presented at CCMAS 44 against the recently updated CEN and AOAC validation guidelines and performance requirements [xi] and simplify the presentation of the methods and their validation status. CCMAS44 tasked the new EWG to draft a response to CCFL49 for consideration by CCMAS45. CCMAS44 confirmed that the EWG would not have to address the second question from CCFL regarding sampling plans.
Nitrogen to protein conversion factors for commodities approved by Codex Commodity Committees
CCMAS agreed to forward the list of Nitrogen to Protein conversion factors as amended, for approval by CAC48 and future inclusion as an Annex to the General Standard on Methods of Analysis (CXS 234), while noting some inconsistencies with these conversion factors especially for various soy products, and it suggested that these factors should be reviewed in the future. CCMAS44 noted that these factors would need to be reviewed by the relevant Codex Commodity Committees to ensure further consistency [xii].
Harmonization of names and format for principles identified in CXS 234, 2024 version
CCMAS44 considered the outcome of an intersessional EWG work led by Brazil and Chile. Purpose of this work was to (i) establish a centralized database consolidating all methods relevant to CCMAS; (ii) harmonize terminology for analytical methods across Codex standards; and (iii) develop a publicly accessible database on methods of analysis and sampling for inclusion on the Codex website. The work of the EWG to develop harmonized terminology for analytical methods, format for principles and provision names was thus to support the development of such a structured database. CCMAS44 significantly updated the document but was unable to address all the issues. CCMAS44 agreed to re-establish the EWG, led by Brazil and co-led by Chile to further revise the “Harmonization of Names for Principles in CXS 234-1999”, including its annexes A, B, and C, using the text included in CCMAS44 report Appendix VI as its working basis, with the aim of ensuring that the principles in CXS 234 are properly included and continue discussions on Annex D, focusing on separating the provisions into three distinct groups (editorial or no-change provisions, provisions linked to active committees, provisions linked to inactive committees) and making corresponding recommendations [xiii].
Endnotes
[i] Food Production Systems Engineer; Food Standards, Safety and Regulatory Specialist; Counsellor at Keller and Heckman LLP Brussels office
[ii] CCMAS is the specialised body of the Codex Alimen-tarius Commission Food Standard Program dealing with the most complex scientific and technical matters relating to (a) methods of analysis (i.e., analytical chemistry); (b) sampling plans (i.e., statistical analysis) other than those covered by specialised horizontal committees, and (c) any other issues related to these. In addition, CCMAS endorses the methods proposed by Codex Committees developing commodity and food standards. As such, CCMAS outputs are key to help countries and food business operators in performing their conformity assessment to existing Codex food standards, hence ensuring food safety and authenticity of such standardized foods, helping minimizing food fraud, and guaranteeing a better traceability and fair practices in international trade of these food supplies.
CCMAS44 was held virtually through five 3-hour daily sessions from May 5 to 8, 2025 and was preceded by a pre-session virtual working group (VWG) on “Endorsement”, held on April 29 and 30, 2025 and which prepared decisions for CCMAS44 on nearly all agenda items (item 2, 3, 4, 5, 7 and 8). The PWG also continued its work during part of the plenary as an in-session working group (IWG). CCMAS44 adopted its draft report virtually on May 14, 2025. CCMAS44 was attended by 74 Member countries, one Member organization and 21 Observer organizations. The session was chaired by Dr Attila Nagy, Director, National Food Chain Safety Office (NFCSO) and co-chaired by Dr Zsuzsa Farkas, Head of Department, Department of Digital Food Science, University of Veterinary Medicine, Budapest. The next CCMAS meeting (CCMAS45) was tentatively scheduled from 9 to 13 March 2026, to be held in person in Budapest (Hungary) and be preceded by the PWG on “Endorsement” and a regular meeting of the contact group of inter-agencies developing and validating methods of analysis and sampling (i.e., composed of ISO, IDF, AOAC International, FOSFA International, USP-Food Chemical Codex, AACC, ICC, AAFCO, NMKL, ICUMSA, and the international association MoniQA).
[iii] See https://www.fao.org/fao-who-codexalimentarius/ meetings/detail/en/?meeting=CCMAS&session=44&
[iv] See https://www.fao.org/fao-who-codexalimentarius/ meetings/en/
[v] See https://www.fao.org/fao-who-codexalimentarius/ codex-texts/en/
[vi] Adopted methods — Cocoa products and chocolate: Updated methods on fat-free cocoa solids, fat-free milk solids (determined as milk protein), Total Fat (on a dry basis), Cocoa shell (determined as spiral vessel count), cocoa shell (determined as stone cell count). Fish and fishery products (Quick Frozen Fish Sticks (Fish Fingers), Fish Portions and Fish Fillets – Breaded or in Batter – CXS 166 (2017 version)): Fish content (declaration) – Nitrogen, Moisture, Total Fat, Ash. Performance criteria for the methods for sodium chloride and for salt determined as chloride expressed as sodium chloride for boiled dried salted anchovies; fish sauce; salted Atlantic herring and salted sprat; salted fish and dried salted fish of Gadidae family of fishes; Sturgeon caviar. Foods for special dietary uses: Follow up formulas – Vitamin A palmitate (retinyl palmitate), Vitamin A acetate (retinyl acetate), Vitamin A (two AOAC methods), Vitamin E, Vitamin D, Thiamine, Riboflavin, Niacin, Vitamin B6, Vitamin B12, Pantothenic acid, Folic acid, Vitamin C, Biotin, Iron, Calcium, Phosphorous, Magnesium, Sodium, Chloride, Potassium, Manganese, Iodine, Selenium, Copper, Zinc, Total Nucleotides, Choline, Myo-innosi-tol, L-carnitine, Total amino acids (excluding taurine and tryptophan) and Tryptophan both for some selected uses specified in CXS 156 (2023 version), Total fatty acids, Crude Protein, Folic acid (addition of ISO 20631). All Foods: content of insoluble and soluble dietary fibres of higher and lower molecular weight (applicable in food that may, or may not, contain resistant starches (AOAC 2022.01/AACC 32-61.01/ICC Standard n° 191 as type I method) with note relating to the subtraction rule resulting from Codex definition of dietary fiber as deemed appropriate by the competent authority. Fruit juices and nectars: L-Ascorbic acid (4 methods), Citric acid (all uses), High Fructose Corn Syrup and Hydrolyzed Inulin Syrup (in apple juices as permitted ingredients), L-Malic Acid, Saccharin, Soluble solids, Sucrose, Phosphorous/Phosphate. Milk and milk products:amendment to the commodity standard on the moisture content to add whey powders to the list, Numeric Performance Criteria for methods used for the quantification of Copper and Iron. Miscellaneous products -Dried Meat: Chloride as sodium chloride; Food Grade Salt: Iodine (only for products fortified with Iodate) and Sodium Chloride and description of the determination of sodium chloride and related sampling method for food grade salt.
