The Union Customs Code (UCC) reform package — first announced in 2023 — is rolling out in phases through 2028. The 2026 phase brings some changes that buyers in EU member states importing US-origin goods need to factor into their cost models.
What is actually live in 2026
The headline 2026 changes that affect US-to-EU trade:
- The 150-euro low-value parcel duty exemption is unchanged — the long-discussed elimination is now targeted for 2028. For 2026, parcels under 150 EUR from a non-EU origin still qualify for duty-free clearance (VAT still applies).
- IOSS (Import One-Stop Shop) remains the simplest path for distance sales of low-value goods into the EU. US suppliers shipping to EU consumers can register for IOSS and collect VAT at checkout.
- CBAM (Carbon Border Adjustment Mechanism) definitive period begins January 2026 for cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. Importers of these specific categories need to surrender CBAM certificates from 2026 onward.
- Centralised Clearance pilots continue but full rollout is post-2026.
What this means for typical US-origin buyers
For most US-to-EU trade — apparel, electronics, machinery, consumer goods — the day-to-day workflow is unchanged from 2025:
- Common External Tariff (CET) applies. No FTA means MFN rates: 0–14% depending on HS code.
- VAT is set by the member state of import (avg 21%, range 17–27%).
- EORI number required for the importer of record.
- Filed via the national customs portal of the member state.
CBAM: only relevant for specific industries
If you're importing US-origin cement, iron/steel, aluminium, fertilisers, hydrogen, or electricity into the EU, you now need to:
- Register as an "authorised CBAM declarant" in the EU member state
- Calculate embedded emissions for each shipment (or use default values)
- Surrender CBAM certificates equal to embedded emissions × (EU ETS price – US carbon price difference)
For everyone else (the 95%+ of US-EU trade), CBAM doesn't apply. Don't let CBAM headlines spook your duty modelling for typical commercial goods.
Worked example: 40,000 EUR US apparel order into Germany
| Line | EUR |
|---|---|
| CIF at Hamburg | 40,000 |
| German customs duty (12% MFN on most apparel) | 4,800 |
| German VAT base | 44,800 |
| German VAT (19%) | 8,512 |
| Broker + final mile | 600 |
| Total landed | 53,912 |
The 12% CET rate is unchanged in 2026. If the apparel is a category that qualifies for US Generalized System of Preferences (GSP), no — GSP is for developing-country exporters from the US, not for US exporters. There is no equivalent preference for US-origin goods entering the EU.
What is coming in 2027–2028
- The 150-euro low-value exemption is targeted for elimination — once in force, all parcels regardless of value will need a customs declaration and may incur duty
- New "EU Customs Authority" centralised body to coordinate national customs
- Mandatory data sharing for high-risk goods
Plan around the 2026 ruleset for now; we will publish a follow-up when 2027 changes firm up.
What to do
Use the EU Customs Duty Calculator with your specific HS code. For low-value parcels, ask the US supplier whether they're IOSS-registered — if yes, your VAT is handled at checkout and the parcel clears faster.
