Final Approval on the EU Customs Reform: Responsibilities, Penalties, and the Compliance Process
In our previous articles dated 03.04.2026 and 09.07.2026, we addressed the legal framework of the comprehensive reform of the European Union's customs system, the fixed customs duty of €3 applied to consignments valued at less than €150 that entered into force on 1 July 2026, and the Electronic A.TR Movement Certificate integration launched by the Ministry of Trade of the Republic of Türkiye in line with these developments.
Regarding this process, the Council gave its final approval on 3 September 2026 to the most comprehensive reform of the European Union customs framework in decades. Following the vote scheduled to take place in the European Parliament later in September 2026, the regulation is expected to be published in the Official Journal of the EU.
The key elements under the reform receiving final approval from the Council are summarized below:
1. Responsibility of E-Commerce Platforms and Applicable Penalties
As noted in our previous articles, the principle of treating platforms as the importer has been maintained at this stage:
Scope of Responsibility: Non-EU platforms selling to EU consumers are considered the goods' direct "importers". Ensuring that customs formalities are handled, duties are paid, and products comply with EU standards falls under the responsibility of these platforms.
Penalties: For e-commerce operators failing to fulfill their customs obligations, fines of up to 6% of the company’s annual import value in the preceding year may be imposed. Furthermore, the removal of certain customs privileges and access restrictions to platforms may be applied.
2. Handling Fee for Small Parcels
A new cost element is envisaged to help cover rising inspection and monitoring costs:
A handling fee on small parcels entering the EU via e-commerce is planned to be introduced across the EU by 1 November 2026.
It is stated that this fee, the level of which will be set by the European Commission, will be separate from the duties applied and the removal of the customs duty exemption for imports valued at less than €150.
3. New Institutional Structure: EU Customs Authority (EUCA)
The reform aims to ensure centralized coordination of customs controls across member states:
The European Union Customs Authority (EUCA), to be established in Lille, France, is planned to commence operations in 2027.
The authority is expected to be responsible for establishing common risk criteria at the EU level, identifying priority control areas, and coordinating crisis management centrally.
4. EU Customs Data Hub and Implementation Timeline
The phased transition timeline for the EU Customs Data Hub, which aims to enable importers and exporters to complete procedures through a single centralized online platform instead of national customs systems, has been clarified:
1 July 2028: The use of the Data Hub will become mandatory for e-commerce businesses. Once the Data Hub becomes operational, the temporary fixed customs duty of €3 applied to small parcels under €150 will end, and goods will be subject to the normal tariff rates.
1 March 2034: The use of the Data Hub will become mandatory for all traders.
5. Enhanced Facilitations for Trusted Businesses (Trust and Check)
In addition to the existing Authorised Economic Operator (AEO) scheme, the creation of a "Trust and Check" status has been decided for companies demonstrating high transparency and regulatory compliance:
Businesses meeting stringent criteria will benefit from streamlined procedures, and goods of the most reliable companies will be permitted to enter into free circulation in the EU without active customs intervention.
Other companies will continue to benefit from existing Authorised Economic Operator (AEO) facilitations.
General Assessment and Implications for Türkiye
With the Council's final approval, the primary direction of the reform points to a transition from a structure in which national administrations operate separately to an integrated model based on shared data, centralized risk analysis, and platform responsibility. The potential implications of this process for Türkiye's foreign trade and logistics sectors may be evaluated as follows:
Significance of Electronic A.TR Integration: As outlined in our article dated 09.07.2026, the facility to issue Electronic A.TR Movement Certificates introduced by the Ministry of Trade within express cargo and postal transportation preserves its strategic value in protecting rights and commercial advantages under the Customs Union. However, the handling fee planned to enter into force by 1 November 2026, coupled with the penalties targeting e-commerce platforms, demonstrates the heightened requirement for compliance in product safety, origin, customs value, and data quality.
Platform Responsibility and Data Reliability: Full compliance with technical standards and the accuracy of customs declarations by exporters selling through platforms in the EU market are expected to be decisive for commercial continuity.
Interaction with the AEO and Mutual Recognition Process: The gains achieved through the mutual recognition processes between Türkiye and the EU in the field of Authorised Economic Operator (AEO / YYS) status in July are expected to become even more significant alongside the newly established “Trust and Check” model. Companies holding Authorised Economic Operator status and providing high levels of transparency and reliability in the supply chain, are considered to have a greater capacity to adapt to streamlined procedures and faster clearance at EU customs.
Digital Infrastructure Preparations: The transition process to the centralized data platform spanning 2028 and 2034 increases the importance of infrastructure preparations based on single-point data submission rather than multiple system declarations in foreign trade operations.
In conclusion, the EU Customs Reform shapes a new era centered on supervision, centralized data management, and platform responsibility in international trade. In line with the phased transition timeline, closely monitoring regulatory updates, prioritizing data quality, and effectively utilizing the digital facilitations provided by public authorities are considered beneficial for sustaining commercial competitiveness.
This article has been prepared on the basis of the European Council's press release dated 3 September 2026, the explainer note titled "Modernising the EU customs union", relevant official announcements, and sectoral evaluations.
Links:
EU customs: Council greenlights landmark reform - Consilium
Modernising the EU customs union - Consilium
EU Customs Reform: A New Era for Global Trade (Our article dated 03 April 2026)