Revoked methods — Fish and fishery products (Salted Fish and Dried Salted Fish of the Gadidae Family of Fishes – CXS 167 (2018 version): Determination of salt content, Salt saturation. Follow up formulas: Vitamin A by colorimery (AOAC 974.29, Type IV), Iodine (milk-based formula, AOAC 992.224 by Ion selective potentiometry). All foods: previously mentioned methods for dietary fibers (AOAC 2011.25 and AACC Intl 32-50.1). Fruit Juices: Carbon dioxide (additives and processing aids) by IFU n°42, Malic acid by EN 1138.
Unchanged methods — Cereals, Pulses and Legumes and derived products: Quinoa – protein content (type IV) until further work discussed. Fruit Juices and Nectars: Malic acid (additives); Preservatives in fruit juices (sorbic acid and its salts). Milk and milk products: Whey powder — Water (moisture) noting that the water content is excluding the crystallized water which is bound to lactose (that part being generally known as the moisture content). Dried meat: Chloride as sodium chloride (≥ 0.25% or ≥ 1.0%).
Methods for further consideration until CCMAS45 with some amended during the IWG/CCMAS44 sessions – Chocolate and Chocolate Products: Cocoa butter (determined as fat); Milk fat; Moisture; Moisture (Determined as Water); Non-cocoa butter vegetable fat; Fat; Free fatty acids; Unsaponifiable matter; Cocoa butter equivalents in cocoa butter and plain chocolate; Cocoa butter Equivalents in Milk Chocolate; Determination of center and coating of filled chocolate (all methods approved for the chocolate type used for the coating and those approved for the type of center concerned). Cocoa powders (cocoa) ad dry cocoa-sugar mixtures: Moisture (Determined as Water); Determination of full-fat cocoa powder, fat-reduced cocoa powder, and highly fat-reduced cocoa powder; Determination of cocoa butter (to be developed). Follow-up formula: Riboflavin, Niacin (x2), Vitamin B6 (x2), Vitamin B12 (x2), Folic acid (x2), Biotin, Iron (x2), Calcium (x2), Phosphorous, Magnesium (x2), Sodium, Chloride, Potassium, Manganese, Selenium (x4), Copper, Zinc, Choline. Fruit juices and nectars: Benzoic acid and its salts – Sorbic acid and its salts, Benzoic acid and its salts, Sulphur dioxide alts, Sulphur dioxide (x3), Tartaric acid in grape juices, Total Nitrogen, Acetic acid (acetate), Alcohol (ethanol), Anthocyanins, Ash, Beet sugar, Benzoic acid, C13/C12 ratio of ethanol derived from fruit juices, Carbon stable isotope ratio (x2), Carotenoids (as total carotenoids and as individual groups), Centrifugable pulp, Chloride (expressed as sodium chloride), Chloride, Essential oils, Essential oils in citrus fruit, Fermentability, Formol number, Free amino acids, Fumaric acid, Glucose Fructose and Sucrose/Saccharose, Glycerol, Hesperidin and Naringin (x2), Hydroxymethylfurfural (x2), D-isocitric acid (x2), D- and L- Lactic Acid, L-Malic/Total Malic ratio to detect added D-Malic acid, pH value (x2), Proline, Relatice density (x2), Sodium Potassium Calcium and Magnesium, D-Sorbitol, Starch, Titratable acids, Total dry matter at 70°C, Total solids (by microwave oven drying), Vitamin C (dehydro-ascorbic acid and ascorbic acid). Fruit juices: Carbon stable isotope ratio of sugars from fruit juices. Apple Juice: High Fructose Corn Syrup and Hydrolyzed Inulin. Orange juice: Sugar beet derived syrups in frozen concentrated orange juice.
