The European Union has politically agreed on the most ambitious overhaul of its customs framework since the customs union was established in 1968. Across the Channel, the United Kingdom is pursuing its own, though earlier-stage, customs modernisation agenda, the first since its withdrawal from the EU. Together, these reforms will reshape how goods move across Europe’s borders.
This briefing is the fourth in our Customs Reform Unpacked series. The EU Customs Data Hub is the digital backbone of the new Union Customs Code and implementing laws (together, the EU Customs Reform or the Reform). It is designed to replace the traditional customs declaration process with a centralised, real-time data exchange platform connecting economic operators, customs authorities, and a wide range of enforcement bodies across all EU Member States. Its implications touch every aspect of customs operations, from what data is shared with the authorities and how, to who bears liability, to how controls are coordinated.
Where this fits
The most impactful operational change introduced by the EU Customs Reform is the elimination of the customs declaration as we know it. Today, goods entering or leaving the EU are subject to a customs declaration: a formal, structured submission filed by a declarant to customs. This process, while digitised in all Member States and subject to a common dataset, remains subject to local differences across the EU due to IT system variations, differences in approaches to the content of data elements, and limitations on what data can and must be provided to customs in electronic form.
The new Union Customs Code replaces this model with an EU-wide, data-driven approach. Rather than requiring the submission of a shipment-by-shipment customs declaration, importers and exporters will submit relevant customs and product data, including supporting documents that currently need only be held at the disposal of customs, directly to a centralised EU Customs Data Hub (the Data Hub). The data will be collected at Union level through a single platform. It will then be made available to Member States’ customs authorities, which will process it to exercise controls and collect customs duty (not necessarily in that order). Several other national and EU enforcement agencies will have access to the data in the Data Hub, including the new EU Customs Authority.
Key changes introduced by the Reform
- New, additional data must be submitted. Under the new Union Customs Code, importers and exporters must provide or make available significantly more data than under the current customs data model. The identity of the person responsible for product compliance, details of the applicable product laws, and supporting documentation, such as certificates, authorisations, and compliance records, that currently need only be held at the disposal of customs authorities will be part of the new dataset. Supporting documents will have to be submitted to or made available in the Data Hub, enabling customs and enforcement authorities to verify compliance proactively. The Data Hub is designed to cross-check this compliance data against connected EU systems, meaning that a missing product safety certificate, an IP infringement report, or an environmental compliance gap flagged in one regulatory domain becomes immediately visible at the customs touchpoint and can trigger a hold, refusal, or control decision before goods are released.
- No “declarant”, but “importer (for distance sales)”. The declarant role will disappear in stages: from 1 July 2028 for importers for distance sales, and from 1 March 2034 for all other operators. For importers for distance sales, the Data Hub becomes the exclusive data channel, and the importer becomes the debtor for customs duty from 1 July 2028, provided that the Data Hub is ready by then. For other operators, this shift occurs at the latest on 1 March 2034. In both cases, the Data Hub will create a single, traceable record linking compliance failures directly to the importer. The importer’s role will become more important from October 2027, when the substantive provisions redefining non-fiscal obligations become legally applicable through regular customs declarations.
- Operators must link their data.The Data Hub will require carriers, importers, and exporters to contribute their respective data (e.g., advance cargo and pre-departure information) and actively link it to a shared consignment reference, rather than submitting separate, unconnected datasets. Gaps or inconsistencies between linked submissions will be visible to authorities, requiring much closer coordination between supply chain partners.
- Record-keeping moves into the Data Hub. Operators holding special procedure authorisations, running warehouses, or involved in storage, processing, or sale of goods under customs supervision will have to feed their records directly into the Data Hub, not simply keep them for inspection. This will enable continuous customs monitoring and require integration of warehouse management, accounting, and logistics systems with the centralised platform.
- Businesses have access to clearance data. The Data Hub will provide businesses with a right to process the data they have submitted. This means that importers and exporters will be able to access their own customs transaction data, verify how it was processed, audit their compliance position across consignments, and identify and correct errors in data previously submitted to customs authorities. This represents a significant improvement over the current environment, where access to clearance data is often fragmented across national systems and dependent on the customs broker’s own record-keeping.
- Broad authority access to data in the Data Hub. The Data Hub will not be reserved for customs authorities alone. It will serve as a shared enforcement resource: the EU Customs Authority will access it for Union-level risk management, leveraging advanced analytics, including artificial intelligence, to identify patterns, predict risks, and generate actionable enforcement signals. The European Anti-Fraud Office (OLAF) will access it for anti-fraud investigations, the European Public Prosecutor’s Office (EPPO) for customs-related criminal prosecutions, Europol for cross-border crime analysis, and Frontex for border-management risk assessment. National tax authorities will be able to process Data Hub data to determine excise and VAT liabilities. Market surveillance and food safety authorities will be able to use it to verify product compliance at the border. The Data Hub’s enforcement reach will be further amplified by its interoperability with other EU systems, including the EU Customs Single Window Certificates Exchange System. This marks a fundamental shift from the current position, where enforcement authorities must typically request customs data through bilateral channels or rely on separate information systems with limited interoperability.
