A selection of customs regulatory developments (EU, Belgium, France, the Netherlands, Luxembourg) over the past 7 days. A Customs Conform IT publication.
European Union
Regulation (EU) 2025/40 replaces Directive 94/62/EC and applies directly in all Member States, with no national transposition required. Taking effect immediately are the recyclability requirement, restrictions on PFAS in food-contact packaging — with no transitional period, including for packaging manufactured before that date — and a combined cap of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium. The remaining obligations, notably labelling, recycled content and reuse, remain phased in through to 2030. Read more
Published in the Official Journal on 10 August, Implementing Regulation (EU) 2026/1904 of 7 August imposes definitive duties of 6.1 % to 13.3 % depending on the Korean exporting producer, and of 24.1 % on all imports from Mexico. It also provides for the definitive collection of the provisional duties applied since 11 April 2026. The EU market concerned is estimated at EUR 1.4 billion. Read more
Also of note: the ICS2 system was unavailable from 7 to 12 August, disrupting entry summary declarations, vessel arrival notifications and temporary storage declarations, with services fully restored and the backlog cleared on 12/08; under the 21st sanctions package, the transaction ban was extended to a further 33 Russian credit and financial institutions, financial messaging services included (13/08).
Belgium
The National Forum published the minutes of its 25 June meeting. On the agenda: progress of the working group on temporary storage declarations and transfers between temporary storage facilities, progress of the working group on customs value, information on the EUR 3 flat-rate duty applicable since 1 July 2026, and locations and location codes. Read more
France
The DGDDI confirms that no change is required in the completion of the customs declaration in Delta IE. Most obligations apply upon release for free circulation, while Article 18(2) applies as soon as goods enter the customs territory. Packaging must be accompanied by an EU declaration of conformity, kept available to market surveillance authorities together with the technical documentation. Customs is not the market surveillance authority for this legislation, but may suspend release of the goods in order to refer the matter to the competent authority — in France, the Directorate-General for Risk Prevention. Read more
Also of note: 243.35 kg of cocaine seized on board a lorry by the Orléans and Bourges units (13/08), a sign that control pressure on road freight is being maintained.
The Netherlands
Since 1 July 2026, declarants of e-commerce goods have been liable for import duties to Dutch customs. Customs now verifies that declarants hold both a deferment of payment authorisation (DPO) and a comprehensive guarantee authorisation (CGU). Without both authorisations, lodging the declaration is not possible. Read more
Also of note: more than 20.7 million cigarettes, 3,000 kg of waterpipe tobacco and raw tobacco materials were intercepted in a series of coordinated operations, on the excise side (13/08).
Luxembourg
No significant developments this week.
Key takeaways this week
- Packaging: since 12 August, any operator placing packaging on the Union market must be able to produce an EU declaration of conformity and the associated technical documentation. The risk is not declarative — the customs declaration itself is unchanged — but lies in a possible suspension of release where the market surveillance authority is called upon. Food-contact packaging warrants particular attention, as the PFAS restriction applies with no transitional period.
- E-commerce: guarantees are becoming the operational bottleneck. In the Netherlands, the absence of a deferment of payment or comprehensive guarantee authorisation simply prevents a declaration from being lodged. Operators declaring low-value consignments since 1 July would do well to audit their authorisation portfolio and the sizing of their reference amount.
- Anti-dumping measures: importers of Korean or Mexican terephthalic acid should verify the accuracy of the declared origin, the TARIC additional code matching the exporting producer, and the impact of the definitive collection of provisional duties since April.
- Declaration continuity: the five-day ICS2 outage is a reminder of the value of written and tested fallback procedures. Without a documented contingency mode, a prolonged outage translates into detained goods and temporary storage costs.
- Sanctions: the extension on 13 August of the transaction ban to a further 33 Russian financial institutions, financial messaging services included, warrants a fresh screening of counterparties and payment flows linked to export operations.