Key points at a glance
- The reform replaces the declaration-based customs system with a data-driven model centred around a central EU Customs Data Hub and a new EU Customs Authority based in Lille
- The new Trust-and-Check status builds on the AEO framework and enables the most transparent companies to benefit from largely automated clearance, in exchange for real-time data and investment in IT and compliance
- From 1 July 2026, the EUR 150 customs duty exemption will be abolished. In e-commerce, platforms will be considered importers. Full implementation will take place in phases through to 2034
What is the EU Customs Reform and why is it happening now?
The EU Customs Reform is a revision of the Union Customs Code (UCC), the legal foundation of European customs law.
– What is the status of the process?
The European Commission presented its proposal in 2023. On 26 March 2026, the Council and the European Parliament reached a political agreement in the trilogue.
Formally, the process is not yet complete. The final text of the regulation is being finalised and must still be adopted and published in the Official Journal of the EU. The regulation will enter into full force twelve months after publication.
– Why is the EU reforming customs now?
There are several reasons for the pressure to reform. The volume of customs declarations has risen sharply in recent years, driven mainly by the growth of online commerce and millions of low-value consignments per day.
At the same time, the 27 Member States have so far worked with largely separate customs IT systems. ATLAS in Germany is one example. The reform aims to reduce this fragmentation, improve protection against unsafe goods and make customs processes more uniform across the EU.
What changes with the shift from customs declarations to data-driven customs?
The core of the reform is a change in logic. Instead of submitting a separate customs declaration for each consignment, companies will in future provide their data centrally and make it reusable.
Two new institutions support this model.
– What role does the new EU Customs Authority play?
The new EU Customs Authority, based in Lille, will coordinate risk analysis and crisis management across the Member States. Operational responsibility remains with the national customs authorities.
However, the EU Customs Authority will support more uniform application of customs law and may issue control recommendations to national administrations. These must either be implemented or rejected with a reasoned explanation. The authority will also develop and operate the central data hub.
– What is the EU Customs Data Hub and what does it mean for national customs systems?
The EU Customs Data Hub is a central platform through which companies submit customs data. It is intended to gradually replace separate national customs IT systems across the Member States. In Germany, this would include ATLAS.
Today, customs data is still handled through many separate national customs IT systems across the EU. The Data Hub is designed to bring this information together and build on existing EU systems, such as the Single Window environment and ICS2.
For customs authorities, this creates a unified view of goods flows and supply chains. For companies, it offers the prospect of less duplicate data entry and lower administrative effort. The EU estimates that this could result in savings of approximately EUR 26 billion for businesses over the next fifteen years.
The Data Hub will initially open for e-commerce consignments and then gradually expand to cover all goods movements. The technical details and exact timeline are still being finalised.
– What does the Trust-and-Check status mean for importers and exporters?
For established economic operators, the new Trust-and-Check status is one of the most important elements of the reform. It is a further development of the well-known AEO status and is aimed at the most transparent importers, exporters and indirect representatives based in the EU.
– What are the benefits of this status?
The benefit lies in customs clearance. Trust-and-Check companies can move their consignments through a type of green lane, without formal intervention by customs authorities for every single import.
Under certain conditions, they may monitor the compliance of their goods themselves and release goods for free circulation on behalf of customs. Controls are risk-based and carried out after clearance. Other benefits include the option to pay the customs debt at a later date.
– What are the requirements?
The requirements are demanding. In essence, the status requires:
- regular customs transactions over a period of at least three years
- no serious or repeated violations of customs and tax regulations
- a high level of control over processes and goods flows, as well as financial reliability
- an electronic system that provides customs authorities with all relevant data on goods movements and compliance in real time
The last requirement in particular may require significant investment in IT infrastructure and data security for many companies.
– Will AEO status remain?
Yes. AEO status will continue to exist in parallel, so small and medium-sized companies that do not meet the Trust-and-Check requirements can still benefit from customs simplifications.
The Trust-and-Check status is also not open to all parties in the supply chain. Carriers or warehouse operators, for example, are eligible only if they act as indirect representatives.
How does the reform affect e-commerce and small consignments?
Even companies outside online retail should be aware of these changes, as they affect compliance and customs planning more broadly.
– What happens to the EUR 150 customs duty exemption?
On 1 July 2026, the previous EUR 150 customs duty exemption was abolished.
As a transitional solution until the Data Hub becomes operational and regular customs rates apply, a flat customs duty of EUR 3 per item category will be levied on small consignments. In addition, an EU-wide processing fee will apply no later than 1 November 2026.
– Who will be liable for imports in the future?
One of the most far-reaching changes concerns liability. In future, platforms and distance sellers will be considered the importers of the goods. They will therefore be responsible for customs formalities and the payment of duties, rather than the end consumer.
Anyone selling from a third country into the EU must be established in the EU or appoint an EU representative with recognised status, such as AEO or Trust-and-Check. Systematic violations may result in financial penalties based on the value of the imported goods. Repeated violations may also cost a company its trusted status.
What are the deadlines and how can companies prepare now?
Implementation will take place over several years.
– Key dates at a glance
| Date | What happens |
| 26 March 2026 | Political agreement in the trilogue |
| 1 July 2026 | Abolition of the EUR 150 customs duty exemption; EUR 3 flat duty per item category as a transitional measure |
| No later than 1 November 2026 | EU-wide processing fee for small consignments |
| Expected by the end of 2026 | Formal adoption of the regulation |
| 1 July 2028 | EU Customs Data Hub for e-commerce consignments |
| From approximately 2031 | Voluntary use of the Data Hub for other economic operators |
| By 1 March 2034 | Mandatory use for all goods movements |
– What steps are worth taking now?
Even though full implementation will take years, early preparation is worthwhile. Useful first steps include:
- reviewing existing AEO status and using it as a basis for future Trust-and-Check status
- aligning data and IT architecture with the real-time provision of customs data
- reviewing the quality of master data and internal compliance processes
- clarifying your own role in the supply chain, for example importer, exporter or indirect representative
- for distance sales, ensuring that an EU establishment or an EU representative with recognised status is in place
Conclusion
The EU Customs Reform is changing the fundamentals of European customs. The direction is clear: fewer individual declarations, more centralised data and clearer responsibilities.
For companies with streamlined processes and a robust data foundation, this creates opportunities, including largely automated clearance as a Trust-and-Check trader. Companies that start adapting their structures early will be better placed to benefit from the new system.
Gerlach works with importers, exporters and compliance teams to navigate this transition, from assessing AEO and Trust-and-Check potential, to adapting customs processes for the Data Hub.
Get in touch to discuss what the reform means for your business.
