The new Union Customs Code: the EUR 3 per-item duty, the EU Customs Data Hub, deemed importers, Trust and Check Trader versus AEO, VAT and the IOSS, the timeline to 2034 and an action checklist for importers, e-commerce and supply chains.
The new Union Customs Code (UCC) — Regulation (EU) 2026/2108 — entered into force on 20 September 2026, but most of its provisions will apply only from 20 September 2027, and the full move to the EU Customs Data Hub will continue in stages until 2034. Already, since 1 July 2026, low-value consignments from third countries no longer benefit from the EUR 150 customs-duty relief: a temporary duty of EUR 3 per tariff item applies instead. The reform affects importers, exporters, manufacturers and distributors, e-commerce sellers and marketplaces, logistics firms, freight forwarders and customs representatives. Legal position as at 10 October 2026.
The new UCC is more than a change to customs rules. It moves the EU from lodging individual declarations towards a European model for managing data, risk and compliance across the supply chain. Preparing for it requires customs, tax, legal, product-compliance, supply-chain and IT expertise working together.
The current system was designed for a different scale of trade. The surge in e-commerce consignments from third countries, data fragmented across 27 national administrations and a growing number of non-customs requirements (product safety, environmental and sanctions rules) make effective supervision difficult.
The reform is intended to deliver EU-level risk analysis, reduce repeated submission of the same data to different systems and simplify cooperation with reliable businesses. The European Commission describes the reform as a move to a data-driven customs architecture.
Regulation (EU) 2026/2108 establishes the new Union Customs Code and the European Union Customs Authority, and repeals Regulation No 952/2013, subject to the application timetable and transitional provisions. The full text is available on EUR-Lex.
When discussing the reform, four categories of rules need to be kept apart:
The new authority will coordinate national administrations, carry out EU-level risk analysis, support common control priorities and be responsible for building and running the Data Hub. National customs authorities remain. What changes is the coordination layer, with data and risk analysed across the whole Union.
Over time, the Data Hub will replace fragmented national systems with a single European data environment. Instead of lodging successive declarations, businesses will make data available, often earlier in the supply chain and from several sources (supplier, carrier, platform, customs representative).
This is not a matter of swapping one form for another. A business has to establish which data is authoritative, who owns it and how it flows between systems. That makes Data Hub readiness a digital transformation project rather than a task for the logistics team alone.
Until now, consignments with an intrinsic value of up to EUR 150 were exempt from customs duty. The removal of this relief was brought forward by a separate Council Regulation (EU) 2026/382.
From 1 July 2026 to 30 June 2028, a flat duty of EUR 3 applies per tariff item, not per parcel, in qualifying distance-sale consignments. A parcel containing several different goods may therefore count as several items, with a correspondingly higher duty. From 1 July 2028, the temporary measure is due to be replaced by the target tariff treatment. The Commission has published guidance on the temporary measure.
The reform provides for a handling fee on e-commerce consignments. As at 10 October 2026, its amount, basis and collection method do not follow from a published act in application. Figures quoted in public debate are not binding, so businesses should plan for scenarios rather than a single rate.
The EUR 3 duty does not replace VAT. Import VAT is still accounted for as before: through the IOSS (Import One-Stop Shop) for consignments up to EUR 150, the special arrangements or the standard procedure. Because customs duty forms part of the taxable amount for import VAT, the VAT due changes too. Customs duty and VAT are two separate workstreams that must run in parallel in customs and accounting systems.
The new UCC strengthens the position of the importer as the party responsible for complete and accurate customs data and for the information needed to assess non-customs requirements, such as prohibitions, restrictions, product safety, labelling and technical documentation.
For distance sales, it introduces the deemed importer: a platform facilitating the sale may be treated as the importer for those transactions. This will apply when the Data Hub's e-commerce functions go live (from 1 July 2028). For marketplaces, it means taking on obligations and risks that currently sit with the seller or the carrier.
