On 9 December, several members of the Trade Contact Group (TCG) – an expert group chaired by DG TAXUD and involving international associations engaged in customs-related activities at the EU level – have published a Joint Statement on the Union Customs Code reform.
Ecommerce Europe, member of the TCG, has co-signed the Joint Statement together with 20 other parties, and is actively engaged in the EU discussions on modernising and digitalising the Customs Union to increase stability and safety in the EU e-commerce import system.
The Joint Statement calls on the EU institutions and policy-makers to look at certain improvements and suggests adjustments to some aspects of the Customs reform. The paper calls for advancing the implementation of the Union Customs Code’s Work Programme and prioritising the completion before any further expansion to the EU customs system. Several Member States have already officially announced that they will not meet the deadline of 31 December 2025, as already evidenced by the UCC Annual Report 2024 on the IT deployment of customs systems in the EU MS27.
Furthermore, the paper puts forward some recommendations regarding the Data Hub, in order to ensure that this new centralised system effectively improves customs efficiency, removes data duplication, and provides accessibility for all actors while safeguarding business interests, particularly those of SMEs. The security of data, especially business sensitive information, should be a key priority in the design. Regarding the deemed importer, the Joint Statement warns that the non-fiscal responsibilities result in a disproportionate transfer of non-financial risks from the perspective of indirect customs representation. The paper states that making parties responsible for the accuracy of data that they cannot themselves verify will not improve the accuracy and the quality of the data, and of compliance in general. Therefore, the Joint Statement calls for introducing a possibility for the importer to have the option to nominate various ‘representatives’ with regard to the fulfilment of their obligations. This will allow them to not only engage a customs representative for customs (fiscal) obligations but also other expert parties for non-fiscal obligations. Therefore, according to the Joint Statement, the conditions under which a customs representative and any other ‘authorized representative’ may provide services in the customs territory should be determined in the legislative text.
In addition to references made to the EU Customs Authority, customs infringements and sanctions, P&R and temporary storage, the Joint Statement calls for a collaborative approach between trade and policymakers to ensure that the customs reform will be both robust and supportive of economic growth.
Within the framework of an open and structured dialogue with the EU Institutions, the co-signatories wish to inform the ongoing negotiations on the UCC reform and contribute to promoting a streamlined, consistent and future-ready EU customs environment.