EU customs 2026 to 2034

EU Customs Data Hub 2028: who becomes the importer, and what your Dutch BV prepares now

The new Union Customs Code, Regulation (EU) 2026/2108, was published on 19 September 2026. From 1 July 2028 the seller or the platform is the importer of every parcel sold to EU consumers, with the data in one EU Customs Data Hub and fines of up to 6% of a year’s imports. The dates, the roles and the preparation for a Dutch BV.

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By Robert Jeffrey, Holdwise B.V., Hoofddorp. Published and checked against the official sources on 20 October 2026.

Summary

The EU replaced its customs code. Regulation (EU) 2026/2108 of 16 September 2026 creates one EU Customs Data Hub, an EU Customs Authority in Lille and a new role: the importer for distance sales. From 1 July 2028 the seller or the platform that sells to EU consumers from outside the EU is the importer. It gives customs the data, pays or guarantees the duty and the handling fee, and answers for product compliance. It must be established in the EU or be represented by an EU company with Authorised Economic Operator (AEO) status.

For a Dutch BV this is good news in three ways. As importer of its own stock it already does what the new code asks. As a seller on platforms it decides, together with the platform, who the importer is. As a logistics provider or customs broker it can represent sellers from outside the EU and apply for the new Trust and Check status.

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What the new Union Customs Code changes

Regulation (EU) 2026/2108 replaces Regulation (EU) 952/2013, the customs code of 2013. The Council gave its final approval on 3 September 2026; the regulation is dated 16 September 2026 and was published in the Official Journal on 19 September 2026. Most of its provisions apply twelve months after entry into force, so from the autumn of 2027. The provisions on distance sales and on the EU Customs Authority apply from 1 July 2028.

Four things are new for a company that imports into the EU:

One data platform. The EU Customs Data Hub is the single place where importers and exporters give their data to customs. It replaces more than 111 national systems and is managed by the new EU Customs Authority.
One authority. The EU Customs Authority in Lille analyses the data, sets priority control areas and risk criteria and coordinates crisis management. It starts its activities in 2027.
One importer for every parcel. For distance sales to EU consumers, the seller or the platform is the importer. The consumer stays out of customs.
A new status for reliable companies. Trust and Check traders give customs real-time access to their systems and may release goods themselves, with fewer checks. The existing AEO status stays.

The code also gives the legal basis for the Union handling fee of €2 per item on parcels sold directly to EU consumers, and for fines of 1% to 6% of a year’s imports for companies that systematically break the rules.

The dates, from 2026 to 2034

Date	What changes	Status
1 July 2026	The duty relief for parcels worth €150 or less ended. Until 1 July 2028 a flat duty of €3 per item type applies to parcels sold to EU consumers.	In force (Council Regulation (EU) 2026/382)
19 September 2026	Regulation (EU) 2026/2108, the new Union Customs Code, published in the Official Journal.	Law
1 November 2026	Product codes mandatory in the declaration for parcels up to €150. Union handling fee of €2 per item type; member states apply it at the latest on this date, Dutch Customs expects it from 1 November 2026.	Law (Delegated Regulation C(2026) 6694 of 21 September 2026)
2027	The EU Customs Authority starts its activities in Lille.	Law
Autumn 2027	Most provisions of the new code apply, twelve months after entry into force. The code of 2013 is repealed.	Law (recital 120)
1 December 2027	The European Commission reports whether the central EU system for duty on distance sales is ready for 1 July 2028. It may propose to extend the €3 duty.	Law (Regulation (EU) 2026/382, Article 3(2))
1 July 2028	The seller or the platform becomes the importer for distance sales. The Data Hub is mandatory for e-commerce. The €3 duty ends; the normal duty rate per product code applies.	Law
1 March 2031	Every business may use the Data Hub on a voluntary basis.	Law (recital 119)
1 March 2034	The Data Hub is mandatory for all businesses and all movements of goods.	Law

The importer for distance sales: the seller or the platform

Article 5(14) of the new code defines the importer for distance sales as the person who supplies the goods in a distance sale or the person who facilitates the sale, which is the platform. The recitals add that only one person is the importer at any time and that the arrangements between seller and platform decide who it is. That importer gives customs all the data on the goods, pays or guarantees the duty, the import VAT and the handling fee, and makes sure the goods comply with EU rules, from product safety to packaging. It must be established in the EU or be represented by an EU company with AEO or Trust and Check status; an indirect representative with AEO status takes over its obligations.