The scope of liability and penalties depends on the party's role, the type of breach, and national and implementing rules. Before making assumptions about penalties, check the text of the Regulation and the implementing acts.
Trust and Check Trader is a new status for the most transparent and reliable businesses. It is intended to allow deeper simplifications, including self-release of goods where conditions are met, in return for giving authorities access to data and maintaining ongoing internal controls. The conditions and procedure will be set by delegated and implementing acts.
AEO (Authorised Economic Operator) remains a separate instrument.
| Criterion | AEO | Trust and Check Trader |
|---|---|---|
| Legal basis | Current UCC, retained in the new one | New UCC, implementing acts in preparation |
| Essence | Certificate of reliability and security | Status based on authority access to data and internal control |
| Simplifications | Fewer controls, priority treatment | Deeper, including self-release of goods |
| Transition | — | No automatic conversion from AEO |
Businesses holding AEO status do have a head start, though: their procedures, internal controls and documentation are a good basis for a readiness assessment.
Responsibility for data increases: CN/TARIC code, customs value, origin and compliance with non-customs requirements. The customs broker should not be the only place where key data is created.
Preferential origin rules, supplier declarations, export documentation and proof of export for VAT become critical, as does the quality of data passed to importers on the other side of the border.
Customs becomes a meeting point with product regulation. Data on composition, origin of materials and product compliance must be available at the point of import, and distribution agreements should clearly allocate information obligations.
The EUR 3 duty per item affects prices and margins, and from 1 July 2028 the deemed-importer and Data Hub obligations follow. Businesses need to review their model, how items are separated in orders, IOSS accounting and relationships with postal and courier operators.
Their role shifts from "the party lodging the declaration" to data intermediary. They need API and data-exchange capabilities for the Data Hub, and a review of representation models, liability and client contracts.
Assess the quality of CN/TARIC codes, origin, supplier, composition and weight data, bills of materials (BOM), customs values and regulatory data. What matters is not only whether a field exists in a system, but its source, currency, evidence and owner.
The review should cover ERP, WMS, TMS, customs and product systems, and integrations. For each data item, establish the source system, where it is validated and how corrections are handled.
Incoterms and contracts with suppliers, distributors, platforms and customs agents should state clearly who the importer is, who supplies which data, who bears duty and fees, and who is liable for errors. We draft such provisions as part of our legal advisory.
The same set of product and supplier data now serves a growing number of regimes: CBAM (Carbon Border Adjustment Mechanism), EUDR (EU Deforestation Regulation), PPWR (Packaging and Packaging Waste Regulation), DPP (Digital Product Passport) and product-safety rules. It makes sense to build one data model for all of these obligations rather than a separate solution for each.
Temporary EUR 3 duty per tariff item begins (Council Regulation (EU) 2026/382); applies until 30 June 2028.
Regulation (EU) 2026/2108 adopted by the European Parliament and the Council.
Published in the Official Journal of the EU and in force the following day.
Most provisions start to apply; some have their own dates.
Mandatory Data Hub for specified distance sales, deemed importer, target tariff treatment of low-value consignments.
Voluntary use of the Data Hub by other importers, exporters and transit users.
Mandatory use of the Data Hub in the target model.
These steps are our recommendations, not obligations taken directly from the legislation:
Through our customs advisory service, we carry out new-UCC readiness reviews, audits of classification, value and origin, VAT and IOSS impact analysis, AEO and Trust and Check Trader assessments, contract updates and ERP, WMS and TMS requirements. We combine tax advisory, legal and digital-transformation expertise. We are not a customs agency; we work alongside our clients' customs agents and logistics teams. The article was written by Michał Zwyrtek, Partner at Zwyrtek Group, tax adviser and customs agent.
Zwyrtek Group was a partner of the Marketing & Digital Experts Summit 2026 in Sopot. Michał Zwyrtek took part in a panel on data, AI, technology and organisational transformation.
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