Customs Compliance & Risk Management

Customs Compliance & Risk Management
Journal for practitioners in Europe
October/November
2025
Issue 35
ISSN 2669-2171
October / November
Enrika Naujokė

Editor's message

Enrika Naujokė

Member of the Editorial Board

Dear Reader,

When is enough, enough? When it comes to evidence to support compliance and manage risks, there’s no one-size-fits-all answer. Global trade is governed by ever-changing local rules, court interpretations, and complex legislation - challenges we track closely in our up-to-date overviews of EU, UK, US, and Ukrainian legal developments. For practical insights into the tricky questions of responsibility and liability, explore our articles “Where does the customs broker’s responsibility end and the importer’s begin?” and “Criminal or administrative? How countries decide on customs violations”.

While preparing this editorial, I was struck by a comment from a fellow practitioner: how is it that so many smart minds strive to simplify regulatory complexity, yet it only seems to grow? This “regulatory paradox” is explored in one of the articles in this issue: “While the European Union seeks to streamline compliance through the ‘Omnibus’ package, new external rules, such as the US Section 232, and internal proposals, like the TRQ, are driving up compliance costs for businesses, often outweighing the value of tariff benefits.” So, what’s the solution? One approach is to stay proactive - for example, by engaging with associations whose voices reach policymakers. We will continue to unpack this challenge in forthcoming issues.

But let’s shift our focus from the challenges to the opportunities ahead. Exciting advances are reshaping our professional landscape: rapid technological progress, the global transformation of customs to meet new challenges, and initiatives such as the EU Customs Reform and the EU Customs Data Hub. The future feels tangible - and we are at the heart of it.

Yes, we will all need to reinvent ourselves - whether within organisational customs and trade compliance functions or as customs brokers - but with change comes opportunity. Human expertise will be more essential than ever. While automation may take on routine tasks, it is experts who will guide these systems, ensure the quality of their output, and tackle the complex challenges that inevitably arise.

As this final issue of the year draws to a close, let me wish us all success in navigating the changes ahead. Together. In our Customs Ecosystem. Taking it to the next level - defined by being unified, cooperative, simplified, digitised, resilient and professionally competent. This will guide our content in the year to come, beginning with the Authors’ Meeting on “Customs function in the organisation - a future-proof set-up”.

With sincere appreciation to our Authors and Readers,
Enrika Naujoke

Read more

Country update

Where does the customs broker’s responsibility end and the importer’s begin?

Where does the customs broker’s responsibility end and the importer’s begin?

Omer Wagner
Omer Wagner
15 Oct 2025

An importer of Botox has been required by Customs to pay additional duties, following the reclassification of the product from a "medicinal product" to a "toxin". The importer is now suing their customs broker for negligence, alleging a classification error and the broker’s failure to advise that a certificate of origin could have mitigated the risk. Will the court hold the customs broker liable? Find out the answer as you read this review of the recent Israeli court judgement.

taxes and tariffs
Country update

News update

EU customs and trade news: October 2025

EU customs and trade news: October 2025

26 Oct 2025

News in week 43: 19th package of sanctions against Russia; simplifications for CBAM - officially published; EU Deforestation Regulation - measures to ensure the timely implementation; applications open for hosting new EU Customs Authority; EU-Ukraine further tariff reductions; EU and Uzbekistan signed the Enhanced Partnership and Cooperation Agreement; anti-dumping on imports of bicycles, screws without heads, steel track shoes; EU wins action on non-compliance by Colombia in WTO frozen fries dispute; new WCO instrument on the meaning of “price actually paid or payable”; and further updates.

law
News update
EU customs and trade news: November 2025

EU customs and trade news: November 2025

30 Nov 2025

News in week 48: major step towards implementing the tariff-related aspects of the EU-US Joint Statement; classification of a component for an electric grill; CJEU on the validity of the rule of origin applicable to steel pipes; definitive anti-dumping duty on imports of ironing boards; imports of alkyl phosphonic acids and their sodium salts subject to registration; WCO publishes Annual Report 2024-2025 and three-year Strategic Plan; and further updates.

law
News update
UK customs and trade news: October 2025

UK customs and trade news: October 2025

01 Nov 2025

News in brief: tariff notices on classification of PETG, candle holders, wines and swimming pool skimmer issued; new notices to exporters published; progress in UK-Japan, UK-Turkiye, UK-Switzerland, UK-Greenland trade relations; policy statement by the UK has been published; countervailing measure on PET from India maintained; TRA’s recommendation to scrap duties on glass fibre from Egypt; and other updates.

law
News update
US customs tariff news: October 2025

US customs tariff news: October 2025

02 Nov 2025

News in brief: Section 232 tariffs on imports of medium- and heavy-duty trucks and truck parts imposed; agreements between the US and Malaysia as well as Cambodia on reciprocal trade concluded; framework agreements on reciprocal trade between the US and Thailand as well as Vietnam agreed; investigation of China’s implementation of the Phase One Agreement announced; tariffs of 100 % on certain ship-to-shore cranes announed and additional tariffs of up to 150 % on certain cargo handling equipment proposed.

