What changed for EU importers of US-originating goods on 1 July 2026?

Article 59a of the Union Customs Code Implementing Act took effect. To claim the adjusted customs duties or tariff quotas under Regulation (EU) 2026/1455, importers must now prove the non-preferential US origin of the goods and that the goods were transported directly to the EU, or remained under customs supervision without alteration during transit through a third country.

Is a statement of origin on the commercial invoice still sufficient?

Not on its own. There is no prescribed form of proof and the free-evidence principle applies, but the European Commission has confirmed that an invoice statement, or a conventional certificate of origin, does not automatically establish entitlement to the adjusted duties. Supporting evidence is required.

What happens if the US exporter cannot provide evidence of origin or direct transport?

The adjusted customs duties cannot be claimed and the goods are dutiable at the standard rate. This is why the evidence should be requested from the exporter as part of the purchasing process rather than at the point of clearance.

Does the removal of the US de minimis exemption affect low-value shipments from the EU?

Yes. Consignments that previously entered the United States without a formal declaration now require one, regardless of value. Commodity codes, product descriptions and delivery terms need to be accurate for every shipment, not only for high-value ones.

Who is liable if a declaration turns out to be incorrect?

The importer is liable, and where a customs representative acts in indirect representation, that representative is a debtor for the customs debt as well. Both parties should agree in advance which records each will hold and for how long.

News & Trends

Smart Customs Management as a Competitive Advantage in EU–US Trade

For companies trading between the EU and the United States, customs is no longer a compliance formality. It now shapes delivery performance, duty exposure and working capital.

Patrick Möller

August 26, 2026

EU–US trade illustration showing air and sea freight, customs documentation and compliance between the US and EU

Changes to tariffs, origin requirements and import procedures have moved customs much closer to the commercial result. A rate that applied last quarter may not apply when the goods arrive, and the evidence needed to secure a reduced rate increasingly sits with the supplier.

Companies that manage customs proactively are gaining ground. They see costs earlier, clear goods more predictably and adapt faster when rules move. It is the shift DHL is putting on the agenda at the TradeConnect Summit in Chicago on 16 September.

What are the changes in the EU–US trade?

Three developments explain most of the friction companies are currently experiencing.

1. Rules are changing faster than planning cycles

Both the EU and the United States have adjusted duties, origin requirements and procedures repeatedly over the past year. Customs planning has to be continuous rather than an annual exercise.

2. Origin has become a procurement topic

Since 1 July 2026, companies claiming the adjusted EU duties on US-originating goods must demonstrate non-preferential origin and direct transport to the EU. Neither is established by a statement on the commercial invoice alone, so the evidence has to be agreed with suppliers before goods ship. Origin management has effectively moved out of the customs department and into procurement.

3. Poor data now carries a price

With the US de minimis exemption removed, consignments that once moved with minimal formality require a full declaration. Vague product descriptions, outdated commodity codes and incomplete documentation translate directly into holds and cost.

Where do companies lose time and money?

Trade disruption makes the headlines, but the larger hidden cost usually comes from routine inefficiencies:

incomplete or insufficient proof of origin
incorrect or undocumented customs valuation
poor master data quality
unclear allocation of liability between importer and customs representative

Valuation deserves particular attention: assists, licence fees and retrospective transfer pricing adjustments are rarely visible on an invoice, and every increase in a duty rate multiplies the cost of getting the value wrong.

So does liability. Where a customs representative acts in indirect representation, it becomes a debtor for the customs debt alongside the importer, so an origin claim that cannot be substantiated becomes a shared exposure.

What does proactive customs management look like?

The answer is not more customs staff. It is better data, available earlier, and a few measurements that make performance visible. Greg Nichols, SVP Customs Solutions at DHL Global Forwarding, describes three areas where this pays off in this short clip.

1. Treat customs data as master data

Classification, origin and valuation should be decided once per product and documented, not reconstructed for each shipment. Held centrally, they make it possible to identify affected products and suppliers within hours of a rule change.

2. Understand duty exposure before goods move

Assessing duty during sourcing rather than after clearance gives real control over landed cost. It also surfaces preferential treatment a company is entitled to but has never claimed, usually because the supporting data was incomplete.

3. Measure customs performance

Clearance time, hold rate, amendment rate and duty paid against duty due are all measurable. The numbers typically show that companies moving comparable goods through the same port clear at very different speeds, and that the causes sit upstream in supplier data rather than at the border.

How does customs become a supply chain advantage?

Where customs is predictable, the benefits are felt well beyond the declaration:

faster and more reliable product flows
planning that holds because clearance windows are known
tighter control of landed cost
lower compliance and audit risk
the ability to respond to policy change in days rather than months

The aim is not to remove customs complexity, but to stop it producing operational surprises.

Join the discussion in Chicago

If you have a presence in North America, DHL is hosting the TradeConnect Summit 2026 on 16 September at the DHL Innovation Center in Chicago, bringing together trade, customs, procurement and supply chain leaders to explore this shift from compliance burden to supply chain advantage.

If you would like to review your EU–US customs flows before then, our specialists are available to help. Gerlach has focused on customs and nothing else for more than 140 years, with over 1,000 experts across 27 countries and no ties to any carrier or freight forwarder.

Request Your Invite

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Table of contents

FAQs

What changed for EU importers of US-originating goods on 1 July 2026?
Article 59a of the Union Customs Code Implementing Act took effect. To claim the adjusted customs duties or tariff quotas under Regulation (EU) 2026/1455, importers must now prove the non-preferential US origin of the goods and that the goods were transported directly to the EU, or remained under customs supervision without alteration during transit through a third country.
Is a statement of origin on the commercial invoice still sufficient?
Not on its own. There is no prescribed form of proof and the free-evidence principle applies, but the European Commission has confirmed that an invoice statement, or a conventional certificate of origin, does not automatically establish entitlement to the adjusted duties. Supporting evidence is required.
What happens if the US exporter cannot provide evidence of origin or direct transport?
The adjusted customs duties cannot be claimed and the goods are dutiable at the standard rate. This is why the evidence should be requested from the exporter as part of the purchasing process rather than at the point of clearance.
Does the removal of the US de minimis exemption affect low-value shipments from the EU?
Yes. Consignments that previously entered the United States without a formal declaration now require one, regardless of value. Commodity codes, product descriptions and delivery terms need to be accurate for every shipment, not only for high-value ones.
Who is liable if a declaration turns out to be incorrect?
The importer is liable, and where a customs representative acts in indirect representation, that representative is a debtor for the customs debt as well. Both parties should agree in advance which records each will hold and for how long.

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