[vii] See https://ifu-fruitjuice.com/page/LCHP2
[viii] CCMAS44 recalled that CCMAS43 endorsed the method for determining protein in quinoa (ISO 1871) as Type IV, noting that the typing could be reconsidered should more information be provided. The VWG considered replies to CL 2024/91-MAS, but information provided at that time of the IWG met did not allow the VWG to find any consensus on retyping the ISO 1871 method as a type I method. During the VWG, another method was also offered as an alternative Type I method for the determination of protein in quinoa (i.e., ISO 20483), but it was noted a lack of specific validation data of that method for pseudocereals such as quinoa. The ISO representative informed the VWG that quinoa could be added in future as a validated matrix and that ISO might consider taking up that work if needed (based on an ISO member internal request and ISO working procedures). CCMAS44 extensively discussed the information submitted by seven countries from Latin America (Bolivia, Peru, Ecuador, Colombia, Chile, Uruguay, and Argentina), as presented in CCMAS44’s CRD19 document. Such information was recognised to be supportive of a retyping of the method ISO 1871 as Type I (official method). Information in CRD19 informed CCMAS44 on details about the validation studies and process, the reagents used, the conditions of the methods, the catalysts used, while noting that a single reference material for quinoa was also used during the validation studies. An explanatory footnote was proposed (e.g. regarding conditions, the catalysts and reagents used), noting that the same footnote would be consequentially applied to the ISO 1871 method for determining protein in Tehena to ensure consistency. It was also reiterated that CCMAS should apply the same decisions regarding the use of ISO 1871 for the determination of protein to Tehena to ensure consistency. Members and Observers which did not support the proposal expressed concerns that ISO 1871 was a general guidance and not a step-by-step method, since it did not specify conditions and chemicals. In accordance with the definition for a Type I method, a detailed analysis of the steps taken across the different validation studies would be necessary to retype ISO 1871 from Type IV to Type I, even though there was no issue with the validation data themselves. CCMAS44 agreed that this topic should be deferred to the PWG on endorsement that would meet immediately prior to CCMAS45 to allow more time to review CRD19.
[ix] The document provides additional information about the sampling plans referred to in the CXG 50, by providing examples for each of the main types of sampling plans, additional information on other sampling plans, including Bayesian plans, and links to the Apps for designing and evaluating such sampling plans. App 1 evaluates and designs sampling plans for homogeneous lots, which is included in the information document by link. Apps 2 and 3 were being developed and would be included in the information document once available. As more Apps are developed, links to these Apps would be included also in the information document. Other resources (e.g. video clips, webinars) would be provided to the extent possible on Codex website (such as the one held on April 28, 2025). As recommended during the two previous CCMAS sessions on this matter for including sampling plans involving smaller sample sizes or less testing, part 3 of the document includes presentation of Bayesian plans, based on risk- or utility-based approaches, while the overall rest of the document structure remained largely unchanged. CCMAS44 discussed an edited version of the information document, as included in CCMAS44’s CRD35. Some concerns were expressed by Japan about the inclusion of Bayesian plans in the information document, as the scope of current CXG 50 (2023 version) was restricted to acceptance sampling plans for inspecting isolated homogeneous lots (i.e., and therefore not using Bayesian approaches). It was clarified that Bayesian sampling plans provided a potential way to reduce testing costs and was an area of still on-going international scientific work, including within ISO, about which a technical report on applying Bayesian methods to acceptance sampling was expected to be published end 2025. It was also suggested that the information document may need to be complemented with information relating to the Codex Principles for the Use of Sampling and Testing in International Food Trade (CXG 83, 2015 version).
[x] CCMAS44 noted the NPC were developed for both adopted MLs and the lowest proposed residue levels in the relevant food matrices. It also reviewed the list of methods submitted by CCFA, including one recently published method added and provided a summary of the method validation data (in Appendix 3 of CCMAS44 working document CX/MAS 25/44/10) for assessment against the NPC. “Examples of applicable methods that met the established criteria” that met the NPC had been identified from Appendix 3 and were presented in Appendices 1 and 2 of CX/MAS 25/44/10. The revised versions were therefore presented in Appendix VI of CCMAS44 CRD02 Rev.1. It was highlighted that should CCFA decide to revise the lowest proposed residue levels, suitable analytical methods should be selected based on the information provided in Appendix III of CCMAS44 working document CX/MAS 25/44/10.
[xi] (a) Dr. Latimer, George W, Jr. (ed.), ‘Validation Procedures for Quantitative Food Allergen ELISA Methods: Community Guidance and Best Practices’, in Dr. George W Latimer, Jr. (ed.), Official Methods of Analysis of AOAC INTERNATIONAL, 22nd Edition (New York, 2023; online, AOAC Publications, 4 Jan. 2023). (b) EN 17855:2024 Foodstuffs – Minimum performance requirements for quantitative measurement of the food allergens milk, egg, peanut, hazelnut, almond, walnut, cashew, pecan nut, Brazil nut, pistachio nut, macadamia nut, wheat, lupine, sesame, mustard, soy, celery, fish, mollusks and crustaceans, CEN, 2024.
