New EU Union Customs Code: EU Customs Data Hub, Trust & Check Traders and the 2026 customs reform

On 16 September 2026, the European Parliament and the Council adopted Regulation (EU) 2026/2108, establishing a new Union Customs Code, the European Union Customs Authority and the EU Customs Data Hub. It was published on 19 September and entered into force on 20 September 2026. That did not switch off the existing customs model overnight: most provisions apply after 12 months, while migration to the Data Hub continues in stages until 2034.

The new UCC is not simply a rewrite of customs law or another public-sector IT project. It moves the EU from digitising individual declarations towards a more integrated European model for managing data, risk and compliance across international supply chains. Businesses will need to connect customs, tax, legal, product compliance, supply chain and IT expertise.

Key points at a glance

• Regulation (EU) 2026/2108 was adopted on 16 September, published on 19 September and entered into force on 20 September 2026.
• Most provisions will generally apply from 20 September 2027; the final act does not set 21 September 2027 as the general application date.
• The EU Customs Data Hub will progressively replace the fragmented landscape of national systems and conventional declarations.
• From 1 July 2028, the Hub will support specified e-commerce imports; other operators may use it voluntarily from 1 March 2031 and must use it from 1 March 2034.
• Trust & Check Trader is not an automatic rebranding of every existing AEO authorisation.
• The reform increases the importance of importer responsibility for customs data and non-customs product requirements.

What has happened to the Union Customs Code?

Regulation (EU) 2026/2108 of the European Parliament and of the Council of 16 September 2026 establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013 is final, directly applicable EU law. Its CELEX number is 32026R2108. The official text is available on EUR-Lex.

The Regulation repeals Regulation (EU) No 952/2013 within a staged application and transition framework. Entry into force, general application, application of specific provisions and technical migration to the Data Hub are therefore separate milestones.

The reform is intended to deliver more consistent Customs Union management, EU-level risk analysis, stronger supervision of goods entering the Single Market and simpler cooperation with trusted businesses. The European Commission's EU Customs Reform page describes a smarter, more resilient and data-driven customs architecture.

Why is the European Union changing its customs system?

The present system was designed for a different volume and pattern of trade. Rapid e-commerce growth, billions of third-country parcels, fragmented data and a growing body of safety, environmental and product rules have made effective supervision harder.

The reform is designed to support common EU risk management and reduce repeated submission of similar information to separate systems. Customs is also increasingly the point where sanctions, product safety, PPWR, environmental duties and other market-access rules converge. The new UCC is therefore not merely an IT modernisation exercise.

1. EU Customs Data Hub – moving beyond conventional declarations

The EU Customs Data Hub will be the central data environment of the new model. Rather than repeatedly filing separate datasets in national systems, businesses will progressively make the information required by customs authorities available through a shared European environment.

This is not a simple form replacement. Data may come from several parties and at different stages of the supply chain. Businesses need to know which record is authoritative, who owns it and how it moves between ERP, WMS, TMS, customs applications and product-information systems.

Readiness will require a review of integrations, APIs, master data, quality controls and access rights. That connects customs reform directly with digital transformation and target operating model design.

2. Greater importer responsibility

The new model gives the importer a more central role. Responsibility extends beyond tariff classification, customs value and origin to the information required to assess prohibitions, restrictions and other rules applying to imported products.

Depending on the goods, that may include safety, labelling, technical documentation, environmental or extended producer-responsibility requirements. These obligations are not identical for every shipment; the exact position depends on the product, the operator's role, the jurisdiction and the supply model.

Customs therefore needs to work with product compliance, ESG and environmental compliance, tax, legal, procurement and supply chain. Examples include PPWR packaging obligations and the market-access requirements covered by our legal and regulatory advisory.

3. Trust & Check Trader – the next stage beyond AEO

Trust & Check Trader is a new status for highly transparent and reliable operators. The Regulation provides for deeper facilitations, potentially including self-release of goods where the conditions are met, alongside supervision supported by customs access to relevant data and systems.

A strong customs track record alone will not be enough. Record-keeping, data quality, internal controls, anomaly detection and transparent processes will matter. Readiness may therefore require a joint customs, internal-audit, compliance and IT programme.

