Customs Compliance & Risk Management

Customs Compliance & Risk Management
Journal for practitioners in Europe
February/March
2026
Issue 37
ISSN 2669-2171
February / March
Enrika Naujokė

Editor's message

Enrika Naujokė

Member of the Editorial Board

Dear Reader,

A historic agreement to reform the EU Customs Union has been reached. What began as a bold vision is steadily taking practical shape, and those who have driven it forward can take justified pride in achieving such a significant milestone. Lille in France has been selected to host 250 officials of the new EU Customs Authority, which will oversee the EU Customs Data Hub and coordinate the harmonisation and standardisation needed for EU customs to operate as one.

For participants across the international supply chain, this transformation presents a unique opportunity to rethink customs-related processes, making them more effective, competitive and future-proof. In this issue, we offer a glimpse into these developments, including an overview of Italy’s new customs IT platform project and an exploration of the growing role of artificial intelligence in international trade compliance research. Readers seeking broader perspectives on the reform will also find valuable insights from two associations: the European Shippers’ Council in Brussels and PIFFA in Poland.

Another area of significant development within the EU is the Carbon Border Adjustment Mechanism (CBAM). With the pricing of CBAM certificates expected to be announced soon and practical questions beginning to settle, attention is shifting towards compliance in greater depth. We examine the key considerations for customs brokers navigating this evolving framework.

On the global stage, the forthcoming HS 2028 revision stands out. A total of 299 sets of amendments have been introduced. In this issue, we review the principal changes and discuss how businesses should prepare. Companies can already begin assessing potential impacts on their goods. At the same time, it is important to recognise that not all countries will implement HS 2028 simultaneously; accordingly, changes should not be applied automatically across all trade flows.

To illustrate current classification challenges, we highlight a court decision involving an importer who had obtained advance authorisation to classify all components of a single project under one HS code, only for the customs authority later to exclude high-value transformers and seek approximately €400,000 in duties under a separate
heading.

Further topics include challenges with CERTEX at the Lithuanian port and issues faced by US importers in reclaiming duties following the end of IEEPA tariffs.

Wishing you an insightful read,
Enrika Naujokė

Read more

Country update

Where have the 'green' import lanes gone? Challenges at Lithuanian seaport Customs

Where have the 'green' import lanes gone? Challenges at Lithuanian seaport Customs

Jurgita Bartninkienė
Jurgita Bartninkienė
08 Feb 2026

Despite the ambition to create a smart, business-friendly customs administration, practical experience at the Klaipėda (Lithuania) seaport customs posts suggests otherwise: procedures are taking longer and green lanes are becoming increasingly rare. A round-table meeting initiated by the Lithuanian Customs Practitioners Association with Lithuanian Customs on 15 January 2025 once again highlighted the systemic issues that continue to disrupt import flows on a daily basis.

clearance process
Country update
Electricity breakdown at Customs: 8502 or 8504 (0% or 10% duty?)

Electricity breakdown at Customs: 8502 or 8504 (0% or 10% duty?)

Omer Wagner
Omer Wagner
10 Feb 2026

A recent Israeli court ruling highlights the decisive role of tariff classification in customs compliance and project economics. The importer had obtained advance approval to open a 'secretariat file' - a procedure enabling all components of a single project to be classified under a single HS code - yet the customs authority excluded high-value transformers and sought duties of approximately €400,000 under a separate heading. How the court ultimately resolved this dispute, and the broader implications for classification practice, are examined in the following overview of the ruling.

classification
Country update
Parallel food importers: compliance challenges

Parallel food importers: compliance challenges

Liat  Hessel
Liat Hessel
05 Mar 2026

Food importers must submit a number of documents as a prerequisite for importation, and state authorities continue to monitor the process even after the food has been imported. In recent years, regulatory reforms - such as the 'What is good for Europe is also good for Israel' initiative - have reshaped the landscape for food importers in Israel, simplifying procedures for imports from the European Union while introducing new complexities for imports from other regions. This article examines the activities of a parallel importer who does not purchase directly from the manufacturer, and who only imports 'regular' foodstuffs, such as pasta, snacks or dried fruit, which are not defined as 'sensitive' foodstuffs.

compliance
Country update
Millions of declarations, one platform: new Italian IT customs platform project

Millions of declarations, one platform: new Italian IT customs platform project

Massimo De Gregorio
Massimo De Gregorio
23 Mar 2026

The Italian national federation of customs brokers’ associations has approved an ambitious project to establish a proprietary digital platform underpinned by actual operational customs declaration data - comprising millions of declarations per annum, including e-commerce H7 declarations. With the first phase already concluded and EU funding secured, the platform is on a 24-month clock to delivery. 

