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Square Insights EU Customs Code (UCC) Reform:
What Should Korean Shippers Prepare, and When?

Registration dateNOV 11, 2026

By Cello Square (Samsung SDS Logistics)Last updated: November 2026

From Mandatory PID Reporting in 2026 to the Data Hub in 2034 — The Timeline and Practical Implications of the Biggest Reform Since 1968

Executive summary

The new EU Union Customs Code is established by Regulation (EU) 2026/2108, which sets out the new customs code and establishes the EU Customs Authority (EUCA). It was adopted on September 16, 2026, published in the Official Journal on September 19, and entered into force on September 20. The Regulation generally applies from September 21, 2027, while certain provisions, including those relating to the Data Hub and distance sales, follow separate implementation timelines. It replaces the existing UCC (Regulation (EU) No 952/2013) and introduces three key changes: ① integrating customs IT systems currently fragmented across Member States into a single EU Customs Data Hub; ② from July 2028, making the seller or the platform facilitating the sale the importer for distance sales, depending on the transaction structure; and ③ establishing the EU Customs Authority (EUCA) in Lille, France.

  • Changes already underway: The customs duty exemption for low-value goods sold through distance sales valued at €150 or less was abolished on July 1, 2026, and a temporary duty of €3 per item on the customs declaration is now in effect. However, goods meeting the requirements for preferential tariff treatment under agreements such as the Korea–EU FTA may qualify for preferential tariffs if declared using H1 without using IOSS.
  • November 1, 2026: Reporting a product identifier (PID) became mandatory for distance sales imports valued at €150 or less. Separately, an EU handling fee of €2 per declared item applies to distance sales imports, regardless of the value of the goods.
  • Next milestones: The distance sales provisions and mandatory use of the Data Hub for e-commerce apply from July 1, 2028. Voluntary use of the Data Hub by other traders begins on March 1, 2031, followed by mandatory use for all traders on March 1, 2034.
  • What this means for Korean shippers: Sellers selling directly to EU consumers need to determine whether they qualify as importers for distance sales and what indirect representation arrangements are required if they are not established in the EU. B2B exporters may face requests from local importers and representatives for more accurate HS code, origin, and customs value data.

EU Customs Reform Timeline at a Glance

Date Change Scope / Affected Parties Status
July 1, 2026 Abolition of the customs duty exemption for goods valued at €150 or less; temporary duty of €3 per declared item; start of voluntary PID reporting Low-value goods sold through distance sales from outside the EU to the EU In effect
September 3, 2026 Final approval by the Council of the EU — Completed
September 16, 2026 Final adoption by the European Parliament — Completed
September 19, 2026 Publication in the Official Journal (Regulation (EU) 2026/2108) — Completed
September 20, 2026 Entry into force (the day after publication in the Official Journal, Article 287(1) — the Commission’s September 21 announcement outlined the entry into force and phased implementation) — Completed
November 1, 2026 Mandatory PID reporting; introduction of the €2 EU handling fee per item PID: Distance sales imports valued at €150 or less / Handling fee: Distance sales imports regardless of value In effect
2027 Establishment of the EU Customs Authority (EUCA) and commencement of certain activities — Scheduled
September 21, 2027 General application date of the Regulation (certain provisions follow separate timelines) All Scheduled
July 1, 2028 Application of distance sales provisions; mandatory use of the Data Hub for e-commerce; scheduled expiry of the €3 temporary duty (an extension may be proposed depending on IT readiness) E-commerce and platforms Scheduled
March 1, 2031 Voluntary use of the Data Hub by other traders All Scheduled
March 1, 2034 Mandatory use of the Data Hub by all traders All Scheduled

※ The phased application dates will be further specified through delegated and implementing acts and may be subject to change. Please consult the European Commission and the original text on EUR-Lex before the relevant provisions apply.

