Customs Compliance & Risk Management

Customs Compliance & Risk Management
Journal for practitioners in Europe
December/January
2025-2026
Issue 36
ISSN 2669-2171
December 2025 / January 2026
Ilona Mishchenko

Editor's message

Ilona Mishchenko

Member of the Editorial Board

Dear Reader,

The start of 2026 has confirmed what many customs professionals have long felt: we are no longer dealing with isolated regulatory changes, but with a constant state of adjustment. The jurisdictions under the Customs Compliance & Risk Management spotlight - the EU, the UK, the US and Ukraine - are seeing their customs and trade frameworks evolve under pressure from geopolitics, digitalisation, sustainability goals and wartime challenges. The news updates in this issue clearly reflect this reality. Tariff shifts, classification changes, the expansion of CBAM obligations, enforcement-driven procedural requirements, and other developments are no longer merely 'technical background noise', but rather factors that directly influence business decisions and compliance strategies.

At the same time, several articles in this issue emphasise that the real challenge lies in translating legislation into practice. Understanding how CBAM document codes are applied in practice, who ultimately bears CBAM liability, and how legal provisions should be interpreted often determines whether or not compliance is successful.

Country-specific articles, including discussions on centralised clearance and deferred payment authorisations in Germany and the application of Procedure 42 in France, demonstrate that organisational design and authorisation management are just as important as legal interpretation.

Beyond traditional rules and procedures, the articles also explore how the customs function itself is changing. The articles deal with professional development, future skills and the evolving role of customs teams. Among the ideas put forward is the provocative one of "making customs sexy" by increasing the attractiveness of the profession.

Looking ahead, contributors examine how artificial intelligence can simplify compliance with international sanctions regimes. In an environment of expanding trade restrictions and growing enforcement expectations, the ability to combine regulatory knowledge with smart technological tools will be key to effective compliance.

With this issue, the Customs Compliance & Risk Management team aims to support practitioners working at the intersection of law, operations, and strategy by helping them to manage current risks and prepare for future challenges.

Dr Ilona Mishchenko,
Member of the Editorial Board

Read more

Country update

VAT exemption for personal imports raised to $150 in Israel

VAT exemption for personal imports raised to $150 in Israel

Omer Wagner
Omer Wagner
30 Dec 2025

While the EU and other jurisdictions have tightened rules and reduced tax- and duty-free allowances for low-value imports, Israel has chosen to ease the burden on consumers and simplify cross-border e-commerce. However, this raises new issues regarding whether the imports are intended solely for private use and not as part of business processes. This article explains the novelty of Israeli law and its consequences for those to whom these newly adopted rules apply.

taxes and tariffs
Country update
Mastering UK legislation: a structured guide to law in action

Mastering UK legislation: a structured guide to law in action

Jeremy White
Jeremy White
20 Jan 2026

The UK’s legal system is often perceived as complex, particularly in the field of customs law, where the rules are spread across multiple layers of legislation and supporting instruments. This article provides a structured overview of how UK laws are made and applied, explaining the different types of legal acts and their respective legal force and practical application. It also outlines the legislative processes behind statutes and statutory instruments, shedding light on the legal complexities surrounding tertiary legislation and offering practical insights into how authority, delegation, and validity influence the implementation of UK customs law.

law
Country update
Application of Customs Procedure 42 in France and its recent developments

Application of Customs Procedure 42 in France and its recent developments

Evguenia Dereviankine
Evguenia Dereviankine
22 Jan 2026

This article examines Customs Procedure 42 as a tool for optimising import VAT where goods are imported into one EU Member State but released for consumption in another. It focuses on recent regulatory changes in France, highlighting how these amendments affect the application of the procedure, particularly for non-EU established companies, and assesses the practical and compliance implications of the new approach.

taxes and tariffs
Country update
Centralised clearance for import and deferred payment authorisations in Germany: practical challenges

Centralised clearance for import and deferred payment authorisations in Germany: practical challenges

Michael Lux
Michael Lux
04 Feb 2026

This article examines the practical and legal challenges arising from the use of Centralised Clearance for Import in Germany, with a particular focus on the interaction between EU customs law and national VAT rules. It analyses the implications of the German deferred payment regime, the newly introduced Section 21b of the German VAT Act, and the resulting administrative burdens for cross-border economic operators and customs representatives. The article highlights systemic deficits that could undermine the intended objectives of simplification and harmonisation within the EU under CCI.

taxes and tariffs
law
Country update
Spread the word about your business with CustomsClear!
Spread the word about your business with CustomsClear!

