Held at customs: how sectoral rules delay clearance
Prohibitions and restrictions in practice: missing data, different definitions and liability for representatives

One missing piece of data required by a sectoral rule is enough to hold goods at the border. The EU Deforestation Regulation (EUDR), the Carbon Border Adjustment Mechanism (CBAM), the F-gas Regulation and the Forced Labour Regulation define terms such as 'importer' and 'representative' differently from the Union Customs Code, or not at all. They also use their own IT systems and set their own rules on the liability of representatives. This recording compares these definitions and liability rules side by side and sets out four causes of delay at clearance: missing data, duplicate entry, different definitions and liability. Each cause comes with an example, from EUDR, CATCH (the EU system for fishery catch certificates), F-gases and CBAM, where the liability of representatives can lead customs agents to refuse the job. It then explains the Commission's new approach, based on TARIC and the EU Customs Data Hub, and what the logistics sector asks the EU to change. If you declare or ship goods, advise traders or set up screening processes, it shows you which data and roles to check under the sectoral rules that apply now and those still to come.





