The European customs reform is not a plan: it has begun. Since 1 July 2026 the €150 duty relief has gone, and a flat duty applies to low-value consignments. The rest — a single data platform, a new trusted-operator status, and liability shifted onto marketplaces — rolls out until 2034. Here is how we read that shift, and what it calls for now.
Many businesses still speak of the reform in the future tense. On the e-commerce side that is a calendar error — and it is already costing money.
Council Regulation (EU) 2026/382 of 11 February 2026 removes the customs duty relief that applied to consignments with an intrinsic value below €150. Designed when such consignments were marginal, that relief had become the entry point for roughly a billion parcels a year, with the effects everyone knows: undervaluation, artificial splitting of orders, and competition skewed against European sellers, who do pay the duty.
Article 2 of the regulation sets a duty of €3 per item, from 1 July 2026 to 1 July 2028, for consignments not exceeding €150. But it applies in two cases only: where the import is VAT-exempt under the Import One-Stop Shop (IOSS), or where the goods are in a postal consignment.
Outside those two cases the Common Customs Tariff applies, in full granularity. In other words: not being registered for IOSS does not avoid the flat duty — it moves you into a heavier regime, not a lighter one.
The legislator anticipated the opposite temptation too. Article 3 requires the Commission to assess, from 1 October 2026 and monthly thereafter, whether trade is being diverted — notably from IOSS to non-IOSS — and to propose, where appropriate, extending the flat duty to all consignments under €150. Avoidance structures built today have a life expectancy measured in months.
Three euros per item: the measure looks trivial, and that is how it was reported. It is not what we see on live files.
What changes is not the tariff, it is how the transaction is characterised. Is a sale a distance sale of imported goods, or an importation by an established operator? The answer does not turn on commercial intent but on objective facts and their sequence in time: at the moment the payment is accepted, where are the goods, and who is the buyer?
Our reading: this is a reform of evidence far more than a reform of tariffs. What the authorities will test is the timestamping — order, payment, release for free circulation — and the consistency between your systems. A characterisation your data cannot demonstrate will not hold, even when it is correct.
This is the sector the reform hits first, and logically so: it is the one that made the old system untenable.
Marketplaces answer for duty and VAT at the point of purchase. Consumers no longer face surprise charges on delivery, and the authorities gain a single, solvent counterparty. The centre of gravity of liability moves.
For low-value consignments, thousands of nomenclature headings collapse into four categories. A real simplification — which shifts the difficulty onto assigning the right category.
Optional since 1 July 2026, mandatory from 1 November 2026. Supplying them voluntarily in the meantime lets you run in your data chains without exposure to penalties.
Our reading: for fulfilment and e-commerce logistics operators, the question is no longer whether duty is due, but who declares, on whose data, and who answers for its accuracy. That is settled in contracts and in information flows — not at the point of clearance.
Thirty years of European customs law can be summed up like this: common rules, applied by twenty-seven administrations, with twenty-seven practices and twenty-seven IT systems. That is what the agreement of 26 March 2026 attacks.
A European body responsible for Union-wide risk management and for cooperation with the other agencies. It will be based in Lille.
What it moves risk analysis stops being a strictly national matter: targeting runs on European data, against common criteria.
A single European platform, set to replace national systems. Data is filed once and holds good across the Union, instead of being re-keyed declaration after declaration.
What it moves the declaration stops being the unit of control. Permanent, comparable data becomes it.
A category of highly transparent operators, able in certain cases to release goods into free circulation without active customs intervention.
What it moves customs no longer checks the consignment; it checks the system that produces it, and the quality of the data it emits.
E-commerce moves into the Data Hub first. What happens there will serve as the test bed for everything else.
Opening on a voluntary basis. This is the window to enter on your own terms rather than under compulsion.
Full rollout. By then the old national declarative world will have ceased to exist.
Our reading: Trust and Check is not a file to assemble, it is an information system to put in order. AEO asks you to demonstrate that you control your processes; Trust and Check asks you to open your data on a continuous basis. A business that keeps its customs compliance in spreadsheets and e-mails will struggle to qualify, even where its declarations are correct. And because the work touches the ERP as much as customs, AEO is the way in: already certified businesses will treat the new status as an extension; the others will meet the full set of requirements all at once.
To our mind this is the heaviest question in the whole reform, and the least discussed. It is not about the rule, but about the raw material the rule is applied to.
Follow a single customs data point — a commodity code, an origin, an intrinsic value. It is often created by a seller established outside the Union, picked up by a marketplace, passed to a freight forwarder, reused by a customs representative, entered on a declaration, then taken up again by a carrier. Six pairs of hands, and not one substantive check. Each simply passes on what it received.