Tech
Country update

News update

EU customs and trade news: February 2026

EU customs and trade news: February 2026

01 Mar 2026

News in week 9: EU Customs Authority - Council and Parliament agree procedure to select a host city; EU-Mercosur agreement - provisional application; broad package of agreements with Switzerland; upcoming steel measure addressing the negative effects of global overcapacity; anti-dumping duty on imports of steel road wheels; imports of new mobile cranes subject to registration; human rights violations in Russia - EU lists additional eight individuals; EU terrorist list - Council strengthens the scope; EU extends Russia sanctions over occupied Ukrainian territories; and further updates.

law
News update
US customs tariff news: February 2026

US customs tariff news: February 2026

01 Mar 2026

News in brief: the US Supreme Court’s ruling on the reciprocal and  other IEEPA tariffs; the US President’s actions in response to the Supreme Courts ruling; new temporary tariffs imposed; the suspension of duty-free de minimis treatment for all countries continued; new frameworks for trade agreements between the US and certain countries; and other updates.

taxes and tariffs
News update
UK customs and trade news: February 2026

UK customs and trade news: February 2026

03 Mar 2026

News in brief: the biggest sanctions package against Russia announced; two notices to exporters issued; tariff notice on the classification of inverters with maximum power point tracking functionality issued; CBAM policy paper published and consultation on draft regulations announced; countervailing duty on continuous filament glass fibre products originating in Egypt revoked; anti-dumping duty on ironing boards from China varied; both anti-dumping and countervailing duties on glass fibre products from China cancelled; registration of imports of creamy/white limestone originating from Portugal introduced; and further updates.

law
News update
EU customs and trade news: March 2026

EU customs and trade news: March 2026

29 Mar 2026

News in week 13: historic agreement to reform EU Customs Union; selection of Lille as seat for EU Customs Authority; 14th WTO Ministerial Conference; EU-Australia FTA; CJEU judgments on customs valuation and on imports of goods generating significant revenues for Russia; provisional anti-dumping duty on imports of yarns of polyamide; decision on exemptions from anti‑dumping duties on certain bicycle parts; anti-dumping extension to cover unthreaded tube or pipe cast fittings of malleable cast iron; safeguard investigation into imports of grain-oriented electrical steel; and further updates.

law
News update
UK customs and trade news: March 2026

UK customs and trade news: March 2026

02 Apr 2026

News in brief: new Steel Strategy published; small and medium-sized enterprise action plan published; updates on future EU-UK SPS agreement; tariff notices on the tariff classification of ballot (box) partitions and animal feed issued; guidance on classification of toys and games republished; new versions of the certain reference documents published; definitive anti-dumping duty on tin mill products originating from China imposed; safeguard measure: tariff-rate quota on steel goods changed; registration of imports of glass containers originating from China and Turkiye as well as imports of rutile titanium dioxide originating from China introduced; UK-Norway, Iceland, and Liechtenstein, UK-Turkiye, UK-Swtzerland, UK-Nigeria negotiations updates; and further updates.

law
News update
Ukraine customs and trade news: February / March 2026

Ukraine customs and trade news: February / March 2026

02 Apr 2026

News in brief: events supporting the European integration of Ukraine; changes in authorisation for customs procedures; reassessment of companies' financial solvency compliance; the start of automatic processing of import declarations; new anti-dumping investigations regarding imports of steel bars and angles from Turkiye, and welding equipment from China; licensing regime for the importing certain products from Moldova to be introduced; and other updates.