News update

EU customs and trade news: December 2025

EU customs and trade news: December 2025

28 Dec 2025

News in week 52: CBAM goes live on 1 January 2026 - a quick guide for importers; CBAM-related regulations setting rules as regards the calculation and publication of the price of CBAM certificates, rules as regards the methods for the calculation of emissions embedded in goods, rules for customs information and reporting under the CBAM, principles for verification of declared embedded emissions, amending provisions as regards CBAM registry and the status of authorised CBAM declarant, etc.;  regulation on simplification and streamlining of EUDR obligations; temporary derogation for ICS2 Release 3 for some countries; amendment of autonomous tariff quotas; Moldova and Montenegro accede to the Convention on a common transit procedure as from 1 November 2025; and further updates.

law
News update
UK customs and trade news: December 2025

UK customs and trade news: December 2025

31 Dec 2025

News in brief: tariff notices on the classification of  PETG, glow sticks, Salemi, telescopic loaders and steel bracket issued; new notices to exporters on legislative changes to export controls and sanctions published; UK Customs Tariff updates; data for UK ETS and CPS eligibility and compensation calculation form updated; General trade licence Russia sanctions – fertilisers updated; changes to eight open general export licences made; and other updates.

law
News update
EU customs and trade news: January 2026

EU customs and trade news: January 2026

04 Feb 2026

News in week 5: EU and India conclude landmark Free Trade Agreement; EU and Viet Nam upgrade ties to comprehensive strategic partnership; EU-Brazil agreements to create the biggest area of free and safe data flows in the world; EU–Morocco Euro-Mediterranean Agreement - updated rules of origin; amendment and extension of EU–Ukraine road freight agreement - Solidarity Lanes; definitive anti-dumping duty on candles, tapers and the like ; expiry of anti-dumping duty on aluminium products and wire rods; Russia, Tunisia, Sudan - amended lists of sanctioned persons; updates to third-country authorisations for food imports; WCO Technology Conference and Exhibition; and further updates.

law
News update
US customs tariff news: December 2025

US customs tariff news: December 2025

07 Jan 2026

News in brief: amendments to adjusting imports of timber, lumber, and their derivative products into the US; measures to implement certain tariff-related elements of the US-Switzerland-Liechtenstein, US-Korea and US-Israel trade arrangements; Section 301 tariffs on Nicaragua’s goods.

taxes and tariffs
News update
UK customs and trade news: January 2026

UK customs and trade news: January 2026

01 Feb 2026

News in brief: tariff notice on the classification of swim spas issued; UK Customs Tariff updates; new versions of several reference documents published; progress in the UK-Japan, UK-Indonesia and UK-India trade relations; registration of imports of boom lifts introduced; anti-dumping duty on ammonium nitrate, on welded tubes and pipes as well as on wire rod products imposed; countervailing duty on rainbow trout introduced; both anti-dumping and countervailing duties on imports of biodiesel products imposed; and other updates.

law
News update
US customs tariff news: January 2026

US customs tariff news: January 2026

04 Feb 2026

News in brief: Section 232 import duties on certain advanced computing chips; measures to adjust imports of processed critical minerals and their derivative products into the US; new tariff system to impose duties on goods from countries that sell or otherwise provide oil to Cuba.

taxes and tariffs
law
News update
Ukraine customs and trade news: December 2025/ January 2026

Ukraine customs and trade news: December 2025/ January 2026

04 Feb 2026

News in brief: duty and tax exemptions for the import of energy and defence goods extended; restrictions on the export of strategic raw materials for 2026 extended; allocation of sugar export quotas to the EU for 2026 done; monitoring of soybean and rapeseed exports introduced; the list of goods that may be subject to anti-dumping measures revised; transition period for the revised rules of origin under the PEM Convention ended; and other updates.