1. Why Is the EU Customs Code Reform the “Biggest Since 1968”?

The European Commission described this reform as “the most comprehensive reform since the establishment of the customs union in 1968.” It goes beyond simply amending legal provisions, simultaneously changing the systems used to process customs clearance, the parties responsible, and the supervisory authority.

The surge in e-commerce parcels is a key driver. According to the European Commission, 5.9 billion low-value e-commerce items were imported into the EU in 2025—four times the 2022 figure—and more than 90% originated from China. Meanwhile, EU importers had to deal with customs administrations across 27 Member States and more than 111 separate IT interfaces and systems, while sellers based outside the EU were difficult to hold accountable.

The reform addresses these issues through the following four pillars.

Pillar Details Implications for Korean Shippers
EU Customs Data Hub Replaces more than 111 separate IT interfaces and systems across Member States with a single platform Customs data is integrated and managed at the EU level
Importer for distance sales The seller or the platform facilitating the sale becomes the importer, depending on the transaction structure D2C sellers need to determine whether they themselves become the importer
EU Customs Authority (EUCA) Based in Lille; operates the Data Hub and coordinates risk management at the EU level Stronger cooperation on risk management among Member States
Trust and Check Provides additional simplifications for operators offering maximum supply chain transparency Certain simplification benefits may vary depending on the status of the EU import partner

2. What Changed on November 1 — Mandatory PID Reporting and the €2 Handling Fee

Mandatory PID reporting and the EU handling fee took effect on November 1, 2026. Korean e-commerce sellers need to review their declaration data, selling prices, and shipping charges to account for these two changes.

Item Details Scope Source
Mandatory product identifier (PID) reporting Voluntary reporting from July 1; mandatory from November 1 Declarations for low-value B2C distance sales goods valued at €150 or less European Commission guidance on low-value imports
€2 EU handling fee A flat fee per item to cover the costs of processing the release of distance sales goods for free circulation Distance sales imports regardless of the value of the goods European Commission reform guidance; EUR-Lex

A PID (Product Identifier) is identifying information used to specify which product the declared goods correspond to. According to the Commission’s guidance, the product identifier assigned by the seller, marketplace, or platform (M-PID) and the non-standard product identifier assigned by the manufacturer, producer, or product supplier (NS-PID) are required in all cases. Standard identifiers (S-PID), such as EAN or ISBN, must be declared where available; otherwise, an exception code is used. Ordinary B2B transactions are generally outside the scope of this requirement.

💡 Practical Points

  • Check whether product codes from your own online store and marketplaces, manufacturer part numbers, and barcode (EAN) information can be linked to customs data. Although declarations are usually submitted by express carriers or customs agents, sellers must provide the source data.
  • The handling fee is charged per item, not per parcel. Under the Regulation, an item means a group of goods within a single consignment that share the same tariff classification and goods description and, where origin is required in the declaration, the same origin. A parcel containing several different items may therefore incur multiple fees.
  • In principle, the handling fee is payable by the import declarant until June 2028. From July 2028, it is payable by the importer for distance sales who is the customs debtor. The amount is set at €2 by a delegated act, and the Commission prepares a report assessing the cost of the service every two years. The actual billing arrangements should be checked in your shipping and customs clearance contracts.

3. What Is the EU Customs Data Hub, and How Will Shippers’ Data Requirements Change?

The EU Customs Data Hub is a single EU customs data platform that replaces customs declaration systems fragmented across Member States. Operated by the EU Customs Authority, it allows businesses to submit data through a single window instead of filing separately in each Member State.

Implementation is phased. Use of the Data Hub becomes mandatory for e-commerce first, on July 1, 2028, requiring importers for distance sales and IOSS users to use it when releasing goods for free circulation. Other traders may use it voluntarily from March 1, 2031, and its use becomes mandatory for all traders on March 1, 2034. (EUR-Lex)

For shippers, the key change is the shift from “customs declaration forms” to “data.” As customs data is integrated and managed at the EU level and used for risk management, providing accurate goods descriptions, HS codes, origin, and customs values on commercial invoices becomes increasingly important.

