Customs Reform
EU Customs Reform 2028: Why Freight Forwarders and AGP Holders Must Act Now
In April 2024, the European Parliament adopted its position on the reform of the Union Customs Code, a legislative package originally proposed by the European Commission in 2023 that significantly changes the foundation of the European customs system. The implementation deadline is set for 2028, but anyone working in freight forwarding and bonded warehousing who assumes nothing needs to happen for several more years underestimates what is coming. The EU Customs Data Hub, changes to the trusted trader structure, and the removal of certain declaration thresholds are not minor adjustments. They are major changes in how customs data is submitted, processed, and shared.
Industry organizations such as Fenex and customs software providers are already warning that preparation may take one to three years. That makes 2026 a critical time to begin.
Quick Navigation:
- How the current customs system works and why it no longer meets requirements
- What the EU Customs Data Hub changes in daily operations
- The revision of AEO status and what it means for AGP holders
- What the customs reform concretely means for the next twelve months
- What freight forwarders can do now
- Conclusion
How the current customs system works and why it no longer meets requirements
The current Union Customs Code has existed in this form since 2016 and is built on national systems that were later connected at the European level. In practice, this means national IT systems, national declaration systems such as AGS in the Netherlands, and a fragmented overview of goods flows within Europe.
Member states exchange information through different systems that were not designed for the volume and complexity of modern global trade.
The European Commission believes this system falls short in three areas. First, it is vulnerable to fraud because there is no central overview. Second, differences in rules and procedures between countries create inequality. Third, the system cannot properly process the growth of e-commerce and the large number of small shipments. The reform currently planned is the biggest change in nearly ten years.
What the EU Customs Data Hub changes in daily operations
The most important measure is the introduction of the EU Customs Data Hub, a centralized European platform where customs data will be submitted, processed, and shared. This may seem like a technical change, but it has major practical consequences.
From national declarations to one European data model
Currently, a freight forwarder submits declarations to the national customs authority, for example through AGS or NCTS. These systems have limited interoperability with other countries. With the Data Hub, this changes. Data will become directly available centrally to all relevant authorities. This requires a different approach to handling data.
System and integration adjustments
For freight forwarders, this means that integrations between their own systems and customs systems must be adapted to European standards that are still under development. Companies currently relying on national integrations will need to modify them. Such adjustments take time, often one and a half to two years.
New role for warehousing and increased administrative pressure
For bonded warehouse operators and AGP depots, even more will change. Under the new model, part of the reporting obligation may shift to the party physically managing the goods. This means storage companies may eventually have to report directly to the Data Hub themselves. This changes their role and responsibility. The exact rules will be determined later, but the direction is already clear.
Certain declaration thresholds will also disappear or change. Companies currently benefiting from simplified procedures, for example for specific goods flows, may lose those advantages. This means more administration and higher costs if processes are not adjusted.
The revision of AEO status and what it means for AGP holders
AEO status is important for many companies because it provides benefits such as faster processing and fewer inspections. The reform does not eliminate this status, but changes it within a new system called Trust and Check. Companies meeting these requirements gain more flexibility but must also share more data.
The question is whether existing AEO certifications will automatically transfer. Based on the current proposals, this is uncertain. Transitional rules will be introduced, but the details will be defined later. Companies therefore cannot assume everything will remain unchanged.
For AGP holders, this is especially important. Their processes are often linked to the trusted trader structure. Changes in AEO rules may affect how excise goods are stored and transported. This remains an area with significant uncertainty and where contact with Customs authorities and organizations such as Fenex is important.
What the customs reform concretely means for the next twelve months
The impact of the reform differs by company. Large freight forwarders often have more resources, but also more complex systems. Smaller companies are more vulnerable because they have less time and capacity to implement changes.
The legislation is not yet final. Negotiations between the European Parliament, Council, and Commission are still ongoing. Details may still change, but the overall direction remains the same. Waiting until everything is finalized wastes time that may no longer be available later.
An important point is collaboration between freight forwarders and customers. If responsibilities change or more data becomes necessary, agreements will need to be updated. Contracts and workflows that make sense today may no longer fit tomorrow’s requirements.
What freight forwarders can do now
In the short term, it is important to gain insight into the current situation. Follow developments through the European Commission and industry organizations such as Fenex. Map out which customs statuses your organization currently holds and what benefits they provide.
Also review current data flows. Which systems are being used and who manages them? This helps determine where adjustments will be necessary.
In the medium term, between three and twelve months, it is advisable to appoint someone responsible for this topic. This person can monitor developments and translate them into operational practice. Create an overview of existing integrations with customs systems and discuss with IT what is required to adapt them.
Contact your software provider and ask about their plans for connecting to the Data Hub. This provides insight into how far the market has progressed with this transition.
Conclusion: EU customs reform 2028 requires action now from freight forwarders and AGP holders
The question is whether 2028 is still far away or whether action is already necessary. The answer is clear. The EU Customs Data Hub requires adjustments that take several years. Changes in AEO and trusted trader rules may affect existing benefits. The removal of thresholds will create additional administrative burdens. And many details still need to be finalized, making the effective preparation period shorter in practice.
What remains important to monitor are the completion of negotiations, the publication of implementing rules, and the plans of Dutch Customs regarding connection to the Data Hub. Industry organizations will continue to provide support, but every company must translate these developments into its own organization.
Sources and Background
- European Commission customs reform
https://taxation-customs.ec.europa.eu/customs/eu-customs-reform_en - Council of the EU agreement 2026
https://www.consilium.europa.eu/en/press/press-releases/2026/03/26/eu-customs-council-and-parliament-agree-on-landmark-reform/ - European Parliament dossier
https://www.europarl.europa.eu/legislative-train/theme-an-economy-that-works-for-people/file-revision-of-the-union-customs-legislation - Think Tank analysis
Establishing an EU customs data hub and an EU customs authority | Think Tank | European Parliament - TLN customs reform
https://www.tln.nl/actueel/eu-bereikt-akkoord-over-ingrijpende-hervorming-douanestelsel - Customs AEO permit
Information on the Authorised Economic Operator (AEO) permit - Customs AEO explanation
AEO permit in brief - AGP permit
Application for an excise goods warehouse permit