“Customs has never been more important than today, but it will be more important tomorrow.” The words of Maersk Head of Global Trade and Customs Consulting, Lars Karlsson, resonate now more than ever as we move into 2026, with customs and tariffs hitting headlines just about every day and customs strategy becoming more and more fundamental to supply chain success.

However, in such an ever-changing industry, staying on top of the latest developments and growing trends can prove challenging. Here are five key regulations changes to look out for in 2026 and the impact they could have on European supply chains.

End of EU’s low-value ‘de minimis’ exemption

From 1st July 2026, the EU will remove its long standing €150 customs duty exemption for low value imports, meaning every commercial shipment entering the bloc will be subject to duties. The change was originally due to happen in 2028, but it’s been accelerated to 2026 and a flat-rate duty of €3 per item type will soon apply.

The change will have a noticeable impact on e commerce and parcel driven supply chains. For businesses, this marks the end of simplified treatment for low value goods and brings these flows fully into standard customs controls. As such, the number of shipments requiring full customs processing will increase significantly, putting more pressure on border processes and therefore placing greater emphasis on accurate shipment data.

There will also be cost and pricing implications. While €3 per item type may appear modest, it represents a meaningful cost for low value items and will need to be factored into pricing, checkout processes, or delivery fees. Over time, this may dampen the volume of very small direct to consumer shipments.

Experience from similar changes in the US in 2025 suggests wider knock on effects, too. As low value parcels became subject to duties, many companies shifted away from shipping individual items directly to consumers and instead imported goods in bulk and stored them closer to the end market. A similar trend is likely in Europe, with increased demand for EU based warehousing, consolidation hubs, and regional distribution centres to reduce per shipment costs and improve delivery reliability.

Read more about it in the Maersk Global Market Update for Winter 2026.

EUDR delayed until December – but no time to relax!

The European Union Deforestation Regulation (EUDR) is a major new trade regulation designed to ensure that goods arriving or leaving the EU market are not linked to deforestation. It applies to key commodities including cattle, cocoa, coffee, palm oil, soy, rubber, and wood, as well as a wide range of derived products such as chocolate, furniture, and paper.

Under EUDR, companies must be able to demonstrate that products were not produced on land deforested after 31st December 2020 and that they comply with local laws. This requires a formal due diligence process, including collecting precise geographic data on where goods were produced, assessing deforestation risk, and submitting a digital Due Diligence Statement (DDS) before goods can be imported or exported.

Following a one year deferral agreed in late 2025 in order to allow businesses to get prepared, the regulation now will apply from 30th December 2026 for medium and large companies, and from 30th June 2027 for micro and small enterprises. While enforcement begins at the end of 2026, it’s safe to say the entire year will be a critical preparation period for European supply chains.

The impact on supply chains is significant. EUDR introduces plot level traceability requirements that many agricultural and forest based supply chains were not previously designed to support. Importers will only be able to clear goods through EU customs if a valid DDS reference is provided, effectively making sustainability compliance a prerequisite for customs clearance. This increases the risk of delays or supply disruptions where data is incomplete or suppliers are not ready.

To prepare, companies should use 2026 to map their supply chains, identify high risk origins, and engage closely with suppliers to secure the required data. Businesses that act early will be better positioned to avoid last minute shipment blocks and maintain continuity once EUDR enforcement begins.

That’s very much the plan for retail giant Primark, who said that they welcome the delay but aren’t taking their foot off the gas. Watch the interview with Primark Head of Customs, Ronnie Bennett, below.

CBAM officially comes into force

As of 1st January 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) is live and now an enforceable, financial obligation for importers. The policy is designed to ensure that EU manufacturers, who already offset emissions under the EU Emissions Trading System (ETS), are not undercut by imports produced under less stringent climate rules. In practice, CBAM introduces a cost on certain imported products, reflecting the greenhouse gas emissions generated during their production.

CBAM initially applies to iron and steel, aluminium, cement, fertilisers, electricity, and hydrogen, with the scope expected to expand to selected downstream products over time. Importers must measure and report the embedded emissions of these goods and purchase CBAM certificates to cover the emissions.

