Product compliance · Customs
Clearing customs — and the reform reshaping it
A product does not reach an EU shelf without clearing customs first, and customs asks the same question compliance does: who in the EU answers for this. The rules for that are changing — the Council and the European Parliament adopted the biggest reform of the EU customs union since 1968 in September 2026.
Who declares
Every import needs an EORI number and a customs declaration under the Union Customs Code, Regulation (EU) No 952/2013 — an operator not established in the EU's customs territory has to register before lodging one, with narrow exceptions for travellers' goods and postal consignments.
The EU-based operator every import needs
The same duty that names a GPSR responsible person shows up at the border: Regulation (EU) 2019/1020, article 4, requires an economic operator established in the EU for products under harmonised legislation before they can be placed on the market, tasked with holding the compliance documents and answering market surveillance. Where the manufacturer sits outside the EU, the importer is usually that operator — the evidence file and the customs declaration end up naming the same party.
The reform: e-commerce sellers become the importer
The Council gave its final approval on 3 September 2026 and the European Parliament's plenary vote followed on 16 September; a new EU Customs Authority based in Lille will run a shared Data Hub across the Union. Sellers and platforms selling directly to EU consumers from outside the Union are now treated as the importer of the goods — responsible for the customs data, the charges and the product-compliance checks a private buyer never used to face. A handling fee for these consignments applies from 1 November 2026; most of the recast Code's other provisions follow roughly twelve months after it enters into force.
- Fines for repeated non-compliance can reach 6% of the operator's annual import value
- The exemption that let low-value parcels through duty-free is going with it
Evidence to keep
What a declarant, or an authorised representative filing on an importer's behalf, needs on hand.
- EORI registration and the declarant's authority to act
- The technical file and conformity documentation behind the declared goods
- The responsible-operator designation named in both the compliance file and the declaration
- Origin and classification evidence for the tariff heading declared
How Listrar structures it
A record's operator, evidence and identifiers are the same data a declaration asks for, restated in customs terms — the agent feed exposes them in a machine-readable form a broker's system can read directly, instead of a compliance file re-keyed by hand for every shipment.
Questions this page answers
- Does the reform change who is liable for a marketplace sale?
- Yes, for direct sales from outside the EU: the seller or the platform facilitating the sale is now treated as the importer, not the consumer receiving the parcel.
- Is the economic operator of Regulation (EU) 2019/1020 the same as GPSR's responsible person?
- Not formally the same clause, but the same function for most consumer products — an EU-established party market surveillance and customs can reach, named once and read by both rules.
Official sources
Last verified by Listrar: September 23, 2026