AEO remains a separate concept under the new Regulation. Businesses should not assume that every AEO will automatically become a Trust & Check Trader. Current authorisations, system gaps, benefits and the detailed conditions of the new status should be assessed once the supplementary rules are available.

4. The European Union Customs Authority

The European Union Customs Authority will strengthen coordination between national administrations and support more consistent application of customs rules. Its role includes EU-level risk analysis, common control priorities and participation in building and operating the EU Customs Data Hub.

National customs authorities will remain in place. What changes is the coordination layer: data and risk should be analysed across the Union rather than solely within individual Member States, helping identify supply-chain risks more consistently.

5. E-commerce and distance-sale imports

The reform is particularly important for marketplaces, platforms, online sellers, logistics operators and fulfilment providers. The new importer-for-distance-sales concept may capture the person supplying goods or facilitating the sale, shifting customs responsibilities towards platforms.

From 1 July 2028, relevant distance-sale importers must use the Data Hub. The removal of the EUR 150 customs-duty relief was accelerated through separate Council Regulation (EU) 2026/382: a temporary EUR 3 duty per tariff line applies to qualifying consignments from 1 July 2026 until 30 June 2028, after which the target tariff treatment is due to apply. The Commission has published official guidance on the temporary measure.

Current UCC versus the new UCC

New UCC implementation timeline

1. 16 September 2026

   Final adoption of Regulation (EU) 2026/2108 by the European Parliament and the Council.

2. 19–20 September 2026

   Publication in the Official Journal on 19 September and entry into force the following day.

3. 20 September 2027

   General application after 12 months; some provisions have their own dates.

4. 1 July 2028

   Key e-commerce rules and mandatory Data Hub use for specified distance-sale imports; the necessary functionality is due by 1 June 2028.

5. 1 March 2031

   Other importers, exporters and transit-procedure holders may start using the Data Hub voluntarily.

6. 1 March 2034

   Data Hub use becomes mandatory in the target model; full functionality is due by 1 February 2034.

What does the new UCC mean for business?

Data

Businesses should assess CN/TARIC codes, origin, supplier and product records, bills of materials, customs values, Incoterms, logistics data and regulatory attributes. The issue is not merely whether a field exists, but its source, currency, evidence and owner.

Systems

The review should cover ERP, WMS, TMS, customs and product systems, integrations and APIs. It should identify authoritative systems, validation points and correction processes. A customs broker should not be the only place where critical company data is created.

Processes

Map import, export, special procedures, classification, origin, valuation and product compliance. The map should show decisions, documents, controls, exceptions and data hand-offs between the business, supplier, carrier and customs representative.

Organisation

Define responsibilities across customs, tax, legal, compliance, procurement, logistics, IT and finance. The target operating model should identify data owners, approvers, escalation routes and risk monitoring. We connect this work with business advisory and international expansion support.

Should businesses start preparing now?

Yes, particularly larger organisations and groups trading regularly outside the EU. Not because every requirement applies immediately, but because repairing master data, redesigning integrations and agreeing cross-functional responsibilities often spans several budget cycles.

A sensible starting point is a customs-process map, customs data assessment, named data owners, a system-architecture review and an AEO assessment. The findings should inform the digital-transformation roadmap, ERP plans and product-compliance and supply-chain initiatives.

How can we help?

Customs & International Trade

We review customs processes, tariff classification, origin, customs valuation, special procedures and AEO. We can assess Trust & Check readiness and design customs-compliance controls through our tax and customs advisory.

Regulatory & Product Compliance

We identify non-customs requirements, importer duties and EU product market-access rules, connecting legal analysis with actual product and data flows.

Digital Transformation

We map customs and trade-compliance processes, assess data flows and master data, and define integration requirements for ERP, WMS and TMS. We translate Data Hub requirements into an executable transformation programme.

Advisory and outsourcing

We design the target operating model, governance, roles and responsibilities for customs and trade compliance. Where appropriate, we connect the project with accounting and back-office outsourcing to keep financial and customs data aligned.

Sources

• Regulation (EU) 2026/2108 — EUR-Lex, CELEX 32026R2108
• European Commission — EU Customs Reform
• European Commission — temporary EUR 3 customs duty guidance