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EU Customs Reform: reshaping responsibilities

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.

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