💡 Practical Points

  • Use specific goods descriptions that clearly identify the products from the commercial invoice stage. As customs data becomes more integrated, the accuracy of data such as goods descriptions and HS codes becomes increasingly important.
  • Updating your product master data now—including HS codes of at least six digits for each item, origin, the basis for determining unit prices, and PIDs—will reduce the burden of adapting to the transitions in 2028 and 2034.

4. Who Is the “Importer for Distance Sales,” and What Responsibilities Will Korean Sellers Have?

The importer for distance sales is the seller supplying the goods or the platform facilitating the sale that assumes the role of importer for goods sold remotely to EU consumers, depending on the transaction structure. The relevant provisions apply from July 1, 2028. The recitals to the Regulation cite these parties’ control over the supply chain and their assumption of risk until delivery to the consumer as the rationale.

According to the European Parliament’s announcement, importers for distance sales have the following obligations:

  • Providing the data required for customs clearance
  • Paying or providing a guarantee for customs duties and other taxes and charges
  • Verifying that the goods comply with EU legislation

Where the seller or platform is not established in the EU, the Regulation allows an EU-established indirect representative holding AEO status for customs simplifications (AEOC) or Trust and Check status to place the goods under a customs procedure in its own name, on behalf of the importer for distance sales, and assume the obligations of that importer. The specific procedures and terms of the representation agreement should be checked against the original legal text and with a local customs broker.

Transaction Type Importer for Distance Sales Status (Typical Cases) What Korean Shippers Should Review
Direct shipping to EU consumers through the seller’s own online store (D2C) The seller (Korean seller) may qualify EU indirect representation arrangements; customs duties and fee structure
Sales through a global marketplace The seller or platform, depending on the transaction structure Clauses in the platform’s terms governing the importer’s role and the passing on of costs
B2B exports to EU importers and distributors Not applicable (standard import procedures) Data required by the buyer or representative
B2B exports under DDP terms Not applicable (the importer’s role depends on the contract) Fees and guarantee conditions based on the scope of the indirect representative’s liability

⚠️ The scope of representatives’ liability may also expand. The new UCC provides that, in certain representation arrangements, indirect representatives may bear obligations to comply with relevant legislation enforced by customs, in addition to liability for customs debt. As a result, the documentation, guarantees, and fee terms required by EU-based customs brokers and representatives may change. The actual scope of liability must be checked against the form of representation and the applicable provisions.

Penalties for systematic non-compliance in distance sales have also been introduced. Under Article 276 of the Regulation, if the same operator is found to have systematically failed to comply with distance sales obligations when releasing distance sales goods for free circulation—where a sufficiently representative proportion of infringements is identified across a substantial number of customs checks over one month—a financial penalty of at least 1% and up to 4% of the total value of goods imported into the EU over the preceding 12 months is imposed. If systematic non-compliance is identified again within six months, the penalty increases to at least 3% and up to 6% (EUR-Lex, Article 276). Operators found to be systematically non-compliant are classified as high-risk operators and may lose their trusted trader status and simplification benefits.

5. How Much Have Costs for Small Parcels Entering the EU Increased? — How the €3 Duty Is Calculated

The €3 temporary duty applies to low-value distance sales goods valued at €150 or less from July 1, 2026, to July 1, 2028. It is charged per item on the customs declaration, rather than per unit of goods. An item is a group of goods sharing the same tariff classification, goods description, and, where applicable, origin. The level of classification detail may vary depending on the declaration type (H1, H6, or H7). According to examples in the Commission’s guidance, five T-shirts of the same type incur a €3 duty, while a parcel containing both a T-shirt and a watch incurs €6. Goods eligible for preferential tariff treatment under agreements such as the Korea–EU FTA may benefit from preferential tariffs if they meet the origin requirements, do not use IOSS, and are declared using H1.

