Customs is shifting from a downstream declaration process to an upstream product-data process. Aggregation of six-digit HS codes for low-value consignments can significantly reduce costs, with AEB’s customers averaging 17% in duty cost savings.
Why waiting for EU Customs Reform is a mistake
Why customs is moving upstream
Complete product master data will be essential
The €3 customs duty already requires better item-level data
Product Identifiers will connect declarations to specific products
The Union handling fee creates another data dependency
The Digital Product Passport is the next product-data milestone
Customs, compliance, and commercial data are converging
To date, customs for e-commerce has generally been treated as a process performed closer to the destination point. The commercial transaction happens first. The goods are then packed and shipped. Only when the shipment approaches the border is customs data assembled and the customs declaration created.
That model will change with EU Customs Reform.
As the launch of the EU Customs Data Hub in 2028 approaches, customs is moving upstream. Instead of remaining a standalone process toward the end of the supply chain, customs is becoming an output of high-quality data generated at the front end.
The Data Hub is not scheduled to become operational for e-commerce imports until July 2028. However, waiting until then to prepare would be a mistake. Businesses that improve their data early can create opportunities and gain a competitive advantage.
In 2025, almost 5.9 billion low-value e-commerce items entered the EU. These consignments represented around 97.9% of all imported items.
The current customs model relies on the manual assessment of individual parcels at the point of entry. It cannot handle this volume effectively.
The EU Customs Data Hub will give customs authorities a broader view of:
To provide this view, the Data Hub will depend on more detailed data being available earlier in the process. By bringing together information from across the supply chain, it will help customs authorities assess the risk of each import at scale.
The European Commission’s procurement tender for the Data Hub closed in July 2026, but the development contract has not yet been awarded. This means the architecture will not be defined until mid-2027 at the earliest.
However, businesses do not need to wait for the final technical specifications before taking action. The underlying data requirements are already becoming clear.
At the center of the future customs model lies complete and reliable product master data. At item level, businesses need to know:
From November 1, 2026, generic product descriptions such as “shoes” or “electronics” will no longer be sufficient. Customs must be able to connect each declaration line to a specific product reference.
Product Identifiers, or PIDs, will create this connection between the customs declaration and the underlying product. As many as three identifiers may be required:
Businesses that cannot connect their product data to these identifiers need to take immediate action to prepare for November 2026.
Another change is expected around November 1, 2026: the introduction of an EU-wide handling fee for low-value imports.
The fee is intended to cover the cost of customs supervision, including:
For businesses, the main issue is not the fee itself. Companies will need systems that can identify the relevant goods, consignments, and liable parties. These systems must also transmit the information required to calculate and collect the fee.
The Digital Product Passport, or DPP, is another data-led change. It acts as a digital identity card that makes product information accessible throughout the supply chain.
Depending on the product category, the DPP can include information about:
The EU will introduce DPP requirements progressively by product category. Industrial, electric-vehicle, and light-transport batteries will require a DPP from February 18, 2027. Other product categories will follow from 2027 onward.
Product compliance data, commercial data, and customs data are increasingly converging. To meet upcoming requirements, businesses across the supply chain must ensure that accurate item-level data flows through the evolving ecosystem.
Treating each requirement as an isolated data project will create duplication and inconsistency. Instead, businesses need a single source of truth for product master data that can support:
Customs automation has long been a strategic focus for companies throughout the supply chain. But the central strategic question is no longer:
“How do we automate customs?”
It is:
“How do we ensure that the data generated at the beginning of the supply chain is good enough to automate the decisions made at the end?”