Now in the first year of full CBAM implementation, only authorised CBAM declarants can import covered goods into the EU, and every shipment begins accumulating an emissions cost. While payments for 2026 imports will be settled in 2027, the financial and operational impact starts immediately in 2026.

For European supply chains, CBAM introduces a new cost and data requirement at the border. Importers must obtain reliable emissions data from non EU suppliers – and where this data is missing, conservative default values may apply and increase costs. As a result, procurement decisions are likely to shift towards lower emission producers, recycled materials or suppliers operating under equivalent emissions pricing regimes, which could have a knock-on effect on trade flows.

CBAM also adds a new layer of customs and compliance complexity, as emissions reporting, certificate management, and annual declarations must now be integrated into import processes.

Businesses that build emissions transparency into their supply chains early will be better positioned to manage costs, avoid clearance delays, and strengthen resilience as CBAM reshapes trade into Europe.

The importance of ISC2 compliance

Import Control System 2 (ICS2) is the EU’s enhanced advance cargo information system, designed to strengthen border security through earlier, more detailed shipment data. It applies across all modes of transport and requires carriers or their representatives to submit a complete Entry Summary Declaration (ENS) before goods enter or transit the EU.

ICS2 became fully operational across air, sea, road, and rail on 1st September 2025, but several EU states and participating countries held temporary derogations into 2025–2026 to ease the transition. However, these grace periods will end in the early part of the year.

A key milestone is 3rd February 2026, when the old message formats are switched off and all ENS filings must use ICS2 version 3. By 1st June 2026, enforcement extends to all land based modes, meaning road and rail operators must lodge complete ENS data well before reaching the EU border.

ICS2 demands far more granular data than before, including accurate goods descriptions, six digit HS codes, shipper/consignee information, package counts and routing details, enabling customs authorities to conduct security screening well in advance of arrival.

Businesses across Europe have had to upgrade IT systems, standardise product data, and ensure that upstream partners can provide accurate information earlier in the shipping process in order to avoid delays.

Companies should review their data readiness, ensure HS codes and product descriptions are complete and standardised, and confirm with carriers and freight forwarders that ICS2 compliant ENS filing is embedded in their processes.

Early data submission must now be treated as a core part of logistics planning as ICS2 becomes fully enforced across Europe.

ELO brings blue sky moment to UK-EU logistics

The Obligatory Logistics Envelope (ELO) is France’s new digital border processing requirement for all trucks moving between France and Great Britain. It consolidates every customs and security document linked to a vehicle into a single scannable barcode, replacing the previous system where drivers presented multiple references at checkpoints. The ELO connects export declarations, import declarations, transit documents and Entry Summary Declarations into one digital “envelope”, allowing France’s Smart Border system to verify all clearance requirements instantly.

ELO becomes mandatory in early 2026 for every truck using French Channel crossings such as Calais, Dunkirk, and the Eurotunnel. From this point, vehicles cannot board ferries or trains without a valid ELO, and French border infrastructure will no longer accept paper bundles or standalone a Movement Reference Number (MRN). For most European supply chains trading with the UK, this covers the primary route in and out of the single market.

Exporters, importers, freight forwarders and hauliers must now align their documentation processes much earlier in the supply chain journey. The ELO cannot be generated unless all MRNs and security declarations are correct, complete, and linked, meaning every customs filing must be finalised before a truck approaches the port. Any missing or incorrect reference will trigger a refusal to board, resulting in delays, additional costs and even fiscal non compliance if export movements are not properly closed.

To ensure compliance with ELO and benefit from predictable Channel crossings, businesses should ensure they have integrated digital document flows with their logistics partners, establish clear cut off times for completing EU and UK declarations, and train drivers and dispatch teams on the new requirements.

Taken together, the de minimis exemption, EUDR, CBAM, ICS2, and France’s ELO system make 2026 a pivotal year for European supply chains. The common thread is clear: more data, more transparency and more advance preparation. While these changes raise administrative effort and may increase costs, they also push the system toward a more secure, consistent and sustainable trading environment.

Maersk’s Global Trade and Customs Consulting experts remain on hand to support with regulations changes, including through the AI-powered Global Trade and Tariff Studio product.