Rotterdam: Officials inside the Port of Rotterdam’s customs office have started preparing the technical groundwork for what Commission negotiators describe as the most consequential category of trader created by the March political agreement on customs reform. The Trust and Check trader status, designed to replace and significantly expand the existing Authorised Economic Operator framework, will give the bloc’s most transparent companies the ability to release goods into circulation without any active customs intervention, provided they share continuous data on movement and compliance with the new EU Customs Data Hub.
The data hub itself will become operational for e-commerce consignments on 1 July 2028, with a phased rollout pulling every category of goods movement into scope by 1 March 2034. Rotterdam’s role in early testing is no accident. The port handles roughly fifteen per cent of all customs declarations filed in the bloc, and Dutch customs authorities have been working with the Commission’s DG TAXUD since late 2024 on the data architecture that will sit underneath the new architecture.
The political agreement struck on 26 March between the Council and Parliament confirmed the broad outline of the reform but left dozens of technical questions to delegated and implementing acts. Among them is the precise list of data fields that a Trust and Check trader will need to provide, the audit cycle that customs authorities will use to verify compliance, and the conditions under which the status can be suspended. The Commission’s draft delegated act on data fields is expected before the summer recess, with Member State experts already split on whether to include real-time inventory data or only declaration-level data points.
For businesses, the carrot is substantial. Trust and Check traders will be able to centralise customs clearance in a single Member State while operating warehouses and distribution networks across the bloc, even when goods physically arrive in another port. That promise of a one-stop interface is what industry groups have been demanding since the original Union Customs Code took effect in 2016. The stick is equally clear. Failure to maintain the data flows triggers immediate suspension and a return to declaration-by-declaration clearance, with the associated time and cost penalties.
The reform also reshapes who carries responsibility for compliance. Online marketplaces and distance sellers selling into the bloc are now treated as the goods’ importer, removing the structure that previously allowed individual consumers to be designated as the legal importer for low-value parcels. That shift, combined with the upcoming three euro per item flat-rate duty on e-commerce consignments under EUR 150 from 1 July 2026 to 1 July 2028, fundamentally redraws the operating model for non-EU e-commerce platforms targeting European consumers.
Rotterdam customs officials told the trade press last week they expect the first wave of Trust and Check applications to come from chemical, automotive and pharmaceutical traders already operating under the existing AEO framework. The Dutch authority has earmarked twelve audit teams to process the initial certifications. Whether other Member States can match that capacity remains an open question, and the Commission has flagged in informal Council notes that uneven national resourcing risks creating a two-speed customs union just as the data hub goes live.
