Customs Compliance & Risk Management

Dear Reader,

Meet Sanne and Clara. You will not find them on LinkedIn: our authors created them. But the working days they describe are real enough - Sanne's in January 2028, Clara's in September 2036 - and they may well be yours.

Sanne is a customs representative in Rotterdam with three import declarations to lodge. Soluble coffee from Vietnam is now covered by the EU Deforestation Regulation. Nitrile gloves from Malaysia are not, although natural rubber gloves under the same subheading are. Stearyl alcohol made from palm kernel oil takes her the rest of the morning. Which of the three would take you longest? Delegated Regulation (EU) 2026/2102 removes some products from the list from 30 December 2026 and adds others from 30 December 2027. Almost every entry is now marked 'ex', so the commodity code alone no longer tells you whether goods are covered.

Clara runs a customs representation company in Antwerp. In our authors' model, a container from Taiwan is released for free circulation for her client without anyone lodging a declaration. The new Union Customs Code, Regulation (EU) 2026/2108, was published on 19 September 2026. Some of its provisions apply since 20 September 2026. Most apply from 21 September 2027, and the code is phased in until 1 March 2034. From then on, customs declarations can no longer be lodged: importers will provide their data through the EU Customs Data Hub.

Meanwhile, other rules require new information about the supply chain. Since 1 October 2026, the declarant of steel products covered by Regulation (EU) 2026/1384 must hold evidence of the country where the steel was melted and poured when the declaration is lodged. Without it, the goods are not released. From 14 December 2027, an authority investigating under the forced labour ban, Regulation (EU) 2024/3015, may ask who made the product and at which site.

Responsibility stays with people. Ramūnas Šablinskas explains why using customs compliance tools does not move it away from the person who lodges the data. Michael Lux analyses a German case now before the Federal Fiscal Court, in which a wrong EORI number made the representative liable for import VAT it cannot deduct.

The issue also covers BTI decisions revoked after the 76th HS Committee session, composite goods, BTI challenges, design costs in customs value (C-307/23), a defective origin certificate, the 21st sanctions package, the 50% rule in sanctions, packaging rules and other topics.

I hope this issue gives you useful insights for today and helps you prepare for days like Sanne's and Clara's.

Enrika Naujokė