EU import rules in 2027: the year the bills arrive

2026 was the year the new EU import rules went live; 2027 is the year they start costing and paying real money. Carbon certificates go on sale, the first carbon declarations fall due, the deforestation rule reaches the smallest companies — and behind it all, the fully reformed customs framework of 2028 comes into view.

For companies outside the EU, every one of these dates strengthens the same conclusion: the parties that own their import position — through their own EU entity — convert each deadline into a commercial advantage, while parties that ship and hope absorb each one as a cost.

CBAM: from registration to real money

The EU's carbon charge at the border — the Carbon Border Adjustment Mechanism (CBAM) — moves from administration to payment in 2027. Certificate sales open on 1 February 2027 on the common central platform; certificates covering 2026 imports are priced at the average 2026 EU ETS allowance value, and from 1 January 2027 the price switches to a weekly calculation. The first annual declaration, covering calendar year 2026, falls due by 30 September 2027. Two softeners from the Omnibus package help planning: the quarterly certificate-holding requirement stands at 50 percent of embedded emissions, and updated CBAM benchmarks apply to goods imported from 1 January 2027. The Commission is also consulting on extending CBAM to downstream products — a signal that the mechanism grows rather than shrinks. The route to holding this position yourself: an EU entity for CBAM.

EUDR: the deforestation rule reaches everyone

The EU's deforestation rule — the EU Deforestation Regulation (EUDR) — applies to large and medium companies from 30 December 2026, and reaches micro and small companies on 30 June 2027 (outside the timber sector, where the December date covers every size). A simplification package under negotiation would ease statements for small primary producers and narrow duties for downstream actors; until adopted, the current rules and dates stand. Coffee, cocoa, palm oil, rubber, soy, cattle and wood — the operator that files its own due diligence statements owns the compliance asset: becoming the EU operator under the EUDR.

E-commerce: the 2026 changes keep tightening

Customs duty has applied from the first euro on parcels since 1 July 2026, with the temporary €3 fee per declaration line bridging to the new framework. Product identification became mandatory on 1 November 2026. Through 2027 these rules simply keep running — and the bulk-import route through a Dutch entity keeps widening its advantage: e-commerce through the Netherlands.

The horizon: the 2028 customs framework

Behind the yearly dates stands the full EU customs reform: a European Customs Authority, a central data hub, and the importer's data responsibility concentrated on the party established in the Union. Every element rewards the same structure — an EU entity that holds the EORI number, the licences and the data relationship with customs. The Netherlands, with Rotterdam, Schiphol and the Article 23 import VAT deferment, is where that entity does its best work: the full EU market entry route.

Frequently asked questions

What happens with CBAM certificates in 2027?

Sales open on 1 February 2027 on the common central platform. Certificates for 2026 imports carry the average 2026 EU ETS price; from 1 January 2027 pricing switches to a weekly calculation. The first annual declaration, covering 2026, is due by 30 September 2027, and declarants hold certificates for at least 50 percent of embedded emissions through the year.

When does the EUDR apply to small companies?

Micro and small companies fall under the EU Deforestation Regulation from 30 June 2027, outside the timber sector where 30 December 2026 covers operators of every size. Large and medium companies comply from 30 December 2026.

Is the €3 parcel fee permanent?

It is the bridge between the removal of the €150 exemption on 1 July 2026 and the new customs framework planned for 2028, when the reformed system with a European Customs Authority and central data hub takes over.

Why does an EU entity keep gaining value through these changes?

Each rule concentrates responsibility on a party established in the Union — the authorised CBAM declarant, the EUDR operator, the importer of record. A company that holds those roles through its own Dutch BV turns every deadline into a position; a company that ships and hopes pays someone else to hold them.