The European Parliament added the establishment rule to stop the use of shell companies. The sanctions match. A company that systematically breaks its customs obligations risks a fine of at least 1% and up to 6% of the value of the goods it imported in the previous twelve months, the loss of its AEO or Trust and Check status, a high-risk flag and restrictions on its access to online platforms.

Stock in the EU is rewarded. Goods imported in collective packaging and in large enough quantities into an EU warehouse get a lower handling fee when they leave that warehouse for an EU consumer. The Commission guidance of 5 October 2026 confirms a lower fee for goods from a customs warehouse for distance sales from 1 July 2028; the amount is still open.

The EU Customs Data Hub: one place for your data

Today an importer deals with the national systems of each member state where its goods enter; in the Netherlands those are DMS for declarations and DECO for e-commerce parcels. The Data Hub turns that into one EU platform: a company gives its data once, the customs authorities and the EU Customs Authority use it for risk analysis, and the duty of a Trust and Check trader goes to the member state where the trader is established.

The rollout has three dates. From 1 July 2028 the Hub is mandatory for e-commerce, so for every importer for distance sales. From 1 March 2031 any business may use it. By 1 March 2034 all businesses and all movements of goods go through it. In 2025 the EU handled around 6 billion e-commerce parcels, over 90% of them from China, which is why e-commerce goes first.

For your systems this means: product codes (your own article number, the manufacturer’s code and the barcode) in every declaration from 1 November 2026, a data link between your shop system, your carrier and your customs software, and one EU customs number (EORI) that the Hub recognises.

Three roles, one Dutch BV

Your role	What the new code changes for you	What to prepare now
Importer of your own stock (bulk shipments into a Dutch warehouse)	Little until 2031. Your BV is already the importer. Its declarations go through the Data Hub from 1 March 2031 at the earliest and from 1 March 2034 at the latest.	Check your EORI number, your Article 23 licence for import VAT and your product codes. Consider AEO status now and Trust and Check status later.
Seller on platforms or through your own shop, shipping parcels from outside the EU	From 1 July 2028 you or the platform is the importer of every parcel, established in the EU or represented by an EU company with AEO status. Until then: €3 duty per item type, €2 handling fee and product codes.	Agree with each platform who the importer is. Compare the cost per parcel with stock in an EU warehouse. Your own Dutch BV can be the importer itself.
Logistics provider, fulfilment centre or customs broker	Demand for EU representatives with AEO status grows. Trust and Check status brings fewer checks and release of goods in your own system.	Apply for AEO status now; the procedure takes months. Prepare your software for the Data Hub and for the fee per declaration line. Offer EU warehousing, which qualifies for the lower fee.

A Dutch BV is established in the EU. It can be the importer of your bulk shipments today and your importer for distance sales from 1 July 2028. It holds the EU customs number (EORI), the Dutch VAT number and the Article 23 licence that shifts import VAT from the border to the VAT return. The same company is the responsible economic operator for product safety and the producer for the packaging rules: one company, one set of data, one counterpart for customs. Read how it works in importer of record in the EU and stock in the Netherlands, and what the company costs in company formation in the Netherlands: from €2,950 excl. VAT.