law
News update

Topic spotlight

2026 CN amendments: a practical overview

2026 CN amendments: a practical overview

Christopher Matt
Christopher Matt
14 Dec 2025

The publication of the Combined Nomenclature (CN) 2026 in the Official Journal of the European Union on 31 October marks the start of a transition period for EU importers and exporters, who now have until the end of the year to prepare their tariff classifications for 2026. The changes are not extensive, with only 13 codes being invalidated and 27 new codes being introduced. However, the adjustments reflect significant regulatory, industrial and technological developments occurring in several sectors.

classification
Topic spotlight
Key updates to the 2025 Commission’s Compendium of customs valuation

Key updates to the 2025 Commission’s Compendium of customs valuation

Ilona Mishchenko
Ilona Mishchenko
18 Dec 2025

Can EU green initiatives influence the determination of the customs value of goods imported into the EU? This article reviews the latest developments from the European Commission included in the updated version of the Compendium of Customs Valuation, and provides the answer to this question.

valuation
Topic spotlight
CBAM document codes (and castor wheels…)

CBAM document codes (and castor wheels…)

Bert Van Leeuwen
Bert Van Leeuwen
18 Dec 2025

An update to the European Commission’s CBAM guidance has clarified which document codes must be used in customs declarations from 1 January 2026, but not without raising new practical questions. This article examines the revised Y-codes, their interaction with TARIC data, origin and procedure rules, and why seemingly simple cases, from de minimis thresholds to returned goods and borderline products like castor wheels, can still create compliance risks for importers.

sustainability
Topic spotlight
CBAM liability of importers and ‘other persons’

CBAM liability of importers and ‘other persons’

Michael Lux
Michael Lux
21 Dec 2025

The CBAM Regulation distinguishes as of 1 January 2026 between importers or their customs representatives who are ‘authorised CBAM declarants’ declaring CBAM goods for release for free circulation, and 'other persons introducing [CBAM] goods into the customs territory of the Union without complying with the obligations under this Regulation'. As the latter will be subjected to enhanced CBAM penalties, this article attempts to describe who these ‘other persons’ are and whether they can escape such penalties under certain conditions.

law
sustainability
Topic spotlight
Rethinking professionalism and customs functions

Rethinking professionalism and customs functions

22 Jan 2026

This article examines what is required for customs functions to remain effective in the modern trade environment. It draws on key insights from the 31st Authors’ Meeting and the perspectives of business and customs practitioners, alongside academics. It analyses how the roles of customs specialists, representatives and compliance officers are evolving in response to EU Customs Reform, sustainability regulations, geopolitical uncertainty and technological change.

compliance
customs understanding
Topic spotlight

Perspective

The future of customs in Europe: insights from CLECAT

The future of customs in Europe: insights from CLECAT

Eva Cartwright
Eva Cartwright
15 Jan 2026

The interview marks the start of the Reflections Series, which follows on from the Customs Ecosystem Conference that took place on 6–7 October 2025. The series aims to share key insights and perspectives from leading figures in the customs ecosystem. Our first guest is Ms Eva Cartwright, CLECAT's Senior Manager for Customs and Digitalisation.

other
Perspective
To make customs sexy

To make customs sexy

Achim Rogmann
Achim Rogmann
20 Jan 2026

This article takes a broad view of the customs ecosystem, considering not only trade and administration, but also academia, non-customs authorities and legislators. It links the evolving mission of EU customs with education, innovation, and European integration, examining how diverse actors interact within a complex system. The article is written in a deliberately non-typical and reflective manner. This invites readers to look at customs from a different angle.

customs understanding
Perspective

Explainer

How can AI simplify compliance with international sanctions regimes?

How can AI simplify compliance with international sanctions regimes?

Aušra Šablinskienė
Aušra Šablinskienė
29 Jan 2026

In this article, we focus on the constantly evolving and highly complex legal landscape of EU sanctions imposed on third countries. We explore whether artificial intelligence (AI) can enable more efficient compliance, in particular by accelerating the assessment of whether a product transported along a specific route is subject to sanctions. Practical examples are drawn from the CustomsClear Sanctions AI Assistant.

Tech
Explainer