law
News update

Topic spotlight

Illusion of savings: the real cost of trade and customs non-compliance

Illusion of savings: the real cost of trade and customs non-compliance

Peter J.M. Bulters
Peter J.M. Bulters
08 Feb 2026

This article poses a straightforward yet unsettling question: what is the true cost of 'saving' on trade compliance? Against a backdrop of volatile regulation and enforcement, it reveals how apparent savings can quietly turn into significant strategic risks.

compliance
Topic spotlight
The end of IEEPA tariffs: what importers must do now

The end of IEEPA tariffs: what importers must do now

Christopher Matt
Christopher Matt
01 Mar 2026

The US Supreme Court’s 20 February 2026 ruling limits presidential emergency powers, confirming that IEEPA cannot be used to impose tariffs. For companies, this creates potentially billions in refund claims and requires urgent attention to the new temporary Section 122 tariffs, which carry strict limits and a 150-day sunset. Meanwhile, broader trade enforcement under Sections 232, 301, and 338 remains in force, keeping compliance and strategic planning critical. The article also examines practical steps for protecting refund claims, navigating Section 122 exemptions, and assessing the impact on ongoing US import strategies.

taxes and tariffs
Topic spotlight
HS 2028 revision: key changes and how to prepare

HS 2028 revision: key changes and how to prepare

Eglė Pučkuvienė
Eglė Pučkuvienė
29 Mar 2026

This article reviews the changes introduced in the HS 2028 revision. A total of 299 sets of amendments have been introduced, covering areas such as healthcare, epidemic control, emergency preparedness, environmental protection, green transition technologies, the circular economy, recycled goods and the fight against illicit trade. It also provides businesses with insights into how they can prepare for these changes.

classification
Topic spotlight

Perspective

Stability in times of uncertainty: PIFFA’s perspective on the future of logistics in Europe

Stability in times of uncertainty: PIFFA’s perspective on the future of logistics in Europe

Marek  Tarczynski
Marek Tarczynski
10 Feb 2026

The interview underlines the increasing complexity of trade and customs compliance for the logistics sector, driven by sanctions regimes, environmental regulations, tighter border controls and ongoing EU Customs Code reforms. It points to Poland’s growing importance as a regional logistics hub and the disruptive effects of the war in Ukraine on supply chains, while stressing the value of digital customs systems, recognised compliance statuses such as AEO, continuous professional training and effective industry representation. Overall, the discussion highlights resilience, cooperation and regulatory clarity as critical factors for a stable and compliant European trade environment.

other
Perspective
Modernising EU Customs: a perspective from the European Shippers' Council

Modernising EU Customs: a perspective from the European Shippers' Council

Godfried Smit
Godfried Smit
15 Mar 2026

In this interview, Godfried Smit, Secretary General of the European Shippers’ Council, shares his reflections on the EU Customs Reform. From the future EU Data Hub and the growing importance of high-quality supply chain data to the practical steps companies should already be taking, the interview offers an insider’s view from Brussels on how the reform is evolving - and why businesses, particularly SMEs, should start preparing now rather than waiting for the new rules to arrive.

other
Perspective
How AI is revolutionising international trade compliance research

How AI is revolutionising international trade compliance research

Nate Young
Nate Young
30 Mar 2026

Different companies are integrating AI tools into international trade compliance in various ways, depending on their specific requirements, data environments and appetite for risk. This article introduces readers to the approach of US law firm Crowell & Moring LLP: using an in-house AI system for routine legal tasks and the secure handling of sensitive information, alongside a third-party platform for large-scale data analysis and trend identification. The article provides practical insights into how AI is already transforming trade compliance work, and emphasises that the manner in which firms implement AI is now more important than ever.

Tech
Perspective

Explainer

CBAM as seen by the customs representative

CBAM as seen by the customs representative

Evguenia Dereviankine
Evguenia Dereviankine
03 Mar 2026

Customs representatives navigating the Carbon Border Adjustment Mechanism (CBAM) face responsibilities that vary significantly depending on the type of representation they provide. This article examines how liability is allocated under direct and indirect representation, when a customs broker must obtain authorised CBAM declarant status, and the legal and financial consequences that follow, including annual declaration obligations, certificate surrender requirements, and direct exposure to CBAM costs. Practical guidance is also provided on refusing CBAM liability and structuring representation contracts to manage financial risk.

sustainability
Explainer