What to do before 1 July 2028, in order

Map every route into the EU. Which goods enter as bulk shipments, which as parcels to consumers, and from which country? The parcels are the ones the new code changes.
Decide who the importer is per sales channel. For your own shop that is you; for a marketplace, agree it with the platform in writing. Check that the importer is established in the EU.
Get the product codes in order now. From 1 November 2026 the declaration needs your article number, the manufacturer’s code and the barcode. A missing code stops the parcel.
Calculate the cost per parcel from 1 November 2026: €3 per item type, €2 handling fee, import VAT and your carrier’s fee. Compare it with one bulk shipment to a Dutch warehouse; see the EU parcel rules 2026.
Apply for AEO status if you represent others, or ask your customs broker for its status. From 1 July 2028 only an EU company with that status may represent a seller from outside the EU.
Plan the Data Hub connection with your customs software supplier. E-commerce declarations go through the Hub from 1 July 2028; the Dutch Customs handbook for the new code is the reference.
Keep the EU rules beyond customs in view: product safety, packaging and the single VAT registration from 1 July 2028. See the EU import rules 2027 and selling in the EU: three options compared.

Prefer a written answer on your own situation, with the roles, the costs and the dates for your goods? That is written advice; the price is in the proposal.

Questions founders ask

Who is the deemed importer under the new EU customs code? +

The importer for distance sales: the seller that supplies goods to EU consumers from outside the EU, or the platform that facilitates the sale. The arrangements between them decide who takes the role, and there is only one importer per sale. That importer gives customs the data, pays or guarantees the charges and answers for product compliance. The rule applies from 1 July 2028 (Regulation (EU) 2026/2108, Article 5(14)).

Does the importer for distance sales have to be established in the EU? +

Yes, or it must be represented by an EU company with Authorised Economic Operator (AEO) or Trust and Check status, which then takes over the obligations. A seller from outside the EU therefore chooses between its own EU company and a representative with that status. A Dutch BV is established in the EU and can take the role itself.

When does the EU Customs Data Hub start? +

In three steps. From 1 July 2028 it is mandatory for e-commerce, so for all distance sales to EU consumers. From 1 March 2031 every business may use it on a voluntary basis. From 1 March 2034 it is mandatory for all businesses and all movements of goods. The EU Customs Authority in Lille manages it and starts its activities in 2027.

What are the fines for a seller or platform that ignores the rules? +

For systematic breaches: a fine of at least 1% and up to 6% of the value of the goods imported into the EU in the previous twelve months, the suspension or loss of AEO or Trust and Check status, a high-risk flag for its goods and restrictions on its access to online platforms.

What happens to the €3 duty and the €2 handling fee in 2028? +

The €3 duty per item type ends on 1 July 2028; from then on the normal duty rate per product code applies to every parcel. The €2 handling fee stays, paid by the importer for distance sales, with a lower fee planned for goods that leave an EU customs warehouse; that amount is still open. By 1 December 2027 the European Commission reports whether the EU systems are ready, and it may propose to extend the €3 duty.

Sources

Regulation (EU) 2026/2108 of 16 September 2026, the new Union Customs Code: eur-lex.europa.eu
Council of the EU, final approval of 3 September 2026: consilium.europa.eu; provisional agreement of 26 March 2026: consilium.europa.eu; EU action on small parcels: consilium.europa.eu
European Parliament, deal on the Union Customs Code reform, 23 March 2026: europarl.europa.eu
Council Regulation (EU) 2026/382 (the €3 duty, the check by 1 December 2027): eur-lex.europa.eu; European Commission, guidance on the €3 duty and the handling fee: taxation-customs.ec.europa.eu; Delegated Regulation C(2026) 6694 of 21 September 2026: ec.europa.eu
Dutch Customs, the handling fee for e-commerce (in Dutch): douane.nl; handbook on the new Union Customs Code (in Dutch): douane.nl

Who is the importer of your parcels from 1 July 2028?

Tell us how your goods reach EU consumers today: bulk, parcels or both, and through which platforms. You get a written answer on your situation: who the importer must be, what a parcel costs from 1 November 2026 and whether a Dutch BV as importer pays off.

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