On February 27, 2025, the Legislative Resolution of the European Parliament of March 13, 2024, which establishes the proposal for the new Union Customs Code (UCC), was published in the Official Journal of the European Union. This new regulation would repeal Regulation (EU) No. 952/2013.
This new legal framework aims to modernize and harmonize customs regulations, adapting them to today’s international trade.
What is the new union customs code and why is it necessary?
The new Union Customs Code (UCC) aims to establish the regulatory framework for the future common customs system. This reform, which expressly plans to repeal Regulation (EU) No. 952/2013— in force since 2016— responds to the need for a deep modernization of customs operations throughout the EU.
The approach of this new Regulation is based on a series of deficiencies identified, as well as the evolving demands of international trade. The European legislator has identified several key reasons that justify this comprehensive reform:
- Inefficiency of the current system
- Growth of cross-border e-commerce
- Insufficiency of current customs controls
- Need to unify and strengthen the EU customs system
Key innovations in the new union customs code
The new Union Customs Code seeks to mark a turning point in EU customs legislation. Below, we clearly and thoroughly explain the main innovations this ambitious reform introduces:
European union customs authority
First, this new body will coordinate customs procedures at the European level. It will ensure uniform application of customs law, oversee authorizations granted to economic operators, and manage digital systems. It will ensure legal consistency between Member States and strengthen control and transparency in international trade within the Single Market.
Full digitalization of the customs system
The gradual elimination of paper-based declarations is planned, to be replaced with fully electronic procedures. Risk assessment will be automated, and national systems will be integrated into a common European platform.
Additionally, the new Regulation introduces the “EU Customs Data Hub”, which will centralize the management of customs declarations, eliminating the need to submit them separately to each national administration. This single database will allow for homogeneous, transparent, and automated processing across the EU.
Reform of the authorised economic operator (AEO) status
The regulation will strengthen the requirements for obtaining AEO status, raising standards for traceability, regulatory compliance, and transparency.
Modernization of customs representation
The new Union Customs Code also redefines the role of customs representatives. Legal responsibilities will be clarified for both direct and indirect representation, and new obligations will be introduced.
Introduction of the “Deemed Importer” in e-commerce
The “deemed importer“ is a person or entity considered responsible for an import for customs purposes. This will mainly apply to e-commerce and will affect digital platforms, marketplaces, and logistics operators.
Under this new concept, platforms themselves will be responsible for complying with customs obligations, paying duties and taxes, and ensuring adherence to EU quality and safety regulations.
💡Practical Example: A consumer in Belgium purchases a product from a Chinese platform (seller not established in the EU). Under the new system, the platform facilitating the transaction will be the deemed importer and will be responsible for declaring and paying the corresponding VAT and customs duties.
Summary of the main new features proposed in the new Union Customs Code (UCC)
| New feature | Description | Expected implementation date |
|---|---|---|
| EU customs data hub | Creation of a centralized digital platform acting as a single window for submitting customs information, simplifying or eliminating the need for individual declarations. | From 2028 for e-commerce; from 2032 for other operators. |
| EU customs authority | Establishment of a decentralized agency responsible for EU-wide risk assessment, harmonizing customs controls across Member States. | From 1 January 2028. |
| “Trust and check” operators | A new category of trusted operators that benefit from simplified customs processes, requiring online access to commercial and transport records by authorities. Will gradually replace the Authorised Economic Operator for Customs Simplifications (AEOC). | Applications from 2032; AEOC phase-out by 2035. |
| E-commerce reform | Removal of the customs duty exemption for shipments under €150, transferring responsibility for payment of duties and taxes to e-commerce platforms (introduction of the “Deemed Importer” concept). | From 1 March 2028. |
| Harmonized system of customs infringements and penalties | Implementation of a common EU-wide framework for customs infringements and penalties, eliminating disparities between Member States. | Not specified. |
| Reduction of the temporary storage period | Reduction of the maximum time for linking goods to the temporary storage procedure from 90 to 3 days, eliminating Temporary Storage Warehouses (TSW), which must be converted into Customs Warehouses. | Not specified. |
| Reform of customs procedures | Renaming and reorganization of special customs procedures into categories such as Transit, Storage, Special Destination, and Processing. | Not specified. |
How does the new Union Customs Code affect importers and exporters?
Greater efficiency, tighter control
The new EU customs framework not only aims to modernize processes, but also to establish stricter control over international operations under Union law. On the one hand, economic operators will enjoy substantial efficiency benefits. Key advantages include:
- Centralized clearance: Thanks to digitalization and the new EU Customs Data Hub, businesses will be able to manage their operations through a single customs authority, even when multiple Member States are involved.
- Reduced administrative costs and times: Centralized platforms will simplify procedures and minimize duplicated documentation.
- Improved traceability: The digital system will enable more accurate, real-time tracking of goods throughout the logistics chain.
What legal risks arise with the new regulation?
However, operators must be prepared to face new risks derived from this more demanding environment. In particular, they must take into account more frequent automated controls, intensive data analysis by the future EU Customs Authority, and possibly more systematic and less predictable audits.
With growing automation, any error or inaccuracy in the declared information could lead to immediate, uniform, and automated sanctions across the EU. This requires economic operators to maintain tight internal control of their data and processes.
What should businesses do to prepare for the new Union Customs Code?
Although many provisions of the new Union Customs Code (UCC) will be implemented gradually, businesses must begin preparing today. Delaying could mean being left out of the market, facing logistical delays, or even incurring penalties for non-compliance. Recommendations to start preparing now:
| 💡Recommendation | Description |
|---|---|
| Internal audit of current customs procedures | Analyzing procedures allows you to identify weaknesses and opportunities for improvement in light of the new UCC requirements. |
| Evaluate compliance with the “trust & check” profile | Assess whether your business meets the criteria and what adjustments are needed to qualify. |
| Reorganization of Temporary Storage Warehouses (TSWs) | The UCC introduces changes to the management of TSWs. If your business relies on them, it’s essential to review their structure and operation. |
| Review of e-commerce flows | Crucial if you operate as a marketplace or sell to end consumers. The new framework will impact shipment management and customs obligations. |
| Strengthening of compliance and document automation areas | Traceability and document control will be key. Investing in compliance will help you avoid risks and penalties. |
Real cases: how we have helped our clients
- Spanish agri-food exporter: We reorganized their tariff classification system and adapted their logistics contracts to anticipate the elimination of TSWs and comply with future customs warehouse requirements.
Result: 30% reduction in clearance times and elimination of the risk of penalties. - E-commerce platform in Belgium: We identified their responsibilities as a “deemed importer,” renegotiated agreements with Asian suppliers, and implemented a customs traceability system.
Result: Full compliance with the new UCC and improved consumer reputation. - French tech startup: We helped a tech startup correct errors in their tariff classification and identify their obligations under the new UCC, including customs representation before the EU.
Result: 45% reduction in operating costs and immediate release of goods.
Ready to adapt to the new Union Customs Code?
The UCC 2028 reform is already underway. At Arthur & Marin, we help you get ahead: we prepare your business for the changes in the new UCC with practical, legal, and strategic solutions. We are experts in International trade law and corporate law.
Avoid penalties, speed up your clearance processes, and ensure legal compliance starting today.
📩 Write to us at info@arthurmarin.com
📞 Call us at +32 465 345 345
Contact us today and get expert guidance.
