EU Customs Reform: reshaping responsibilities

Massimo De Gregorio
Massimo De Gregorio
President, CONFIAD - Paneuropean Network Confèdèration Internationale des Agentes en Douane, Italy
Published 29 Jun 2026

A customs-broker expert unpacks the sanctions and liability chapter of the EU customs reform, explaining how it reshapes responsibility across the whole supply chain and what it means for customs representatives and e-commerce operators. Relevant for customs and trade compliance professionals who need to understand the new liability and sanctions framework in the reformed Union Customs Code.

Topics covered:

  • Why the EU is moving from 27/28 diverging national sanction regimes towards a common EU framework for customs infringements and penalties
  • The European Parliament's priorities: defining infringements, penalising only negligent or intentional conduct, avoiding double penalisation, and basing fines on duty evaded rather than the value of goods
  • Title XIV of the reform text: minimum, non-criminal EU-wide infringement rules and the "effective, proportionate and dissuasive" penalty standard
  • How liability extends beyond importers and exporters to the whole supply chain, including compliance with product safety, environmental and sustainability rules
  • Indirect customs representation: liability for non-EU-established importers' representatives, and joint and several liability for EU-established importers
  • The new "Trust and Check" operator status alongside AEO, and the simplifications it brings in exchange for full liability
  • New e-commerce-specific sanctions, the removal of the low-value consignment exemption, and the tiered penalty scale for online platforms and their customs representatives
  • What the reform means for customs professionals' future skills: digitalisation, shipment tracking and computerised customs accounting

For a broader overview of the topic, please watch the full recording. The slides are available in the Resources section.

Please note that this summary was generated using AI, based on the recording and available slides.

Related content

UCC changes - purpose and impact

UCC changes - purpose and impact

Anthony Buckley
Anthony Buckley
14 Jul 2026

A cluster of EU customs changes has taken effect together, and they reach well beyond e-commerce. The €150 duty exemption is gone, and a flat €3 duty now applies to…

Customs law
E-commerce
The new Union Customs Code (UCC)

The new Union Customs Code (UCC)

12 May 2026

Anthony Buckley, former Head of Irish Customs, explains the proposed reform of the EU Union Customs Code (UCC) to CustomsClear - essential viewing for anyone in customs and trade compliance…

Customs law
CERTEX in the context of the EU Customs Reform

CERTEX in the context of the EU Customs Reform

Anthony Buckley
Anthony Buckley
19 Apr 2026

Anthony Buckley, former Head of Irish Customs, explains what Certex (the Customs Single Window Certificate Exchange) is, how it works, and why it is central to the EU Customs Reform…

Customs law
A wrong EORI number, and the direct customs representative is held liable for the import VAT

A wrong EORI number, and the direct customs representative is held liable for the import VAT

Michael Lux
Michael Lux
13 Aug 2026

Editorial note. A direct customs representative inserts a wrong EORI number which does not belong to his client (the importer) and ends up being considered as customs representative without empowerment,…

Duties & taxes
Customs law
Topic spotlight
2026 Customs and trade outlook: key changes and challenges

2026 Customs and trade outlook: key changes and challenges

Anthony Buckley
Anthony Buckley
18 Jan 2026

Anthony Buckley, CEO of Anthony Buckley Consulting Ltd. and former Head of Ireland's Revenue Customs Service, gives a strategic overview of the key trade and customs developments expected in 2026,…

Customs law
How can SMEs get ready for the new UCC?

How can SMEs get ready for the new UCC?

Agnieszka  Brodacz
Agnieszka Brodacz
20 Nov 2025

This roundtable helps small and medium-sized importers, exporters and logistics companies prepare for the EU customs reform (the new Union Customs Code, UCC), covering the current status of the negotiations,…

Customs law