Parcel Contents (Examples) Number of Declared Items €3 Temporary Duty
5 T-shirts 1 €3
1 T-shirt + 1 watch 2 €6
3 skincare products (same classification) 1 €3

※ The €3 temporary duty is charged per item on the customs declaration, rather than per unit of goods. The actual grouping of items varies depending on tariff classification, goods description, origin, and declaration type. The third row assumes that the products are classified as a single declared item.

Since November 1, 2026, a €2 handling fee per declared item has also applied to distance sales imports, regardless of the value of the goods. The lower the product price, the greater the cost as a proportion of the selling price, making it necessary to recalculate selling prices and shipping charge policies.

💡 Customs Warehouse for Distance Sales
The new Regulation introduces a “customs warehouse for distance sales,” with a lower handling fee scheduled to apply to goods sold through distance sales from these warehouses from July 1, 2028. The specific reduction has not yet been determined. However, under Article 145, these warehouses may only be operated by importers for distance sales that use IOSS and hold Trust and Check status, or by indirect representatives holding that status. The goods must comply with EU market requirements when they enter the warehouse (EUR-Lex, Article 145). As this is not an option that ordinary sellers can use immediately, direct shipping of individual parcels and EU-based fulfillment (bulk entry followed by dispatch within the EU) should be compared based on eligibility and total costs, including warehousing, inventory, and intra-EU delivery costs.

6. Trust and Check and AEO: Why Do They Matter When Choosing an Import Partner?

Trust and Check is a separate simplification status for operators that provide customs authorities with maximum transparency over their supply chains. The Commission explains that these operators can handle all import customs clearance through the customs authorities of the Member State where they are established. Depending on eligibility, simplifications may include fewer inspections and self-release.

The existing AEO framework remains in place. In the EU, it comprises AEO for customs simplifications (AEOC) and AEO for safety and security (AEOS). Importers, exporters, and indirect representatives established in the EU that have regularly carried out customs activities for at least two years may apply for Trust and Check status (EUR-Lex, Article 31).

These statuses matter to Korean shippers because the qualifications required vary depending on the customs procedure and transaction type.

Scenario Required Status (Under the Regulation)
Customs representative carrying out procedures for releasing distance sales goods for free circulation AEOC or Trust and Check status
Operating a customs warehouse for distance sales (lower handling fee) Use of IOSS + Trust and Check status

The procedures available may vary depending on the status held by your import representative and customs clearance partner. Actual customs clearance times and costs depend on the goods, procedures, customs risk assessments, and contract terms. For information on Korea’s AEO certification system, see the AEO Guide.

7. What Should Korean Shippers Review Now? — A Checklist by Shipper Type

# Checklist Item D2C / E-commerce Sellers B2B Exporters Check
1 Organize product codes, manufacturer part numbers, and EAN data required for mandatory PID reporting ● — □
2 Recalculate selling prices and shipping charges to reflect the €3 duty (per declared item) and €2 handling fee (per item) ● — □
3 Determine whether your business becomes the importer for distance sales for each sales channel (own online store / marketplace) ● — □
4 If not established in the EU, check whether you can secure an indirect representative holding AEOC or Trust and Check status ● — □
5 Review marketplace terms for clauses on importer liability and the passing on of costs ● — □
6 Compare the total costs of direct shipping of individual parcels and EU-based fulfillment ● ○ □
7 Update master data for each product: HS code (at least six digits), origin, and customs value ● ● □
8 Review commercial invoice goods descriptions for specificity (remove generic descriptions) ● ● □
9 Check for changes in data requirements from EU buyers and local customs brokers ○ ● □
10 Review the importer’s role and the representative’s fees and guarantee conditions in DDP contracts ○ ● □

● Priority review ○ Review if applicable

※ This checklist covers general practical review points. Specific obligations may vary depending on the transaction structure and Member States’ implementing legislation. Please consult a customs expert to determine your legal status and calculate the duties and taxes payable.

Conclusion — Start by Preparing Your Data, Rather Than Waiting Until 2028

The EU Customs Code reform may seem like a long-term undertaking extending through 2034, but its impact on Korean shippers has already begun. Customs duties on low-value imports changed in July 2026, and mandatory PID reporting and the handling fee took effect on November 1.