[xii] The proposed conversion factors for adoption were included in Appendix III of the CCMAS44 report. Nitrogen To Protein Conversion Factors For Commodities Approved By Commodity Committees Proposed For approval by CAC48 and Future Inclusion as an Annex to CXS 234: Animal Protein Source: Milk and milk products – 6.38; Meat and meat products – 6.25. Infant formula: The calculation of the protein content of infant formulas prepared ready for consumption should be based on N x 6.25, unless a scientific justification is provided for the use of a different conversion factor for a particular product. The value of 6.38 is generally established as a specific factor appropriate for conversion of nitrogen to protein in other milk products, and the value of 5.71 as a specific factor for conversion of nitrogen to protein in other soy products. Follow-up formula for older infants and product for young children: The calculation of the protein content of the final product ready for consumption should be based on N x 6.25, unless a scientific justification is provided for the use of a different conversion factor for a particular product. The protein levels set in this standard are based on a nitrogen conversion factor of 6.25. For information the value of 6.38 is used as a specific factor appropriate for conversion of nitrogen to protein in other Codex standards for milk products. In accordance with the Guidelines on nutrition labelling (CXG 2-1985), the calculation of protein for nutrient declaration purposes should be based on a conversion factor of 6.25, unless a different factor is specified in the present annex. Fish and fishery products: Crackers from marine and freshwater fish, crustaceans and molluscan shellfish – 6.25. Plant Protein Source: Wheat, wheat protein products – 5.71; Maize – 6.25; Quinoa – 6.25; Sorghum – 6.25; Millet (grains and flour) – 5.71; Gochujang – 6.25. Soya and non-fermented soybean products: 5.71; Tempe – 5.71; Natto – 5.71; Cheonggukjang – 5.71. Vegetable protein Products (VPP): Products produced by separation from wheat and soya grains and flours of certain non-protein constituents (starch, other carbohydrates) – 6.25. Soy protein products – 6.25. CCMAS44 noted that the list would continue to be updated as new nitrogen to protein conversion factors were agreed by commodity committees. It was also explained that in cases where such nitrogen to protein conversion factors had been developed by a committee adjourned sine die (or dissolved) and needed further review, the Codex Secretariat would look into some practical modalities for such a review.
[xiii] The document included in Appendix VI of CCMAS44 report is entitled “Harmonization of Names for Principles in CXS 234-1999” is composed of the following sections: 1. General Guidelines; 2. Definitions (Principle, Biological assay, Chromatography, Colorimetry, Gravimetry, Potentiometry, Sensory assay, Spectroscopy, Mass Spectrometry (MS), Titrimetry, Visual examination, Volumetry); 3. Criteria Used (3.1. Assays Whose Results are Method Dependent – e.g., Moisture at 105°C – Gravimetry, etc.; 3.2 Assays Whose Results are independent of the method – e.g., Nitrate – UV-Vis (ultraviolet visible) – Spectrophotometry, etc.); 4. Additional information (to consider removing any additional information such as “ashing”, “ceramic filter filtration”, etc.); Annex A — Principles of Methods of Analysis (e.g.; Anodic Stripping Voltammetry (ASV), etc.); Annex B – Acronyms and abbreviations (e.g., AAS Atomic Absorption Spectrophotometry; etc.); Annex C List of Acronyms for Standard Method References (e.g., AACC, USP, ISO, etc.); and the to-be-developed Annex D – List of Provisions. CCMAS44 also noted the view that the provisions in CXS 234 should remain aligned with those in the commodity standards to avoid misalignment and confusion. It was further emphasized that the provisions in CXS 234 reflected the original commodity standard provisions and should not be oversimplified as this could remove essential context. Some provisions indicated method complementarity and had been the subject of extensive discussions. Some of the proposed changes in Annex D carried significant implications. Therefore, consultation with commodity committees and other relevant committees was necessary and for better clarity future proposed changes would be presented in three groups: those requiring no changes or only editorial changes; those changes linked to active commodity committees; and those changes related to adjourned sine die or abolished commodity committees. The Codex Secretariat also clarified that, in general, CCMAS did not have the authority to make such changes to provisions falling within the remit of a Commodity Committee adjourned sine die (or abolished/dissolved). If necessary, such proposals should be referred to the CAC, as per the mechanism followed precedingly with the proposed amendment of a provision in section 3.3 of the Codex Standard for Edible Casein Products (CXS 290).
The BR Privacy & Security Download: June 2025
On May 5, 2025, the newest Commissioner of the Federal Trade Commission (FTC), Mark R. Meador, spoke at the Second Annual Antitrust Conference at George Washington University.
His prepared remarks offer insight into his approach to antitrust enforcement, addressing what he sees as common antitrust enforcement myths.
In dispelling the first myth—“antitrust is regulation”—the Commissioner is very clear: “Antitrust is law enforcement, period. Full stop.”
He similarly and succinctly rejects four other myths related to antitrust enforcement:
“Vertical integration is always procompetitive.” Commissioner Meador makes the contrary case that vertical integration is not always procompetitive, particularly in non-physical markets such as technology.
“Innovation can justify exclusion.” The Commissioner instead asserts the need to identify conduct that forecloses alternatives.
“We need national champions to compete with China.” The Commissioner suggests, to the contrary, that competition is better suited by free enterprise.
“Structural remedies are an extreme measure.” He counters that structural remedies can be a way to restore free markets.
Commissioner Meador concludes his comments with what might be seen as a policy warning, making clear that the current FTC’s interest in antitrust enforcement is not limited to technology platforms or “Big Tech,” but extends to every industry, including “groceries, healthcare, and energy.”
Additional Authors: Daniel R. Saeedi, Rachel L. Schaller, Gabrielle N. Ganze, Ana Tagvoryan, P. Gavin Eastgate, Timothy W. Dickens, Jason C. Hirsch, Adam J. LandyAmanda M. Noonan, and Karen H. Shin.
The Latest Changes to the Ontario Employment Standards Act, 2000
Several 2024 amendments to the Ontario Employment Standards Act, 2000 (ESA) will be implemented in summer 2025, and more new requirements will take effect starting in 2026. Below is a detailed overview of these changes, organized by their effective dates. Employers in Ontario may want to note these deadlines and update their processes and policies accordingly.
