Changes to customs policies across the EU, US and Asia are re-shaping global supply chains.

And the evolving compliance and trade landscape creates complexity and risk for businesses, who need to consider carefully how this may affect their operations, particularly when sudden changes can affect access to markets and upstream suppliers.

In this article, we consider recent developments and forecasts for 2026 that underline why businesses must take action to integrate compliance across their supply chain to protect their resilience.

Tariffs and trade agreements will force re-wiring (and integration) of supply chains

In the EU alone, three major regulatory changes will require substantive adjustments to customs management. The Import Control System 2 ( ICS2, Release 3) is already live in most member states, while some are yet to implement locally implement locally within the EU’s timeframe. The Carbon Border Adjustment Mechanism (CBAM) is in a transition phase and will come into full effect from January 2026. Finally, the EU Deforestation Regulation (EUDR) - even if the planned date of coming into force on December 30th, 2025 is potentially postponed - will require substantial preparations and adjustments.

Changes such as these force companies trading across borders to adapt their customs operations and suppliers, bringing trade rules firmly to the fore as leaders consider both the risks and opportunities for their supply chains and wider business operations. Boston Consulting Group recommends that trade compliance is “embedded in activities from product development to logistics to sales” to cope with the increasingly complex trade rules.

In short, for businesses to maximise their advantage going into 2026, better integration of customs operations will go hand-in-hand with re-wiring supply chains. Below, we’ve highlighted some actions to prepare for ICS2, CBAM and EUDR specifically:

ICS2: how to prepare

Goal: Avoid departure and arrival delays due to incomplete Entry Summary Declarations.

Actions:

1. Verify your upstream freight forwarders and carriers are prepared for ICS2.
2. Adjust processes to ensure ENS is submitted before cargo departure.
3. Coordinate with logistics partners to prevent hold ups at origin.

CBAM: how to prepare

Goal: Ensure accurate emissions reporting and readiness for certificate obligations starting 2026. Incorrect or missing 2025 data will directly impact 2026 certificate obligations.

Actions:

1. Register as CBAM declarant, if you’re subject to these regulations, and establish CBAM reporting processes.
2. Identify required emissions data and communicate requirements to upstream suppliers so they can provide the correct data, including direct & indirect emissions and installation-specific data from upstream suppliers.
3. Prepare for CBAM certificate purchases in 2026, based on 2025 reporting.

EUDR: how to prepare

Goal: Ensure due diligence and cargo handling align with EUDR to avoid hold-ups & delays.

Actions:

1. Understand how EUDR impacts your business, and establish due diligence systems for upstream suppliers.
2. Ensure references to the approved due diligence statement (DDS) is available for the customs declaration that needs submitted to customs. This means ensuring DDS approval prior to cargo arrival on EU imports, and prior to submitting the export declaration to customs on EU exports, to avoid customs hold-ups.
3. Understand the cargo-separation requirements and arrange shipments to support traceability and compliance.

Collectively, these actions will help businesses to achieve smooth customs processes integrated into their supply chain, avoiding costly delays and penalties, while protecting your resilience and regulatory credibility.

How can Maersk help?

Partnering with Maersk strengthens supply chain resilience and efficiency, by bringing sourcing, logistics and customs together in an integrated approach. In the UK, an operations client was facing uncertainty about how customs adjustments were going to impact their business. This was partly due to limited internal expertise around compliance processes and what was required to digitalize operations. Maersk provided a customs expert, acting as an in-house consultant, who provided flexible support across both short and long-term planning. As a result of this engagement, Maersk helped the company to avoid a £1m penalty by resolving compliance errors.

A company representative explained: “Maersk optimised our daily routines, offered insights on future process improvements, and guidance on broader government policy, reducing costs and enhancing efficiency.”

Product production regulations will ramp up data integration demands

Data readiness – and specifically product data readiness – will become a critical differentiator for businesses and their customs operations in 2026.

What’s changing?

The Ecodesign for Sustainable Products Regulation (ESPR) came into force in July 2024, but is still pending confirmation of specific product requirements. Getting a head start on preparations for this element coming into force is recommended, as it will impose complex product data demands on businesses at distinct points along their supply chain:

1. Design – ESPR sets performance and information rules for nearly all categories of physical goods. This will include requirements such as making products easier to remanufacture, limiting waste generation, and enhancing product durability, repairability and upgradability.
2. Manufacturing – The CBAM requires businesses to make emissions declarations on imports that will affect the cost of importing products with carbon-intensive manufacturing processes. If businesses need to adjust their manufacturing processes in light of ESPR, then it will have a knock-on effect for CBAM reporting, too.
3. Import & export – The ESPR will introduce a requirement for a Digital Product Passport (DPP). This product identity card will be accessible electronically and may allow customs to improve their automatic controls to better target the desired control objects.

What does this mean for businesses?

Businesses will be required to collect more product data, and ensure their digital infrastructure can support consistent and accurate data reporting. Customs specialists will need to understand where and when data is required across the supply chain, and when prior preparations need to be made. When Maersk handles your customs, you get one contact point, which improves visibility and the flow of data, particularly when integrating other Maersk services.

How can Maersk help?

Maersk can help businesses to optimise their customs operations, aligning this with your broader business priorities. The Trade & Customs Consultancy service can perform a material database assessment and advise on improvements in data gathering, handling, and reporting. For businesses operating across multiple regions and geographies, Maersk can help to streamline activities, including working to reduce the impact of new data demands.

Flexible customs setups will be critical to maintain a resilient, adaptable supply chain.

Importers and exporters will need to sustain flexible and agile customs operations, as challenging operating environments persist, and delays and re-routing continue to be ever-present risks. For example, there has been a recent uptick in customs inspections in the UK and US that will increase demands on importers.

What’s changing?

The UK customs authority, HMRC, has laid out a digitalisation roadmap, which includes integration of AI and other automations to reduce errors and speed up customs checks. This cuts both ways, as the authority expects businesses to digitalise their own operations, to meet the demands of processing more data, ensuring data accuracy and timely data accessibility.

The US authority, CBP, is actively encouraging people to report trade violations through its e-Allegations whistleblower programme, which could lead to more examinations of shipments deemed suspicious.

What does this mean for businesses?

Ensuring that documents are accurate, with proper classification of goods and key details made readily available - such as details of the importer of record, country of origin, currency, and proper product descriptions – will be important.

We also recommend familiarising yourself with additional requirements for specific or high-risk goods, such as CHED-D documents for food and feed of non-animal origin.

How can Maersk help?

Your customs operations can be a critical enabler for your logistics, helping to minimise or avoid delays. Our deep regulatory expertise across our strong global and local network helps to improve speed and reliability if you face increased scrutiny and checks on your imports. There are also potential cost efficiencies when integrating with other Maersk services such as ocean, inland and air, as there are no handover fees.

Furthermore, our AEO certification means businesses involved in international trade can benefit from simplified customs procedures.

How Maersk Customs Services can help you be ready in 2026

Customs has never been more important for supply chain success, and partnering with Maersk will support efforts to make customs an enabler in your 2026 supply chain strategy.

Want to turn customs compliance to your advantage in 2026? Book a meeting with one of our customs experts.

For more information on Maersk Customs Services, learn more here.