The law does not dilute liability in the same way. The declarant remains liable for the customs debt — including for data it did not produce, has no means of verifying, and whose real source it frequently does not know. That gap between who produces the data and who answers for it is currently absorbed by sheer volume. It will not be.
As long as each declaration stood alone, an inconsistency between two consignments was practically invisible. On a single platform, the same product reference declared under two different headings, or two different origins, shows up at once — and not only at your end: at every operator that handled it.
The product identifiers that become mandatory on 1 November 2026 are the first stone in that structure: they make it possible to tie a data point back to whoever issued it, merchant or manufacturer. That is exactly what data traceability means.
Our reading: customs compliance stops being a matter of correct declarations and becomes a matter of a certification chain for the data. The question to ask today is not "are my declarations correct?" but "can I show where each data point I declare comes from, and who answers for it?" That is built in contracts, in written undertakings obtained from marketplaces and suppliers, and in system traceability — not at the point of clearance, and not in 2034.
We do not merely state the problem. CUSTOMS CONFORM IT is working alongside e-Origin on a project addressing the certification of customs data exchanged between the actors in the chain — seller, marketplace, customs representative, administration.
It follows naturally from what we see on live files: until data is certified at source, everyone keeps answering for what they did not produce.
2028 sounds distant. The work that has to be done by then is not.
B2C or B2B, IOSS or non-IOSS: the applicable regime is being settled now, and this is what controls will target. A flow mischaracterised since July 2026 gets corrected across the whole period.
Classification, origin and value stop being entries on a declaration and become data that is consultable and comparable from one consignment to the next. An inconsistency that used to pass unnoticed will be visible immediately.
On recurring flows, Binding Tariff Information or Binding Origin Information (Article 33 UCC) turns an arguable position into one enforceable against the administration.
It is the way in to Trust and Check, and the only item on this list that takes several months of audit and remediation before the application is even filed.
Who is the declarant, who is the importer, who warrants the accuracy of data supplied by a third party, and who bears the cost when it is wrong: those allocations were drafted under the previous regime, when data was disposable. Obtaining written undertakings from marketplaces and suppliers on product identifiers, classification and origin is this year's contractual work.
The reform changes how customs controls. It changes neither what it controls, nor the fact that control looks backwards.
Three questions will go on deciding the amount due, and driving most of the litigation: tariff classification, which governs the rate but also licences and trade defence measures; origin, non-preferential (Article 60 UCC) or preferential (Article 64) — and it is the evidence that makes files collapse; and customs value, transaction value as the rule (Article 70), failing which the secondary methods of Article 74, in a prescribed order.
On import it is not the administration that calculates what you owe: you declare it, and the accepted declaration gives rise to the customs debt. The control comes afterwards. Article 103 UCC sets the limit: the debt can no longer be notified more than three years after it was incurred — a period extended where the debt results from an act liable to criminal proceedings, under the conditions laid down by national law.
Hence the true measure of the risk: a classification or origin error is never isolated. Repeated on every consignment, it is recovered across all the flows of the period. A few percentage points on one tariff heading becomes a five- or six-figure assessment.
Before any decision adverse to you, the administration must communicate the grounds on which it intends to base it and let you put your point of view (Article 22(6) UCC). It is the last chance to change its mind before it commits itself in writing.
Many businesses answer in a few lines by e-mail, without realising that this letter fixes their position for everything that follows — administrative appeal, then court proceedings under the General Law on Customs and Excise of 18 July 1977. If you have received such a document, that is the moment to call. Not afterwards.
Raphaël Van de Sande served as conseiller-chef de division (division head) at the Belgian federal finance ministry, in the AGD&A — the customs and excise administration. He worked in AEO audit, declaration management and customs marketing: he knows how a file is read from the other side of the counter, where an officer stops, and what makes an application succeed or fail.
He now teaches at HEC Liège, on the specialised master's in tax law and on the fundamentals of customs and excise legislation, and sits on the steering committee of the Customs & Trade Law Academy — the centre created by HEC Liège and the Faculty of Law of the University of Liège. He also represents the private sector in the regional customs forums of the Liège – Luxembourg Directorate.
That combination is what the reading above rests on: the rule as it is written in Brussels, and the rule as it will be applied in a Belgian customs office. The two never quite coincide, and it is in that gap that files are won and lost.
We do not provide representation in court. Where a file moves into judicial litigation or customs criminal proceedings, we work with specialist lawyers, bringing them the technical analysis: classification, origin, value, and the mechanics of the procedure at issue.
That is often where a case is won. Counsel carries the procedure; the customs position they defend still has to be technically right, and evidenced.
Wondering what the reform changes for your flows? That is precisely the question we handle: where you stand today, what has already changed, what changes next and by when, and where to start.
Tell us about your flows →