Quick Hits
Starting June 19, 2025, employees in Ontario with at least thirteen consecutive weeks of employment will be entitled to an unpaid leave of absence for up to twenty-seven weeks in a fifty-two-week period for serious medical conditions certified by a qualified health practitioner.
Effective July 1, 2025, Ontario employers would be required under the amended law to provide new employees with specific employment information in writing before their first day of work, including the employer’s legal name, the employer’s contact information, the employee’s work location, the employee’s starting wage rate, the company’s pay period, and the anticipated hours of work.
Beginning January 1, 2026, employers in Ontario with more than twenty-five employees are required under the amended law to disclose the range of expected compensation, disclose the use of AI in hiring, confirm if a job posting is for an existing vacancy, and are prohibited from requiring “Canadian experience.”
Changes Effective June 19, 2025
Long-Term Illness Leave
Under the amended law, employees with at least thirteen consecutive weeks of employment will be entitled to an unpaid leave of absence for up to twenty-seven weeks in a fifty-two-week period if they have a serious medical condition certified by a qualified health practitioner.
The law does not require that the weeks of leave be taken consecutively. Employees may extend the leave within the same fifty-two-week period by submitting another medical certificate if the condition extends beyond the initial duration noted in the original certification and the twenty-seven-week period has not yet been exhausted.
This new leave does not amend existing obligations under the Ontario Human Rights Code and any contractual leave entitlements or disability benefits plans and policies.
This new leave is in addition to the regular three-day sick leave, for which employees are not required to provide a medical note.
The newly amended law requires employers to retain related records for three years after the leave expires.
Changes Effective July 1, 2025
New Rules About Employment Information
Employers will now be required to provide new employees with the following information in writing, prior to the employee’s first day of work or as soon as reasonably possible thereafter:
the employer’s legal name (and operating or business name, if different);
the employer’s contact information (including address, telephone number, and one or more contact names);
the location from which the employee will be performing work;
the employee’s starting wage rate or commission, as applicable;
the applicable pay period/pay day; and
a general description of the employee’s anticipated hours of work.
This requirement does not apply to employers with fewer than twenty-five employees or to assignment employees.
Changes Effective January 1, 2026
Effective January 1, 2026, employers with more than twenty-five employees that are posting jobs are required to disclose the range of expected compensation and use of artificial intelligence (AI) in the hiring process and confirm whether the job posting is for an existing vacancy. The amended law prohibits employers from requiring applicants to have “Canadian experience.”
The amendments require employers that interview applicants for publicly advertised jobs to provide information about the status of the hiring process within forty-five days of interviews or, if the employer interviews applicants more than once, within forty-five days of the last interview.
Employers may want to ensure these changes are implemented by the relevant deadlines, and that the relevant policies are updated accordingly.
DJI Says “Bring It On” to U.S. Drone Security Scrutiny
In a surprising move, China-based DJI, the world’s largest drone manufacturer, is not flinching at the prospect of tighter U.S. restrictions on Chinese drone companies. In fact, they’re embracing it.
Currently, the Trump administration is finalizing executive orders that would affect the commercial drone landscape in the U.S., which could be set for a serious shake-up. These potential measures would require companies like DJI, and its competitor Autel, to undergo national security reviews before selling new drone models in the U.S.
You might think DJI would be sounding the alarm—but instead, they’re rolling out the welcome mat. “DJI welcomes and embraces any opportunities to demonstrate our privacy controls and security features,” explained a company spokesperson.
The company has been submitting its systems for independent security audits since 2017. Evaluations from heavyweights like Booz Allen Hamilton, FTI Consulting, and even U.S. government bodies like the Department of the Interior and Idaho National Laboratory have come to a consistent conclusion: DJI’s drones are secure, and there’s no evidence of data being transmitted to unauthorized entities—including the Chinese government.
The legal spotlight is now on Section 1709 of the FY2025 National Defense Authorization Act. This provision requires a designated national security agency to determine—within a year—whether DJI’s equipment presents an “unacceptable risk” to U.S. national security.
If that assessment isn’t completed within the deadline, DJI could end up on the FCC’s Covered List by default, effectively barring them from launching new products in the U.S.
So, yes, the stakes are high. But DJI seems ready to bet on its track record.
In response to longstanding concerns over data privacy and national security, DJI has introduced several robust features aimed at giving control back to users:
Local Data Mode: Operates like an air-gapped device—no internet, no data leakage.
Default Data Settings: No automatic syncing of photos, flight logs, or videos.
Third-party software compatibility: Users can fly DJI drones and analyze data using U.S.-based software, without touching DJI’s ecosystem.
DJI no longer allows U.S. users to sync flight records to its servers.
“Unlike our competitors, we do not force people to use our software,” DJI spokesperson pointed out.
While the upcoming executive orders are designed to boost domestic drone production and address national security risks, DJI is using the moment to double down on its commitment to transparency. Their message is clear: judge us by the tech, not the passport.
Whether that’s enough to maintain access to the U.S. market will depend on how these reviews play out—and how political winds blow in the coming months.
But one thing’s for sure: DJI isn’t backing down. It’s gearing up for inspection—and maybe even looking forward to it.
Stay tuned as we track legal developments on this issue and how it could reshape the drone industry in the U.S.
Competition and Consumer Law Round-Up June 2025
What’s Inside This Issue?
This edition of the K&L Gates Competition & Consumer Law Round-Up provides a summary of recent and significant updates from the Australian Competition and Consumer Commission (ACCC), as well as other noteworthy developments in the competition and consumer law space.
