customs

The removal of the de minimis threshold, together with the proposed amendments to the UCC Delegated and Implementing Acts on customs declarations, will have significant operational implications for freight forwarders, customs representatives and other logistics service providers. CLECAT therefore provides the following comments with a view to ensuring that the implementation of these measures effectively addresses e-commerce challenges while remaining operationally feasible and proportionate for compliant economic operators across the EU Customs Union.

CLECAT calls for an implementation that is operationally feasible for freight forwarders, logistics service providers and customs representatives and aligned with customs reform objectives.

Our recommendations:

• meaningful consultation with logistics stakeholders and practitioners throughout the design and rollout
• preserve simplified procedures for low-value consignments, including the extension of H7 simplified procedures and the application of the EUR 3 duty to distance sales shipments below EUR 150, independent of the method of VAT collection
• Reuse of Article 14(4) of Council Directive 2006/112 (the VAT Directive) for the definition of distance sale shipments, to better define the actual scope of these measures (i.e. e-commerce items, independent of the method of VAT collection)
• Keep items subject to Prohibitions and Restrictions (P&R) under H1, ensuring that the additional data of H1 declarations facilitates better controls of these items
• do not add new data elements to H7 which declarants cannot realistically and compliantly obtain, nor which national customs systems automatically validate
• mandatory IT readiness assessments and contingency planning at national level, as well as realistic lead times for IT and operational adaptations
• close operational coordination between customs authorities and trade to support the transition to new declaration flows and avoid unnecessary disruption to legitimate trade

CLECAT supports the modernisation of EU customs and fairer treatment of e-commerce flows. However, without careful design, realistic timelines and genuine trade involvement, the removal of the customs duty de minimis risks slowing legitimate trade and affecting the entire logistics sector.