EU Customs Reform Shifts Liability, Impacts Swiss Businesses as New Rules Enforce Data-Driven Compliance
October 26, 2026
Importers under the new rules must be EU-established entities responsible for complying with customs and related regulations, shifting substantial liability and requiring alignment with the broader business model rather than just the goods’ ownership.
For Swiss businesses, increased trade data visibility and standardized risk assessment create obligations and opportunities; preparation involves aligning product classifications, origin, and valuation data across systems, with a voluntary testing window starting in 2031.
The reform’s implications reach beyond customs to legal entity footprints, transfer pricing, VAT, and intercompany agreements, demanding cross-functional consideration across risk, tax, legal, and operations.
The EU is reforming its customs system with the creation of the EU Customs Authority (based in Lille, operational 2027) and the EU Customs Data Hub to enable data-driven risk analysis and coordinated controls across the union.
Indirect representation by customs brokers remains possible but requires careful assessment of liability and roles within the updated framework.
The reform distinguishes between B2B (importer concept) and B2C/distance sales (deemed importer concept), requiring Swiss businesses to map their models accordingly.
E-commerce changes assign non-EU platforms as importers for goods sold into the EU, with new penalties for non-compliance and new duties, including the removal of the €150 duty exemption for low-value consignments and a temporary €3 per-item duty until 2028.
The choice of importer affects legal responsibilities, tax positions, intercompany arrangements, and supply chain flows, potentially necessitating changes to operating models and internal structures beyond the customs department.
The EU Customs Data Hub aims to centralize interactions with customs, support risk analysis, and prioritize inspections, with mandatory use for e-commerce from 2028 and for all traders from 2034.
Summary based on 1 source
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EY • Oct 25, 2026
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