taxes and tariffs
News update
UK customs and trade news: November 2025

UK customs and trade news: November 2025

04 Dec 2025

News in brief: UK CBAM officialy introduced; tariff notices on the classification of  starch and sugars in pet food, and wines issued; new notices to exporters on legislative changes to export controls published; UK Customs Tariff updates; anti-dumping duty on imports of biodiesel, certain ceramic tableware and kitchenware imposed; anti-dumping duty on certain excavators suspended; a call for evidence to understand the merits of the PEM Convention; and other updates.  

law
News update
US customs tariffs news: November 2025

US customs tariffs news: November 2025

04 Dec 2025

News in brief: certain agricultural products exempted from reciprocal tariff; the scope of Brazil tariffs modified; framework for the US-Switzerland and Liechtenstein trade deal announced; trade deals with El Salvador, Argentina, Ecuador, and Guatemala announced; suspension of heightened reciprocal tariffs on Chinese imports maintained; duties addressing China’s synthetic opioid supply chain reduced; exclusions from China Section 301 tariffs related to forced technology transfer investigation extended; and other updates.

taxes and tariffs
News update
Ukraine customs and trade news: October/November 2025

Ukraine customs and trade news: October/November 2025

04 Dec 2025

News in brief: reduced customs duties and increased agricultural quotas in EU–Ukraine trade introduced; procedure for confirming the right to tax relief on the export of soybeans and rapeseed established; Commission’s Ukraine 2025 Report published; a pilot scheme to control the origin of timber exports adopted; zero quota for the export of unprocessed timber set; the list of goods that may be subject to anti-dumping measures revised; and other updates.

News update

Topic spotlight

The role of the risk register in compliance and risk management

The role of the risk register in compliance and risk management

Mark Rowbotham
Mark Rowbotham
19 Oct 2025

This article introduces the risk register as a practical tool for identifying, assessing, and managing risks within organisations and projects. It explains how risks can be categorised, prioritised, and monitored through both qualitative and quantitative approaches, and illustrates these principles with a sample risk register for a customs training course.

compliance
Topic spotlight
Steel and rules of origin: new US-EU developments

Steel and rules of origin: new US-EU developments

Antonio Castagnini
Antonio Castagnini
21 Oct 2025

In recent months, the steel sector has once again come under the spotlight of international regulatory scrutiny. Legislative measures are proliferating, aimed at strengthening controls over the origin of materials and preventing duty circumvention practices. Among these, the US Section 232 regulation is particularly notable, as it extends declaration requirements not only to steel products but also to numerous goods containing steel or aluminium, or using them as packaging materials. This article examines the implications of these new regulatory developments for international supply chains, considering how enhanced origin requirements and traceability obligations affect economic operators in the EU and their compliance systems.

origin
Topic spotlight
China’s export control system: overview and impact on EU traders

China’s export control system: overview and impact on EU traders

Sabine van Osenbrüggen
Sabine van Osenbrüggen
11 Nov 2025

In recent years, China has established a comprehensive export control and sanctions regime that protects national security interests and influences international trade relations. This article provides a brief overview of the legal framework, controlled items, licensing procedures, sanction mechanisms, and current developments in China’s export controls as well as their impact on EU traders.

restrictions
Topic spotlight
Overview of the 19th EU sanctions package against Russia

Overview of the 19th EU sanctions package against Russia

Aušra Šablinskienė
Aušra Šablinskienė
16 Nov 2025

On 23 October 2025, the Council adopted the 19th package of sanctions against Russia. The Council also introduced additional measures against Belarus to restrict its support for Russia’s war. Below is an overview of the changes requiring particular attention due to exemptions, derogations, and differing dates of entry into force of certain provisions.

restrictions
Topic spotlight
Criminal or administrative? How countries decide on customs violations

Criminal or administrative? How countries decide on customs violations

03 Dec 2025

This article brings together the insights of experts delivered during the 30th Author’s Meeting to examine how customs infringements are classified, sanctioned and enforced across different legal systems. The contributions highlight the complexity and fragmentation of the EU sanctioning landscape, the challenges faced by individual Member States undergoing reform, and the lessons that can be drawn from non-EU jurisdictions with clearer or more consolidated enforcement models.

law
Topic spotlight

Perspective

How can you train an artificial intelligence system to do what you need?

How can you train an artificial intelligence system to do what you need?

Ramūnas Šablinskas
Ramūnas Šablinskas
12 Oct 2025

This article aims to explain how artificial intelligence (AI) systems are trained, how they differ from traditional programmes, and – most importantly for your daily work – when they can be trusted and what to expect from them in the future. We recognise the need for, and importance of, this knowledge in our interactions with users who are beginning to utilise the AI products developed by CustomsClear, one of which is the EU sanctions compliance checking tool for Russia and Belarus.

Tech
Perspective

Explainer

Unlocking global trade insights: an introduction to the WTO’s data portals

Unlocking global trade insights: an introduction to the WTO’s data portals

Sabine van Osenbrüggen
Sabine van Osenbrüggen
03 Dec 2025

This article provides an overview of the most prominent WTO data portals, explaining their key features and demonstrating their practical applications. Whether you are a trade professional searching for tariff rates, a company evaluating market access conditions or a researcher studying multilateral trade disciplines, these platforms provide an ideal starting point for informed analysis.

Tech
Explainer