- Penalties become visible across the EU. All non-criminal customs penalties will be recorded in the Data Hub, creating a pan-European penalty register. An infringement in one Member State will form part of the operator’s EU-wide risk profile and will influence how all other customs authorities assess that operator’s consignments from a risk management standpoint. The new Union Customs Code is largely silent on criminal penalties, indicating that these remain governed exclusively by Member State law.
- Automated decisions carry full legal weight. Many Data Hub processes, risk assessments, release decisions, and duty calculations will be automated. The Reform confirms that these automated acts are legally attributable to the relevant authority or operator. Operators can challenge automated decisions; at the same time, they cannot disclaim responsibility for data submitted through automated system interfaces.
- Protection of commercially sensitive data. Operators will be able to restrict access to their commercially sensitive information (e.g., transport costs and routing details) by other parties contributing data to the same consignment. Customs authorities will retain full access, but commercial counterparts in the supply chain will not be able to see shielded data.
When does this apply?
The transition from customs declarations to the submission of data in the Data Hub follows a differentiated phased schedule. Distance sales operators face the earliest cut-off: from 1 July 2028, importers for distance sales and users of the VAT Import One Stop Shop must provide data exclusively through the Data Hub, and the declarant role ceases for these transactions. E-commerce operators face a short runway and should begin preparing now.
For all other importers and exporters, customs declarations remain mandatory until 1 March 2031, are available as an alternative to the Data Hub until 1 March 2034, and cease entirely thereafter. Early adoption during the voluntary period (from 1 March 2031) offers an opportunity to pilot systems, resolve integration issues, and gain a competitive edge in streamlined processing.
Three reasons why this matters for your business
Reason 1: You will navigate a single digital environment, not 27 fragmented national systems. This offers benefits as there will be fewer regional differences, meaning lower compliance costs for businesses and more flexibility to move goods via entry points across the EU. You can expect a more predictable regulatory experience across the EU. You can prepare by reviewing your EU trade operations and optimising trade compliance resourcing, including a review of your customs broker relationships to ensure that your brokers are adapting to the new data environment, can facilitate your IT integration with the Data Hub, and can offer entry point flexibility.
Reason 2: You will see convergence of customs and non-customs regulatory data in one platform. The Data Hub will interface with other national and EU regulatory databases, enabling the processing of non-customs data. The Data Hub will serve as a central repository for supporting documentation, licences, authorisations, and the like. This data ecosystem will be accessible to not only customs authorities but also tax authorities, market surveillance authorities, and other enforcement agencies. For businesses, this means that product safety documentation, environmental compliance records, origin certificates, and transaction data will all need to be digitally accessible and structured within a single framework. Compliance gaps in non-customs areas, such as product safety or environmental reporting, will surface much more easily as a customs issue. You can prepare by breaking down internal silos between customs, sustainability, product safety, and finance teams, and treating the Data Hub as an all-encompassing compliance framework. Consider mapping which regulatory regimes apply to which product flows and consolidating the underlying data into a single source of truth rather than maintaining parallel compliance records for each regime, and ensure that the data is available in a timely manner for submission to the Data Hub.
Reason 3: You will experience a shift from declaration-based customs supervision to data-driven customs supervision. As a result, you can expect quicker detection of non-compliance and broader impacts if non-compliance is detected. At the same time, you can also expect a more coherent approach to data treatment across Member States. You can prepare by conducting internal audits of your customs data and how that data is treated by your customs brokers. This can include working towards creating a single source of truth for customs data within your organisation, shared across regions and business units. Critically, operators should also engage now with their customs representatives to assess their readiness for this transition: the declarant role will disappear, and customs representatives acting indirectly will assume joint and several liability not only for the customs debt but also for non-fiscal compliance, including product safety. Businesses should verify that their customs representatives have the data infrastructure, compliance expertise, and contractual willingness to take on these expanded responsibilities under the new regime.
About the Reed Smith International Trade team
Reed Smith’s International Trade team is known for its deep experience in customs law, advising clients across the globe on the full spectrum of customs and international trade matters – from regulatory compliance, customs classification, origin, and valuation, to anti-dumping proceedings, sanctions, and export controls. Our team represents clients in customs litigation before courts and regulatory authorities worldwide, and advises multinational businesses on complex cross-border trade projects in every major jurisdiction. If you have questions about how the reforms discussed in this briefing may affect your operations, please reach out to your usual Reed Smith contact or one of the team members below.
This briefing is based on publicly available EU and UK legislative proposals and official policy documents as at the date of publication. The legislative process has not yet been fully completed, and key operational details are still to be determined. Timelines, thresholds, and specific requirements discussed in this briefing may change as the legislative process advances. Readers should verify any information against the final legislative texts and official authority guidance before making compliance or business decisions.
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