What’s Announced and What We Believe

On 27 June 2025, the Council of the European Union adopted its negotiating mandate on the reform of the EU Customs Union, thereby opening trilogue negotiations with the European Parliament. This follows the EU Commission’s proposal of 17 May 2023 to recast the Union Customs Code and modernise customs governance and IT infrastructure within the EU. 

The reform is positioned as the most extensive upgrade since the creation of the Customs Union. The ambition announced is proportionate to the massive challenges facing the EU Customs Union today. This reform should have an impact on all stakeholders (public and private) involved in customs activities, and will be built around three ambitions: a new partnership with business, a smarter approach to customs checks, and a more modern approach to e-commerce. Each of these pillars would entail specific changes for all actors involved in cross-border operations.

In this article, we propose to focus on the impact for businesses, and in particular on three key elements that have been announced as fundamental shifts: the EU Customs Data Hub, the European Customs Authority, and the “Trust & Check” trader status. Let’s take a closer look.

The EU Customs Data Hub

What’s announced

The Data Hub is the flagship project. In short, it will centralise customs data at EU level, replacing more than one hundred national systems with a single interface. Traders will submit product and supply chain information once, reusing it for multiple consignments across EU Member States. The Commission projects €2.7 billion in annual compliance savings for businesses and €2 billion in IT cost savings for administrations.

The announced timeline is gradual. E-commerce flows are to be covered from 2028, other traders may join voluntarily from 2032, and full mandatory use is foreseen from 2038.

What we believe

For many businesses, a single interface would be a genuine simplification, reducing today’s need to interact with multiple national systems - which is a central problem that even the adaptations of the Union Customs Code have failed to resolve. 

But the announced benefits remain distant. At this stage, no specifications for this hub have been published, and criticism from some Member States suggests that it will be difficult to fully implement this ambition. As things stand, the mandatory data hub is not expected to be operational until 2038 - and delays are highly likely. This means that for the next decade, most companies will continue to operate in fragmented national environments.

And to take it a step further, the credibility of the Hub depends entirely on uniform implementation across Member States. Experience with the Union Customs Code and the e-Customs programme shows how fragile this is: repeated delays, inconsistent adoption, and uneven technical delivery. Until specifications and national commitments are clear, companies should treat the Hub as a long-term prospect. Concretely, and until more information is released, or their strategy over the next decade, companies must work to implement their own approach to centralizing customs activities and data, without relying on the data hub.

The European Customs Authority

What’s announced

The European Customs Authority (EUCA) is to be established in 2028 according to the EU Commission. At that stage, it has been announced that it would manage the Data Hub, conduct EU-wide risk analysis, issue control recommendations, and coordinate crisis responses. It is presented as the instrument for customs to “act as one.” In other words, the goal would be to ensure a harmonious implementation of EU customs legislation and practice.

What we believe

For businesses, this EU Customs Authority could improve the consistency of risk management across borders, reducing the “weakest link” problem where operators target less strict Member States. The lack of strong and unified enforcement of EU customs law across Europe is a structural issue that almost all stakeholders - both private and public - recognize and struggle with. Therefore, on paper, it is a reform many professionals had been waiting for. But the outcome is likely to disappoint.

The scope and mandate of the EUCA will remain limited. As far as we understand, this Authority would not have supranational powers: it cannot grant authorisations, issue binding decisions, or enforce penalties. In short, this would not be an entity with the powers to oversee and enforce actions against national administrations. Member States remain sovereign and may justify not applying its recommendations. And this authority is unlikely to address the structural crisis affecting all EU customs administrations: chronic staff shortages.

This means that while EUCA may support information sharing and coordination in crises, companies should not expect uniform enforcement or faster authorisations. In practice, it is a coordination body, not a regulator. The reform strengthens administrative cooperation but does not create a fully unified (strong) EU customs authority. At this stage and in the current state of affairs, its relevance will therefore likely be limited, to say the least.

Trust & Check

What’s announce

The reform introduces a new Trust & Check status, presented by the EU Commission as a higher tier of trusted operators. In theory, it would build on the Authorised Economic Operator (AEO) framework, with stronger supply chain transparency through the EU Customs Data Hub, and by providing further benefits to businesses. Certified companies would benefit from simplified reporting, fewer interventions, and the ability to centralise dealings with one customs administration across the Union. A review in 2035 will assess whether the scheme should be extended more widely once the Data Hub is mandatory in 2038.

What we believe

For companies, the promise is attractive: fewer interventions, simpler processes, and the possibility of dealing with one authority instead of many. But in substance, Trust & Check closely resembles AEO (even as the Commission claims the opposite). The criteria are almost identical, certification remains national, and the benefits are still loosely defined.

If the status is deemed to be extended to the maximum of traders (as announced), its value risks being diluted, just as happened with AEO. Without stricter eligibility criteria and stronger EU-level oversight, Trust & Check is unlikely to deliver the simplifications companies expect. For such a certificate to be credible, it must be reserved for a handful of operators - those who put the maximum effort into trade compliance. At this stage, this Trust & Check status  should be seen as a AEO rebranded program rather than a real structural transformation - albeit urgently needed..

Conclusion: Looking Ahead to the Trilogue

The Council’s mandate has cleared the way for trilogue negotiations, where the final balance of the reform will be decided. At this stage, expectations should remain modest.

The EU Customs Data Hub is by far the most promising element for businesses, but its implementation is distant and its value depends entirely on future technical specifications and uniform adoption by EU Member States. The European Customs Authority may improve coordination, but it will not overcome structural fragmentation in enforcement. And for us the Trust & Check status sets the bar far too low, and has failed to learn from AEO’s weaknesses. 

As trilogue discussions begin, the key for companies is to monitor developments closely, but not to adapt prematurely. This reform remains first and foremost a restructuring project for customs authorities in crisis. For companies (setting e-commerce aside), this reform does not, at this stage, appear as ambitious as announced.