The more fundamental change is that the basis of customs clearance is shifting from “documents” to “data.” From 2028, the seller or the platform facilitating the sale will assume the importer’s role in distance sales, depending on the transaction structure. For ordinary B2B imports, the EU importing company remains the importer, but expectations for data accuracy may also increase. D2C sellers need to plan now how the importer’s role will be fulfilled within the EU, while B2B exporters need to establish how to provide accurate data required by buyers and representatives. Doing so can turn the transitions in 2028 and 2034 into a competitive advantage rather than a cost.

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Frequently asked questions (FAQ)

Q. When does the new EU Union Customs Code (UCC) apply?
Regulation (EU) 2026/2108 entered into force on September 20, 2026, and generally applies from September 21, 2027 (Article 287, with exceptions for certain provisions). The distance sales provisions and mandatory use of the Data Hub for e-commerce apply from July 1, 2028. Voluntary use by other traders begins on March 1, 2031, followed by mandatory use for all traders on March 1, 2034.
Q. What is the PID that became mandatory on November 1?
It is a product identifier used to identify goods when declaring distance sales imports valued at €150 or less. The seller’s or platform’s product identifier (M-PID) and the non-standard product identifier assigned by the manufacturer, producer, or product supplier (NS-PID) are required in all cases. Standard identifiers (S-PID), such as EAN, must be declared where available. Voluntary reporting was available from July 1, and reporting became mandatory on November 1.
Q. If I sell directly from Korea to EU consumers, do I become the importer?
In distance sales, the seller or the platform facilitating the sale may become the importer for distance sales, depending on the transaction structure. The relevant provisions apply from July 1, 2028. If you are not established in the EU, an EU-established indirect representative holding AEOC or Trust and Check status may clear the goods on behalf of the importer for distance sales and assume its obligations. You therefore need to review the arrangements for each sales channel.
Q. Is the €3 duty charged on each individual product?
No. It is charged per item on the customs declaration, rather than per unit of goods. According to examples in the Commission’s guidance, five identical T-shirts incur a €3 duty, while a parcel containing both a T-shirt and a watch incurs €6. Separately, since November 1, 2026, a €2 EU handling fee per declared item has applied to distance sales imports, regardless of the value of the goods.
Q. Are companies that only export B2B also affected?
In ordinary B2B transactions where the EU importing company is the importer, direct application of the importer for distance sales and PID requirements is limited (this may vary depending on the contractual and representation arrangements). However, the introduction of the Data Hub and the expanded scope of indirect representatives’ liability may raise the standards of data accuracy required by buyers and local customs brokers.
Q. What penalties apply to violations of the Regulation?
Article 276 provides that, where the same operator’s non-compliance with distance sales obligations during customs clearance of distance sales goods is found to be “systematic,” a financial penalty of at least 1% and up to 4% of the total value of goods imported into the EU over the preceding 12 months is imposed. If systematic non-compliance is identified again within six months, the penalty increases to at least 3% and up to 6% (EUR-Lex). Operators found to be systematically non-compliant are classified as high-risk operators and may lose their trusted trader status and simplification benefits. Member States may impose additional penalties.
Q. Does Trust and Check replace AEO?
No. The existing AEO framework remains in place. In the EU, it comprises AEO for customs simplifications (AEOC) and AEO for safety and security (AEOS). Trust and Check is a separate simplification status. Customs representatives carrying out procedures for releasing distance sales goods for free circulation must hold either AEOC or Trust and Check status. Operating a customs warehouse for distance sales requires the use of IOSS and Trust and Check status.

References

▶ This article provides general information based on publicly available materials as of November 2026 and does not constitute legal or customs advice. Details and application dates may vary under delegated and implementing acts. Before applying this information in practice, we recommend consulting the original legal text on EUR-Lex and seeking expert advice.

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