EU Customs Reform

On 17 May 2023, the European Commission published its proposal to reform the customs setup of the European Union - the most ambitious and comprehensive reform of the European customs Union since its inception in 1968. In doing so, the European Commission has particularly focused on three key ambitions:

• Partnership with business
• Smart approach to customs checks
• More modern approach to e-commerce

These ambitions are supported by a comprehensive revision of the Union Customs Code (UCC) and associated provisions on how the European customs Union will operate in the future.

Structural changes

The key structural updates as follows:

1. Centralisation of the EU’s customs function and greater uniformity in the application of rules to ensure a more consistent experience for traders via:
   • The creation of a central EU Customs Authority with responsibility for central risk management and which will issue control recommendations to national customs authorities for implementation;
   • Greater uniformity of EU customs rules – e.g. setting out an EU-wide minimum penalty regime for e-commerce rather than giving Member States autonomy to set and implement penalties.
2. An overhaul of customs legislation to ensure e-commerce is dealt with in a simplified manner via:
   • Removal of the 150 euro low-value consignment customs duty relief since 1 july 2026;
   • Temporary duty of 3 euro per item for e-commerce shipments up to 150 euro;
   • New concepts of “importer” and “deemed importer” to align customs rules with VAT rules on distance sales and increase responsibilities for sales-platforms.
3. Streamlining customs formalities and the introduction of the EU Customs Data Hub:
   • A centralised EU Customs IT structure instead of 27 separate systems – ultimately a single interface for traders dealing with customs;
   • Will combine data from the Single Window, ICS2, digital product passport to ensure central oversight of EU customs data;
   • Focus on traders and other stakeholders holding required customs data being able to provide firsthand, reusable data to simplify clearance.

What happened since?  

Since the proposal was published, both the EU Council and the EU Parliament have expressed their views on the proposal. Followed by trilogues finally the political agreement between the EU Council and the EU Parliament was reached on 26 March 2026.

The final text is now awaiting formal adoption by both the EU Council and the European Parliament and is expected to be published in the Official Journal during the fourth quarter of 2026.

However, due to growing concerns about e-commerce shipments, particularly the increasing number of non-compliant products entering the EU and the undervaluation of goods to remain within the 150 euro low-value consignment relief threshold, the low-value consignment relief was abolished on 1 July 2026. It has been replaced by a temporary customs duty of 3 euro per item for e-commerce consignments with a value of up to 150 euro.

To further encourage bulk-importation of goods, thereby enabling customs authorities to carry out inspections more efficiently and verify compliance with EU product safety requirements, the EU is also planning to introduce a handling fee for e-commerce shipments as of 1 November 2026. The fee is expected to amount to 2 euro per item.

How can PwC assist you in preparing for the proposed changes?

PwC has a dedicated team of customs specialists who possess extensive knowledge and experience in the legal, technical, and operational aspects of customs. Consequently, we have been selected by the European Commission to assist them in the development of the Proposal (through the study "An integrated and innovative review of the EU rules governing e-commerce transactions from third countries from a customs and tax perspective", as referenced in the Proposal).

This has given us a profound understanding of the background and intention behind the proposal. It places us in an extremely favourable position to assess the implications of the EU Customs Reform for businesses and to assist in taking the appropriate measures to comply with the proposed legislation, as well as to capitalise on the opportunities it presents.

Of course, we do this in collaboration with our network of experts in other areas, such as VAT, Transfer Pricing, digitalisation, sustainability, and security, who can provide cross-sectoral and multidisciplinary perspectives on customs issues.

What to take into account during implementation?

The proposed recasting of the UCC is a significant step towards modernising the EU Customs Union to account for the developments in data analysis and e-commerce and to create a more consistent, streamlined customs experience. As such all parties involved in importing into the EU should consider how the proposed changes will affect them.
Some of the bigger points of attention are:

• A new definition of "importer" will be introduced, with significantly expanded responsibilities. Online platforms are now designated as importers for distance sales who are responsible for compliance with EU rules and standards. The role of customs brokers also changes: indirect representation remains possible, but many parties may be unwilling to accept the related liability. Understanding your exact supply chain and current role will be essential to understand the consequences of the new framework. These insights will also help in reacting to geopolitical changes or spotting opportunities.

• The implementation of the EU Customs Data Hub will provide the customs authorities with real-time data availability and continuous risk analysis will require companies to ensure that the essential customs data they provide such as classification, origin, and customs valuation is accurate. There will be a fundamental shift in how customs data is captured, shared and scrutinised.  
  Read more in our article on the EU Customs Data Hub.

• In relation to non-fiscal measures, it is to be mentioned that the EU Customs Data Hub will create an EU-wide risk management system. E.g., it will connect or consolidate with systems like CERTEX (health, safety and environment) and include data from the Digital Product Passport. Identify all measures relevant to your business and ensure you have processes/procedure in place to comply will be important. Non-compliance will be flagged and shipments will be stopped.

Implementation Timelines

A significant point within the implementation timeline will be the publishing of the Implementing and Delegated Acts which will contain the detailed steps on how the new proposals will be implemented. It is expected that these legislative texts will not be published before 2027. Further to this, the following key timelines should be noted in respect to the proposed new UCC:

• 2026: Introduction of the EU Customs Authority
• 2028: Introduction of the EU Customs Data Hub for e-Commerce
• 2031: Voluntary use of the EU Customs Data Hub for all traders
• 2034: Mandatory use of the EU Customs Data Hub for all traders