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Back Expert insights into the EU Customs Reform

In 2023, the European Commission proposed a comprehensive reform of the EU Customs Union. These changes are considered the most ambitious transformation since the union was established almost 60 years ago.

On June 6th, Kuehne+Nagel hosted a webinar with over 700 participants to illuminate the proposal’s core elements and explore what it means for businesses trading in the region.

Over the course of what was a thrilling discussion, Kuehne+Nagel’s customs expert, Jennifer Kotula, National Customs Manager, covered the following topics:

  • Understanding the historical context of the EU Customs Reform
  • Examining key changes in the EU customs framework:
    —  Trust & Check traders
    —  EU Customs Data Hub
    —  New realities for e-commerce
  • Assessing the impact and future implications of the EU Customs Reform

Ready to unravel the EU Customs Reform? Watch our webinar recording and read our experts’ answers to the audience's questions.


Webinar Q&A

Trust & Check (T&C) traders/Authorised Economic Operator (AEO)

Unlike AEO, the criteria for granting the status of a T&C trader include product safety standards and an electronic system that makes real-time data, such as tracking information and commercial and transport records, available to the authorities.

Companies must check whether the customs simplifications granted for AEO C (Customs) or AEO F (Customs and Security) will still be needed. If so, they must check if they qualify for T&C trader status and apply for it to benefit from the customs simplifications.

AEO S (Security) will remain in place, covering obligations and benefits.

T&C trader status is not automatically granted to AEO holders. Enterprises must apply for it.

It currently needs to be decided if the process is easier or faster for AEO status holders.

No, it is too early to provide a trustworthy estimation.

According to the actual information, it will be a separate process. You can directly apply for the T&C trader status.

A company can do so if it meets the outlined criteria. You can find out more here.

Yes, real-time data information provided to the EU Customs Authority, including information on product safety, adheres to a higher standard than AEO requirements.

The simplification of AEO C will be phased out as part of AEO F. This means that traders interested in simplified customs procedures will need to apply for T&C trader status.

No, the company needs to be registered in the EU.

As soon as the regulation and its delegating acts come into effect—unless a deviating deadline is announced. The authorities will assess whether AEO C holders qualify for T&C trader status.

Yes, it will include simplifications, such as clearly defined obligations and responsibilities, in exchange for benefits that ease international trade.

No, like the current AEO programme, it won’t be mandatory. However, being a registered T&C trader means you will benefit from the abovementioned simplifications.

You can still declare goods if you are a T&C trader. The role of agents and forwarders is still being discussed.

EU Customs Data Hub/Trader Portal

Standardisation may lead to better access to data. Data availability, the criteria for when data can be shared, and with whom it can be shared might help economic operators get better access. Secondly, according to the plans, T&C trader status opens the door for a responsible partnership in both directions.

It is not explicitly mentioned in the proposal but is not excluded. It might be part of the delegating acts or be relevant during the further legislation process.

There are currently no specifications regarding how the exchange will occur or which system will be connected.

Although you can still use a customs broker, as a T&C trader it is not a necessity.

Member states need to develop applications to connect to the EU Data Hub. They can also request EU customs authorities to do so on their behalf. The financial effort needs to be covered by the member state.

Member states will determine which systems are connected to the EU Customs Data Hub. It is too early to provide detailed information.

The proposal does not specifically mention this. However, the possibility remains that EU and member state systems can coexist, at least during the transition.

The proposal does not specifically mention this. However, it is still possible for EU and member state systems to coexist, at least during the transition.


This only applies to distance sales to EU consumers, specifically under the jurisdiction of Article 14 (4) (2) VAT Directive 2006/112. To reduce effort, the duty rates follow a lump sum approach and are categorised into a five-tier bucket system. The tiers are as follows:

  • 0%: goods currently at 0% will continue to benefit (7 chapters)
  • 5%: toys, games, and houseware articles (26 chapters)
  • 8%: silk products, carpets, and glassware (32 chapters)
  • 12%: cutlery, electrical machinery, and clothes (9 chapters)
  • 17%: food, beverages, tobacco, and footwear (21 chapters)


They only apply for distance sales from a third-country party to an end consumer.

Yes it does, and duties will be applicable from €0.01.

No. The data needs to be accurate and specific, not only for customs purposes but also for risk assessments conducted by authorities.

Harmonised System (HS) codes

Yes, but not specifically as part of the reform. They are part of a regular amendment.

There are existing rules for classification. If the product is mentioned specifically in the tariff, this code must be used for clearance. If there are any uncertainties, you can apply for Binding Tariff Information (BTI).

There is a regular process for amending tariff codes and measures.

Impact of the EU Customs Reform/Outlook

First and foremost, the authority will oversee the EU Customs Data Hub. The new authority will also contribute to implementing an enhanced EU strategy for risk management and customs inspections.

Yes. This will be available for AEO C holders and probably for T&C traders, too (although the latter has yet to be explicitly mentioned).

No, simplified procedures like “entry in the declarant's records” will remain available.

No, there aren’t any significant changes yet.

Yes, it is still possible. There are ongoing discussions on the mode of representation.

Yes, there is no change to this.

The reform doesn’t even mention CBAM. It is too early to answer this question. However, there will be an exchange of data between different authorities. Whether this exchange will ease the reporting procedure is yet to be determined.

There are several topics. The main ones are:

  • The temporary storage procedure—the proposal of three days by the EU Commission versus the 90 days proposed by Internal Market and Consumer Protection (IMCO).
  • Additionally, the IMCO increases the responsibility for T&C traders regarding compliance standards, specifically the product safety category. For small- and medium-sized businesses, a digital product passport can be made available to authorities to prove safety standards instead of having an electronic system in place.
  • During a five-year grace period starting from 1 January 2029, direct representatives can be recognised as T&C traders for small or micro-enterprises.

They should assess the compatibility of their current record-keeping systems with the new method of exchanging data with customs authorities. They should also evaluate the impact of the abolished customs duty exemption and the introduction of new customs duty categories on their imports. Finally, they should also determine the potential benefits of the new T&C category for their business.


It has yet to be officially announced. The IMCO proposal includes implementing a national EU Single Window Customs coordinator. This role would be the single point of contact for the EU Commission and promote cooperation between authorities on a national level.

This topic is still part of the negotiation process, especially for midsize and small enterprises that cannot obtain T&C trader status.

Are you interested in learning more about the EU Customs Reform? Visit the European Commission for more information. Additional details can also be found on your local chamber of commerce and customs websites.