Customs law reimagined: the reformed Union Customs Code

On 19 September 2026, Regulation (EU) 2026/2108 was published in the Official Journal of the EU. It marks the most significant overhaul of European customs law since the Union Customs Code (UCC) was introduced. We set out what the EU customs reform changes, which deadlines apply and how businesses should prepare.

The Regulation replaces the current UCC (Regulation (EU) No 952/2013). For the first time, a central EU customs authority will be established. Customs supervision is being reset accordingly: instead of national authorities checking individual customs declarations, customs will operate on an EU-wide, data-driven and risk-based model. The framework is in place.

The Commission will settle the details in delegated and implementing acts. For businesses that import or export, the reform brings new obligations and new opportunities.

Key changes under the new Union Customs Code

• EU Customs Data Hub: A single central platform will gradually replace the more than one hundred national IT systems currently in use. Businesses will submit their data once, through a single interface.
• New EU Customs Authority (EUCA): The new authority, based in Lille, will take on responsibilities including common risk management and operation of the Data Hub.
• The importer takes responsibility: Until now, the declarant was the customs debtor. Going forward, the importer is at the centre of the regime, and the Regulation defines the term expressly for the first time. The importer must provide the required data and ensure that duties are paid. It must also ensure that goods comply with non-customs requirements, such as product safety rules. The requirement for the importer to be established in the EU is expected to remain.
• E-commerce: Online sellers and platforms are treated as “importers in the context of distance sales”. Customs authorities will levy a handling fee on goods from distance sales (Art. 20). The EUR 150 duty exemption threshold was abolished on 1 July 2026 and replaced by a flat-rate duty of EUR 3 per item category.
• New “Trust & Check Trader” status: The new status builds on the Authorised Economic Operator (AEO) concept. Customs must be given access to the company’s electronic systems. Among other conditions, the company must have carried out customs operations regularly for at least two years. The benefits are significant: the company can release goods itself, determine its customs debt periodically and defer payment. AEO status remains in place, with compliance reviewed at least every three years.
• Tougher penalties: The Regulation sets a minimum list of infringements that Member States must penalise. A tiered regime applies to systematic infringements in distance sales. Initial penalties range from 1% to 4% of the value of imports over the previous twelve months. Further infringements within six months raise the range to 3% to 6%. Additional consequences include loss of AEO or Trust & Check status, classification as a high-risk economic operator and, in the most serious cases, restrictions on access to online marketplaces.

Entry into force and reform deadlines

Existing delegated and implementing acts under the current UCC remain in force until the Commission replaces them.

Recommendations: how businesses should prepare for the customs reform

1. Review roles and responsibilities: Determine who in your supply chains will qualify as importer or exporter. Check whether customs representatives need to be engaged on a new basis. Indirect representatives are jointly and severally liable.
2. Secure product compliance: Put processes in place to demonstrate and document compliance with non-customs requirements, such as product safety.
3. Prepare IT and data: Plan your connection to the Data Hub early. Improve the quality of your master data and review your systems landscape.
4. Maintain AEO status and assess Trust & Check: For many businesses, whether to seek Trust & Check status will be a key strategic decision. Customs will review data from the previous three years, so preparation should start now.
5. Update contracts: In e-commerce in particular, review your contractual and pricing models with platform operators and service providers, including who bears customs obligations and liability risks.
6. Use the time remaining: Just under a year remains until the new Union Customs Code applies on 21 September 2027. That is little time for the changes required.

Union Customs Code advice: how Baker Tilly can help

The reform touches customs law, tax, IT and contracts alike. At Baker Tilly, lawyers and tax advisers with expertise in customs and foreign trade law work together across disciplines. We assess how the reform affects your business and adapt your processes and contracts. We support you with AEO and Trust & Check authorisations and represent you before the customs authorities. Get in touch. Together, we will make sure your business is ready for the reformed Union Customs Code.