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Customs Watch — Week of 14 to 20 September 2026

Published on 22 September 2026

Customs watch — Week of 14 to 20 September 2026

A selection of customs regulatory developments (EU, Belgium, France, Netherlands, Luxembourg) over the past 7 days. A Customs Conform IT publication.

European Union

The new Union Customs Code has entered into force— 19-20/09/2026

Regulation (EU) 2026/2108 of the European Parliament and of the Council of 16 September 2026 establishes the new Union Customs Code and creates the European Union Customs Authority. It was published in the Official Journal of 19 September 2026 (OJ L, 2026/2108) and entered into force on 20 September 2026. It repeals Regulation (EU) No 952/2013. Some provisions apply from entry into force; general application of the new code is set for 21 September 2027. The text designates e-commerce platforms and sellers as importers responsible for customs formalities and the payment of duties, and creates the Trust and Check trader status. The implementation timeline provides for the Customs Authority to start operating on 1 January 2028, mandatory use of the customs Data Hub for e-commerce on 1 July 2028, voluntary use by other importers from 2031, full operational capacity on 31 December 2032 and mandatory use for all movements of goods on 1 March 2034. The handling fee applicable to e-commerce consignments must be collected by 1 November 2026 at the latest. Read more

Also of note: update of the EU dual-use items control list (14/09); technical extension of the Ukraine-related asset-freeze regime (15/09).

AEO & Trust and Check

AEO status is retained and forms the basis of the Trust and Check trader— 19-20/09/2026

Regulation (EU) 2026/2108 retains the Authorised Economic Operator (AEO) status and creates, in addition, the Trust and Check trader status. Recital 18 of the regulation states that the criteria and conditions for the Trust and Check status build on the AEO criteria, adding a transparency requirement: the operator grants customs authorities access to its electronic systems recording its compliance and the movement of its goods, such access remaining proportionate and strictly necessary. In return, the Trust and Check trader may obtain release of goods on behalf of the customs authorities without their active intervention, as well as deferral of payment of the customs debt. The status is refused to persons who have committed serious or repeated infringements of the legislation applied by the customs authorities. Recital 17 introduces an obligation for customs authorities to monitor compliance with the criteria at least every three years. The Council confirmed on 26 March 2026 that companies not eligible for Trust and Check would continue to benefit from the existing simplifications attached to AEO status. The removal of AEO, which featured in the Commission’s original 2023 proposal, was not retained. Read more

Migration arrangements toward Trust and Check have not yet been published— 22/09/2026

The transitional provisions applicable to existing AEO authorisations — reassessment, transition period, validity of current authorisations — do not appear in the material published to date. The date from which the Trust and Check trader status can actually be applied for is not specified: the general framework of the new code applies from 21 September 2027, and the benefit of a single customs interlocutor across the Union is announced for 2032. The Commission’s AEO documentary pages are unchanged: the AEO Guidelines remain under reference TAXUD/B2/047/2011 – Rev.6 with their four annexes (self-assessment questionnaire, threats and risks with the AEO COMPACT model, security declaration, examples of information to be shared), and guidance document TAXUD/A3/002/2026 of 31 March 2026 has not been revised. As at 22 September 2026, the Commission’s "Authorised Economic Operator", "Union Customs Code" and "EU Customs Reform" pages mention neither Regulation (EU) 2026/2108 nor the Trust and Check status, and still refer to Regulation (EU) No 952/2013. Read more

Belgium

Steel: proof of the country of melting and pouring required on import— 17/09/2026

Implementing Regulation (EU) 2026/1963, published on 31 August 2026 and applicable from 1 October 2026, sets out how the country of melting and first pouring must be evidenced for steel imports. The Mill Test Certificate, stating the country and the heat number, is the primary evidence document; other documents (invoices, delivery notes, quality certificates) may supplement it where it is incomplete. TARIC codes Y376 to Y387 identify the country and certificate codes C131 to C139 the type of document. A transitional period, during which broader documentation is accepted, runs until 30 September 2027; a stricter regime applies from 1 October 2027. Any import for which the evidence is not properly established is refused. Read more

France

New instruction on monitoring the exit of goods (AES)— 14/09/2026

French Customs Official Bulletin no. 7692 publishes administrative decision 26-079 on monitoring the exit of goods under the Automated Export System (AES/ECS). It repeals and replaces decision 26-001 and has applied since 14 September 2026. A full technical instruction, setting out the updated exit monitoring procedures, is attached to the bulletin. The text concerns all operators exporting from France. Read more

Netherlands

DECO: digital dossier for e-commerce declarations— 19/09/2026

Since 19 September 2026, businesses can upload their documents directly into the DECO platform, used for e-commerce declarations, instead of sending them by e-mail. Read more

Also of note: publication of a new stop-word list for the ICS2 system (18/09); reminder of CERTEX information sessions, ahead of the mandatory document checks of 31 October 2026 (17/09); update of the Dutch Customs dossier on the new Union Customs Code (16/09).

Luxembourg

No significant developments this week.

Key takeaways this week

  • The new Union Customs Code, Regulation (EU) 2026/2108, has been in force since 20 September 2026 and repeals Regulation (EU) No 952/2013. Its general application is set for 21 September 2027.
  • Authorised Economic Operator status is retained. Trust and Check trader is an additional status, built on the AEO criteria and coupled with customs access to the operator’s electronic systems.
  • The transitional provisions applicable to existing AEO authorisations and the date on which Trust and Check applications open have not yet been published.
  • Steel imports require, from 1 October 2026, proof of the country of melting and first pouring, evidenced by the mill test certificate.
  • France replaced its instruction on monitoring the exit of goods under the Automated Export System on 14 September 2026.
  • The Netherlands opened the DECO digital dossier on 19 September 2026 and will make CERTEX document checks mandatory on 31 October 2026.

Key dates ahead

  • 1 October 2026: Proof of the country of melting and pouring required for steel imports.
  • 31 October 2026: Netherlands: mandatory document checks via CERTEX, including CBAM.
  • 1 November 2026: Collection of the handling fee on e-commerce consignments.
  • 21 September 2027: General application of the new Union Customs Code.
  • 30 September 2027: End of the transitional period on proof of the country of melting and pouring.
  • 1 January 2028: The European Union Customs Authority starts operating.
  • 1 July 2028: Customs Data Hub mandatory for e-commerce.
  • 2031 to 2034: Data Hub: voluntary use from 2031, full capacity on 31 December 2032, general obligation on 1 March 2034.
Customs Conform IT — Weekly customs watch. Sources: Council of the EU, DG TAXUD, European Commission, EUR-Lex, Belgian FPS Finance and NAFORNA, French Customs (DGDDI), Dutch Customs, Luxembourg Customs (ADA). Information provided for indicative purposes; please refer to the official texts.
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