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The new Union Customs Code: what your business needs to know about the 5 most important reforms

04 Aug '25

Author(s): Irene Stassen

The customs union is on the verge of major changes. The EU is expected to take a decision on the new, ambitious Union Customs Code (hereinafter: ‘nUCC’) before the end of this year. This new legal system must be fully operational by 2038. Companies that trade internationally—in particular (customs) forwarders and logistics service providers—will face far-reaching new customs obligations. This blog discusses the 5 most important reforms.

Reasons for new customs legislation

Customs authorities in EU Member States are under pressure. Their tasks are broad and complex, ranging from ensuring safety and health to protecting the economy and the environment. At the same time, the volume of customs declarations has exploded in recent years due to the increasing number of e-commerce shipments from countries such as China. This overload means that customs authorities are no longer able to perform their tasks properly, undermining centralised supervision and control of the supply chain. The nUCC is intended to make the current system more future-proof.[1]

The nUCC: the most important upcoming changes

The new Customs Code aims to fundamentally simplify and modernise the customs process. Below, we discuss the most fundamental changes:

1. The EU customs data hub

Currently, each national customs authority works with its own national IT system. The nUCC will change this with the introduction of an EU customs data hub. In concrete terms, this means that the customs authorities of the Member States will soon be working with and retrieving information from a single centralised digital environment. The data hub should make it easier to collect and process information from various parties involved for the purposes of EU customs risk management and to share it with other competent authorities. This will give agencies such as OLAF (European Anti-Fraud Office), EPPO (European Public Prosecutor's Office), Europol, Frontex (European Border and Coast Guard Agency) and national supervisory authorities access to this data, including sensitive (privacy) information. This decision was made to strengthen mutual cooperation and combat fraud and smuggling within the Community.[2] In short, the EU customs data hub will help European authorities to perform their supervisory tasks better and more efficiently.

The change will affect not only customs authorities, but also customs agents, importers and exporters. The traditional declaration system as we know it is being overhauled; instead of submitting a declaration, companies will now provide 'data' via this centralised, uniform platform.[3]  Exactly how this will work in practice has yet to be determined. Whatever the case, the shift from declarations to data delivery will require your company to invest in IT and compliance. In return, the future system will be more transparent and efficient. Moreover, declarations will reportedly be processed more quickly.

The data hub must be fully operational by 2037, although market participants will be able to meet their reporting obligations from 1 March 2032. [4]

2. A central EU customs authority

The nUCC also introduces a new European body: a central customs authority. One of the main tasks of this new EU agency  will be to develop and manage the data hub discussed above.[5]

The idea behind a centrally managed information system is that risks and control areas can now be identified at a common level. This will enable more targeted checks, which is expected to lead to more effective detection and prevention of customs fraud.[6] In future, your company may therefore be approached by Dutch customs for an administrative or physical check because shipments originating from your supply chain have been identified as high-risk by the EU customs authority.

The EU customs authority will start its activities on 1 January 2028.[7]

3. Abolition of the €150 exemption

Currently, there is an exemption from import duties for parcels with a value of up to €150.[8] In order to promote fair competition and protect the environment, it is proposed to abolish the exemption from import duties for shipments with a value of €150 or less.[9] At the same time, the EU is working on creating a simplified system for determining customs duties on distance sales.[10]

If the EU adopts this proposed abolition, the plan is for the exemption to expire in 2028. The simplified tariff treatment will enter into force on 1 March 2028.[11]

4. New responsibilities for representation

Under the nUCC, only one party will be liable for the actual completion of customs formalities. In most cases, this will be the importer or exporter themselves. This party will also be responsible for complying with all customs obligations. Indirect representation will remain possible, however, with the customs agent acting as the declarant and therefore liable.[12]

It is not yet clear when these new rules will come into force.

5. Trust & Check

From 1 March 2032, your company can be designated as a 'Trust & Check partner' by the national customs authority. This status grants additional benefits—such as fewer and more targeted customs checks, periodic payments and the ability to release goods yourself—to transparent, reliable companies. This status will replace the current Authorised Economic Operator (AEO) status. However, customs will have access to your IT system at all times to ensure transparency and compliance with customs obligations.[13]

How your company can prepare for the new legislation

The shift from traditional customs declarations to data delivery via the EU customs data hub requires timely investment in your IT systems, coordination with software suppliers and training for your employees and customs declarants.

Trust & Check requires real-time data exchange from your company, demonstrable control over goods flows and compliance with strict standards. By investing in your digital infrastructure and compliance in good time, you have a better chance of retaining or obtaining customs benefits.

Conclusion  

Customs legislation will undergo radical changes in the coming years. Ploum is closely monitoring these changes. Companies that trade internationally will be faced with new customs law issues. Is your company already prepared for the new legislation and regulations, or would you like to know more about how you can comply with the upcoming new obligations? Please contact us. The Customs, Trade and Logistics team has all the knowledge you need to advise your company. If you have any questions about the above, please feel free to contact Arjan Wolkers (a.wolkers@ploum.nl), Jikke Biermasz (j.biermasz@ploum.nl) or Irene Stassen (i.stassen@ploum.nl).

 

[1] Proposal for a Regulation of the European Parliament and of the Council laying down the Union Customs Code, establishing the European Union Customs Authority and repealing Regulation (EU) No 952/2013 (COM(2023) 258 final) of 16 May 2023 (hereinafter: ‘Proposal nUCC’), p. 1-3 & recitals 2-6.

[2] nUCC Proposal, p. 13; recitals 4 & 18-28.

[3] nUCC proposal, p. 19; recital 40.

[4] Article 265(3)-(4) in conjunction with Article 29 Proposal nUCC.

[5] Proposal nUCC, pp. 13-14.

[6] Article 51(5) in conjunction with Articles 53-54 in conjunction with Articles 207-208 Proposal nUCC.

[7] Article 265(1) Proposal nUCC.

[8] However, customs clearance costs and VAT must still be paid for these parcels.

[9] Proposal nUCC, pp. 11-12. High-value orders are currently split into several shipments of less than EUR 150 in order to benefit from the exemption. Abolishing the exemption will curb these practices.

[10] Proposal nUCC, p. 20; recital 40.

[11] Article 265(2) nUCC proposal.

[12] Proposal nUCC, recital 17; Article 27 nUCC.

[13] Proposal nUCC p. 12; recital 16.

Contact

Attorney at law, Partner

Jikke Biermasz

Expertises:  Customs, Transport law, Insurance law & Liability law, Food safety & product compliance , Customs, Trade & Logistics, Food, Transport and Logistics, Customs and International Trade, International Sanctions and Export Controls, E-commerce,

Senior associate

Arjan Wolkers

Expertises:  Customs, Customs, Trade & Logistics, Transport and Logistics, Customs and International Trade,

Attorney at law

Irene Stassen

Expertises:  Insurance law & Liability law, Transport law, Customs, Customs, Trade & Logistics, Transport and Logistics, Customs and International Trade,

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