CLECAT POSITION ON TRUST & CHECK AND SINGLE LIABLE PERSON CONCEPTS IN EU CUSTOMS REFORM
CLECAT published this week a detailed position on the European Commission’s proposed Customs Reform, focusing on the introduction of the Single Liable Person (SLP) and Trust & Check (T&C) trader framework. While the reform aims to enhance customs compliance and efficiency, CLECAT has raised concerns that it could have unintended consequences, particularly for SMEs, logistics providers, and the broader European supply chain.
One of the key issues highlighted is the centralisation of trade facilitations under the T&C framework, coupled with the requirement for indirect representation. These changes could limit access to essential customs simplifications, undermining the ability of freight forwarders and intermediaries to continue providing efficient and compliant services. While CLECAT welcomes the Commission’s willingness to retain AEO-C status, it argues that any reductions or waivers in the comprehensive guarantee should remain part of the AEO-C framework rather than being exclusive to T&C.
CLECAT also challenges the viability of the Single Liable Person concept in complex B2B supply chains. Unlike B2C e-commerce, where a platform-based model could function as the deemed importer, B2B logistics operations involve multiple actors and customs procedures such as transit and warehousing, which the proposed framework fails to adequately consider. The mandating of indirect customs representation as a condition for accessing trade facilitations could create additional compliance burdens, financial strain, and operational bottlenecks, particularly for SMEs and customs intermediaries.
Instead of imposing additional liability on intermediaries, CLECAT calls for a sector-specific approach to non-fiscal compliance obligations. It advocates for greater investment in modern digital solutions, such as Single Window IT systems, that enhance data accuracy and security without overburdening businesses.
CLECAT urges European legislators to revise the proposed approach to ensure that the reform does not disrupt well-functioning customs processes or hinder the competitiveness of the European logistics sector. A balanced and inclusive approach is needed to protect SMEs, supply chain resilience, and trade facilitation across the EU.
The full position paper is available here.