The proposed reforms to the EU customs framework not only signal significant changes for trade with the EU—they also reflect broader global trends, including developments underway in the United States. Over the past several months, U.S. trade policy has shifted rapidly, including the July announcement of new tariffs and an expanded rollback of the de minimis exemption. While some of these changes have been delayed or adjusted, it would be a mistake to assume that trade policy will return to pre–“America First” norms.
As the EU’s reform package illustrates, many of the U.S.’s recent changes align with global trends aimed at modernizing customs operations, addressing e-commerce challenges, and enhancing supply chain transparency, though the EU’s approach is more gradual.
EU Customs Reform: Key Components
A New Customs Framework Mandate
On June 27, 2025, it was announced that EU Member States adopted a common negotiating mandate to modernize the Union Customs Code (UCC). This sets the stage for formal negotiations with the European Parliament and eventual adoption of a significantly revised framework.
The current Union Customs Code (UCC), introduced in 2016, has struggled to keep up with the surge in trade volumes, the rise of e-commerce, and growing safety concerns. Member States have applied customs rules inconsistently, undermining the Customs Union’s integrity.
Objectives of the reform include:
- Harmonizing customs enforcement across the EU
- Enhancing product safety and regulatory oversight
- Creating a level playing field for EU-based businesses vs. low-cost imports
- Cutting customs-related red tape by 25%, improving competitiveness and efficiency
Key changes of the new framework include:
- Creation of a European Customs Authority (EUCA) to coordinate risk management and crisis response across Member States.
- Launch of an EU Customs Data Hub, centralizing customs declarations via a single EU-wide digital platform, replacing fragmented national systems.
Trust & Check: Streamlining for Trusted Traders
The reforms introduce a new “Trust & Check” designation for highly compliant businesses. These companies, which meet strict transparency and data-sharing standards, will benefit from:
- Simplified customs procedures
- Fewer physical inspections
- Streamlined, EU-wide customs clearance
This builds on the current Authorised Economic Operator (AEO) program, with additional support tailored to small and medium-sized enterprises (SMEs).
Tackling the e-Commerce Surge
To address the massive influx of low-value goods, especially from online platforms, the EU reform package includes:
- A €2 handling fee for parcels shipped directly to EU consumers
- A reduced €0.50 fee for goods sent from EU-based warehouses
- Elimination of the €150 de minimis exemption, requiring all sellers to register for VAT and act as importers, making them responsible for product safety and compliance
Major online platforms such as Temu, Shein, and Amazon Marketplace would be held liable for unsafe or illegal goods and must collect VAT and duties at the point of sale.
Next Steps & Timeline
- Trilogue negotiations between the Council, Commission, and Parliament are underway.
- Final adoption is expected following agreement by all three institutions.
- Phased implementation will begin with the European Customs Authority and Data Hub, with e-commerce provisions prioritized in early stages.
What This Means for EU Stakeholders
- For businesses: Streamlined customs but stricter compliance, especially for online sellers.
- For consumers: Likely higher costs on low-value imports, but improved safety and reduced unfair competition.
- For Member States: More efficient risk management, better EU-wide data oversight, and revenue from handling fees.
Parallels and Lessons for the US
1. Modernization of AEO programs
The U.S. version of the AEO model is the Customs-Trade Partnership Against Terrorism (CTPAT) program. While incremental improvements to CTPAT are frequently discussed (e.g., through the Commercial Customs Operations Advisory Committee (COAC)), there is no plan for a revamp as comprehensive as the EU’s Trust & Check scheme.
As we’ve discussed in our podcast, Customs & Cocktails, AEO and CTPAT programs globally must evolve to stay relevant in a world of rapid technology changes improving trade and customs processes. The EU’s Trust & Check program could serve as a future model for reform in the U.S.
2. E-commerce and the End of De Minimis:
The exponential rise of e-commerce has strained U.S. Customs and Border Protection (CBP) for several years now, particularly due to the de minimis exemption. As we’ve noted in the past, CBP has been seeking changes to the de minimis rules to address this. However, these changes have been much quicker than expected, as so far in 2025 changes have included:
- In early 2025, the U.S. eliminated the exemption for imports from China and Hong Kong.
- As of August 29, 2025, the exemption will end for all countries under a new Executive Order.
- The One Big Beautiful Bill Act mandates a full de minimis phase-out by July 1, 2027, and introduces penalties for misuse.
While the U.S. rollout has been swift, we expect these changes to survive future shifts in political leadership.
3. Risk Management & Data Transparency
Unlike the EU, the United States operates under a centralized customs authority – Customs and Border Protection (CBP)– with an established risk management system that integrates data from multiple federal agencies.
However, recent enforcement trends show that CBP is moving beyond centralized oversight and increasingly pushing traders themselves to strengthen internal risk management and supply chain transparency. Notably, regulations targeting forced labor in supply chains now require all importers—not just CTPAT-certified entities—to demonstrate full end-to-end visibility, regardless of supply chain complexity.
Similarly, the EU’s customs reform and accompanying regulations on forced labor, deforestation, and carbon border adjustments reflect a parallel shift: traders are being required or strongly incentivized to maintain granular, verifiable data on their supply chains and share that data proactively with authorities.
This alignment between the U.S. and EU underscores a growing global expectation: supply chain transparency and risk governance are no longer optional – they are core compliance obligations.
Final Takeaway
The EU’s customs reform effort offers a window into how customs authorities worldwide are adapting to the complexities of modern trade. While the U.S. has taken a faster and more unilateral approach, many of the underlying drivers—data transparency, e-commerce accountability, and risk-based oversight—are the same. As trade becomes more digital and dispersed, governments will demand greater transparency, accountability, and coordination. Businesses that prepare for that shift will be best positioned to succeed.
CT Strategies is a team of global customs and trade experts that help businesses ensure they are complying with today’s regulations, while preparing them for the future trade environment. Check out our services to see how we can support your company.