Key Developments in Environmental / Greenwashing Guidance and Enforcement
EnergyAustralia Settles Greenwashing Action Brought by Advocacy Group
AU$8.25 Million Penalty Ordered Against Clorox for Misleading Greenwashing Claims
Enforcement
Oil and Gas Company Qteq Found to Have Engaged in Cartel Conduct
Federal Court Orders Captain Cook Vocational College to Pay AU$30.4 Million in Penalties for Unconscionable Conduct and Misleading Representations
ACCC Commences Proceedings Against Retailer City Beach for Noncompliant Button Battery Products
Mergers and Acquisitions
ACCC Raises Concerns With Rural Merchandiser Elders’ Proposed Acquisition of Delta
Qube’s Acquisition of MIRRAT Not Opposed by ACCC
Notifications and Authorisations
ACCC Proposes to Grant Authorisation to Australian Payment Network to Facilitate Wind Down of Cheque Industry
Noteworthy Developments
Mandatory Information Standard for Toppling Furniture Brought into Effect
Click here to view the Round-Up.
Climate Lawsuit Against German Energy Company Dismissed by Court
Last week, a long-running lawsuit brought against a major German energy company by a Peruvian farmer for alleged damages stemming from climate change was dismissed by an appellate court in Germany. The court’s reasoning focused on the inability of the plaintiff to prove damages, highlighting the difficulty of this aspect of the various climate tort litigations for plaintiffs–and, indeed, this legal point has featured prominently in a number of defenses to these lawsuits (especially in the United States).
Nonetheless, the environmental groups backing the lawsuit claimed victory–at least to a degree–as the case could be interpreted as establishing the principle that emitters of greenhouse gases could ultimately be held liable for damages attributable to climate change, even if this particular action failed to satisfy the applicable legal standard. While it is true that this general legal principle could be invoked in other litigation in the future, environmental lawsuits will still need to be able to prove specific damages that were caused by climate change, which–as this case demonstrates–is a stringent standard to satisfy. Any future plaintiff would have to be selected delicately and deliberately, with this standard in mind–and it is not at all clear that such a suitable candidate for a legal action would be found. Simply stated, the fact that the court found that the plaintiff in this action–a homeowner whose building could be washed away if a dam formed by a glacier collapses due to warming temperatures–had insufficient proof to prosecute this claim will likely discourage (to some degree) similar lawsuits in the future.
RWE AG, one of Europe’s top carbon polluters, won dismissal of a case brought by a Peruvian farmer who tried to hold the German energy giant liable for its impact on climate change. An appeals court in Hamm on Wednesday said that while national law allows a single company to be targeted for its share of climate-related damage, not all the necessary requirements were met in this suit against RWE.
www.bloomberglaw.com/…
Canada Pauses Mandatory Climate Disclosure Rules
Recently, the Canadian Securities Administrators (the umbrella organization of Canada’s provincial securities regulators) announced that it would pause the development of certain sustainability reporting initiatives, including a proposed mandatory climate-related disclosure rule.
This development is emblematic of an overall retreat from mandatory climate disclosures and similar rules that has occurred over the past several months, stemming in large part from recent political developments in the United States, which have discouraged a climate focus in the financial context. As further evidence of this trend, the EU has begun to retreat from its sustainability reporting through the “Omnibus” process, which is delaying and reducing the scope of CSRD disclosures, and, in perhaps the paradigmatic example, the SEC has abandoned entirely the mandatory climate disclosure rule that it had promulgated under the Biden Administration.
Nonetheless, this trend should not be overstated. Certain key regulators from economically-important jurisdictions–including the State of California–are proceeding vigorously in promulgating mandatory climate disclosure rules and similar regulations. And the “pause” recently announced by the Canadian regulators is not an abandonment of this area of regulation, as this process could easily restart when circumstances change.
Canada’s securities regulators announced that they are pausing their work on the development on key sustainability reporting initiatives, including a new mandatory climate-related disclosure rule and amendments to diversity-related disclosure requirements. According to the Canadian Securities Administrators (CSA), the umbrella organization of Canada’s provincial and territorial securities regulators, the move to pause the development of new sustainability reporting requirements is being made “to support Canadian markets and issuers as they adapt to the recent developments in the U.S. and globally.” The announcement follows a series significant changes in the sustainability reporting landscape in major markets, with the EU in the midst of its “Omnibus” process to delay, reduce the scope and simplify disclosure requirements under its CSRD legislation, and the U.S. Securities Exchange Commission in the process of entirely abandoning its climate-related reporting rules.
www.esgtoday.com/…
Northern Ireland: Gender Pay Gap Reporting
In February 2025, the Department for Communities in Northern Ireland closed a public consultation that began late last year on the proposed introduction of a requirement for Northern Ireland employers to report on their gender pay gap.
Quick Hits
Unlike England, Scotland, and Wales, Northern Ireland’s employment law is devolved, meaning the existing United Kingdom gender pay gap reporting requirements for employers with 250 employees or more do not extend to Northern Ireland.
In February 2025, the Department for Communities in Northern Ireland concluded a twelve-week public consultation on proposed requirements to report on differences in the pay of male and female employees, i.e., the gender pay gap.
The Employment Act (Northern Ireland) 2016 introduced the concept of gender pay gap reporting in Northern Ireland, in addition to ethnicity and disability pay gap reporting and the publication of pay gap action plans. However, for much of the three-year period from 2017 until 2020, the Northern Ireland Assembly was suspended following a breakdown in power-sharing, meaning the act was not brought into force.
The proposed regulations set out in the department’s consultation document would require organisations with 250 or more employees to report annually on their gender pay gap information. However, this employee threshold is currently under review. It is proposed that in their annual pay reports, employers would need to include the mean and median gender pay gap statistics using a “snapshot date” to lessen the effects of fluctuations in the workforce. This currently follows the definition from the Office for National Statistics used in England, Scotland, and Wales, which uses an annual snapshot date of April 5 and allows results to be directly comparable. The methodology and process of calculating the gender pay gap reports are also under review.
If the proposals are adopted, employers that identify a gap must publish an action plan detailing the steps they are taking to address the gender pay gap within their organisation. The department has outlined that it does not intend to set specific requirements for the content of action plans. Instead, the department encourages employers to develop plans that align with the scale of their gender pay gap. The department also said that these plans should address the contributing factors and outline the steps being taken to address the causes that fall within the employer’s control. Employers are required to provide the action plan to all employees and trade unions, if possible.
The department states that the aim of the proposed obligations is to:
identify gender pay gaps,
analyse the drivers behind them,
explore the extent to which an employer’s policies and practices may have contributed to the gaps, and
take remedial action.
In England, Scotland, and Wales, the UK government is currently consulting on whether to extend a similar reporting framework to gender pay gap reporting for ethnicity and disability reporting. Northern Ireland also seeks to impose similar obligations for ethnicity and disability reporting, although the details of these obligations have not been set out at this stage. It is likely that a reporting framework in Northern Ireland may operate slightly differently to take into consideration Northern Ireland’s existing mandatory employee monitoring obligation regarding community background.
What’s Next?
The consultation document indicates an intention to publish draft regulations as soon as possible, but the regulation is not expected to take effect before 2027. Employers may want to prepare for the required reporting obligations sooner and could consider undertaking some pay gap analysis work mirroring the existing obligations in England, Scotland, and Wales to identify whether there are any areas that require further scrutiny.
This consultation comes as part of a broader move towards requiring employers to be more transparent about pay and pay gaps. In the European Union, Directive (EU) 2023/970 (the EU Pay Transparency Directive) sets a high standard for pay transparency and pay gap reporting across the EU and is currently undergoing implementation by member states, with some countries such as the Republic of Ireland proposing to go beyond the directive’s minimum requirements.
DHS: Cameroon TPS Will Terminate Effective August 3
Cameroon’s Temporary Protected Status (TPS) designation will expire Aug. 3, 2025.
On April 14, 2025, Department of Homeland Security (DHS) Secretary Kristi Noem announced that she will not renew Cameroon’s TPS designation.
While the work authorization documents of Cameroonian TPS beneficiaries were not automatically extended beyond Dec. 7, 2024, Cameroonian TPS beneficiaries were eligible for a 540-day extension from the facial expiration dates on their work authorization documents.
A Federal Register notice means that TPS-based work authorization documents will also expire Aug. 3, 2025.
Supreme Court Reverses Lower Court Order Pausing Termination of CHNV Parole Program
On May 30, 2025, the Supreme Court of the United States issued an order granting the Trump administration’s application to stay a lower court order temporarily halting the rescission of the Cuba, Haiti, Nicaragua, and Venezuela (CHNV) parole program. This order allows the administration to resume implementation of this rescission while court challenges continue through the appeals process.
Quick Hits
On May 30, 2025, the Supreme Court granted the Trump administration’s request to stay a lower court order that had temporarily halted the rescission of the Cuba, Haiti, Nicaragua, and Venezuela (CHNV) parole program, allowing the administration to resume its implementation.
The Supreme Court’s decision reinstates DHS’s initial notice, potentially invalidating employment authorization documents (EADs) under the CHNV parole program, regardless of their listed expiration dates.
Employers may need to identify and reverify the employment authorization of impacted employees due to the revocation of the CHNV parole program.
Background
Section 212(d)(5)(A) of the Immigration and Nationality Act authorizes the secretary of homeland security, at the secretary’s discretion, to “parole into the United States temporarily under such conditions as he [or she] may prescribe only on a case-by-case basis for urgent humanitarian reasons or significant public benefit any alien applying for admission to the United States.” Parole allows noncitizens who may otherwise be inadmissible to enter the United States for a temporary period and for a specific purpose.
The Biden administration implemented a temporary parole program for Venezuelans in October 2022, and later expanded the parole program to include Cubans, Haitians, and Nicaraguan nationals in January 2023. Individuals within this program may apply for an Employment Authorization Document (EAD) in the (c)(11) category. The Biden administration announced in October 2024 that it would not extend legal status for individuals who were permitted to enter the United States under the CHNV parole program but encouraged CHNV beneficiaries to seek alternative immigration options.
On March 20, 2025, the U.S. Department of Homeland Security (DHS) published a Federal Register notice announcing the immediate termination of the CHNV parole program. The termination was set to take effect within thirty days of the date of publication of the notice, or April 24, 2025. On April 14, 2025, U.S. District Court Judge Indira Talwani issued a nationwide order staying or temporarily suspending the implementation of this categorical termination of the CHNV parole program. On May 5, 2025, the First Circuit Court of Appeals denied the Trump administration’s request for a stay of Judge Talwani’s ruling. The administration promptly appealed to the Supreme Court.
Analysis and Impact
The Supreme Court’s order reverses the lower court’s temporary pause on the rescission of CHNV parole but does not address the rescission’s merits. Nevertheless, DHS may now proceed with its revocation of CHNV parole as litigation on the merits continues.
The Court’s decision effectively reinstates DHS’s initial Federal Register notice, which in part states that any employment authorization derived through the CHNV parole program was scheduled to terminate on April 24, 2025. Persons with employment authorization documents (EADs) in the (c)(11) category under the CHNV program may no longer have valid work authorization, regardless of the expiration date listed on the EAD itself.
We expect DHS to provide further clarity as to how it intends to proceed with implementing revocation of CHNV parole and how employers should proceed, but based on DHS’s guidance prior to the district court’s initial hold, employers may be required to identify impacted employees and reverify employment authorization.
Identifying which employees are impacted by this change can be challenging, since the public interest parolee EAD category code (c)(11) is typically not entered in the I-9 form or other personnel records.
UK Government Announces Proposals for Reforming Immigration System
On 12 May 2025, the UK government published the white paper, “Restoring Control over the Immigration System,” which proposes several significant changes to UK immigration policy aimed at reducing net migration and tightening immigration controls.
Quick Hits
The UK government has published a white paper which proposes significant changes to the immigration rules, including a 32 percent increase in the Immigration Skills Charge.
The proposed changes include extending the qualifying period for Indefinite Leave to Remain under the Skilled Worker route from five to ten years and raising the minimum skill level to RQF Level 6.
The Graduate visa period is proposed to be reduced from two years to eighteen months, prompting employers to consider switching Graduate visa holders to the Skilled Worker route to avoid higher fees.
Prime Minister Keir Starmer announced the proposed changes in response to record-high migration levels, with net migration having quadrupled in 2023.
The proposed changes are not immediate and will need to be assessed and debated in Parliament before any changes come into effect. In this article, we summarize the key proposed changes specifically in relation to the Skilled Worker and the Graduate visa routes.
Increased Immigration Skills Charge
The Immigration Skills Charge (ISC) is proposed to increase by 32 percent in line with inflation. This will be the first time the ISC fee has been increased since its introduction in 2017.
For small sponsors, this would increase from £364 to £480 per year. For medium/large sponsors, this would increase from £1,000 to £1,320 per year.
Qualifying Period for Indefinite Leave to Remain
Under the current rules, those under the Skilled Worker route can apply for indefinite leave/settlement after five years’ continuous residence in the UK, subject to meeting the requirements. The proposal looks to extend this to ten years, though there may be an opportunity to reduce the qualifying period based on unspecified “Points-Based contributions to the UK economy and society.” At this stage, it is not clear what this entails, and further details should be issued in due course.
The white paper does not provide a detailed roadmap for handling transitional cases, and it is not yet clear whether those who have already started their five-year Indefinite Leave to Remain (ILR) journey will be exempt from the new ten-year requirement.
Skilled Worker Route
Raising the Skill Level
The proposal aims to raise the minimum skill level for Skilled Worker roles to RQF Level 6 (i.e., graduate level).
Under the current rules, Skilled Worker roles can be sponsored at RQF Level 3 (i.e., A-level equivalent). The skill level was lowered by the UK government in 2020 which led to a large increase in work visas and concerns with an overreliance on international recruitment, rather than sourcing talent from within the United Kingdom. The increase aims to address the government’s “concerns about exploitation of overseas recruits.”
The paper confirms the raised threshold will apply to new Skilled Worker applicants. Existing Skilled Worker visa holders can continue to extend their visa, change employment, and take supplementary employment in currently eligible occupations below RQF 6.
Raising the Salary Threshold
The proposal confirms the salary thresholds under the Skilled Worker route will increase. Details have not been provided yet on the new thresholds.
Abolishing the Immigration Salary List
The Immigration Salary List, which provides a salary discount to eligible occupation codes, will be abolished. The government has asked the Migration Advisory Committee (MAC) to review the current salary requirements and discounts to ensure salary thresholds reflect the new changes to the immigration system.
English Language Requirement
The following changes are proposed for the English language requirement:
For main applicants under the Skilled Worker route, the minimum English proficiency level will increase from B1 (intermediate) to B2 (upper-intermediate).
The English language requirement will extend to adult dependants at a reduced level. They will need to meet a minimum of A1 (basic user) level and will be required to show progression for visa extensions (to A2 level) and settlement (to B2 level). Under the current rules, dependants are not required to meet the English language requirement.
Graduate Visa Holders
It is proposed that the Graduate visa period will be reduced from two years to eighteen months.
Given the proposed fee increase and salary threshold changes to the Skilled Worker route, employers may wish to consider switching those on a Graduate visa to the Skilled Worker route as soon as possible to avoid paying higher application fees which could be implemented this year.
Next Steps
At present, there is little detail on the proposed changes. In light of the recent proposals, particularly those affecting the Skilled Worker route, employers may wish to consider the following practical steps:
Reviewing workforce needs: Consider conducting an internal audit and aim to identify roles that are currently filled or may be filled by Skilled Worker visa holders. An assessment may be made on how the proposed reforms (e.g., higher English language and skill levels) could affect future recruitment needs.
Having clear lines of communication with existing Skilled Worker visa holders: Consider assessing the potential impact on current sponsored workers and provide reassurance regarding the actions they plan to take to mitigate any negative effects if the proposals are implemented.
Reviewing current recruitment strategies: Where practicable, consider expediting the recruitment and sponsorship of Skilled Workers before the increased fees take effect.
Reviewing recruitment budgets: Consider preparing for the potential increase in visa application fees and overall costs associated with sponsoring Skilled Workers.