Customs in 2025: Major updates for the EU & UK

January 1, 2025 – Changes to Customs Commodity Codes

On October 31, 2024, the EU Commission announced changes to the Combined Nomenclature: 49 new codes were introduced, and 34 codes which were declared invalid. Starting January 1, 2025, companies have to report the commodity codes listed in the Commission Implementing Regulation (EU) 2024/2522 of September 23, 2024 in exports or intra-Community transactions. It is of utmost importance to use the correct commodity codes to prevent incorrect tax assessments and avoid unauthorized exports.

January 1, 2025 – Compliance with reporting requirements and new reporting portal

All CBAM reporting must fully comply with the EU method as of 1 January 2025. This means it is no longer allowed to use default values in reports, which was possible throughout 2024. Reports submitted from 2025 onwards that still include default values will not be accepted.

Additionally, a new portal section of the CBAM Registry will be available to installation operators outside the EU to upload and share their installations and emissions data with reporting declarants in a streamlined manner. Throughout the year, CBAM declarants will be able to apply for the ‘authorised CBAM declarant’ status via the CBAM Registry, which will become mandatory as of 1 January 2026.

January 1, 2025 – Enforcement of new modernized rules of origin in the Pan-Euro-Med zone

New rules of origin apply under the Regional Convention on Pan-Euro-Mediterranean (PEM) from 1 January 2025. The 24 PEM contracting partners modernized the previous rules to add more flexibility to the preferential trade agreement. Some of the contracing partners will implement the new rules only later this year.

Key changes and benefits include streamlined handling and processing rules, elimination of cumulative requirements, lower thresholds, consolidation of rules of origin, and elimination of many former rules for HS headings and subheadings.

More information about the new rules, implementation dates for all partner countries, changes to proof of documentation and more can be found in our deep-dive magazine article: PEM: New rules of origin coming January 1, 2025

April 1, 2025 - Road and rail economic operators need to start using ICS2

Starting April 1, 2025, rail and road carriers will also be able to connect to ICS2 to submit Entry Summary Declarations (ENS) for imports by rail and road. From September 1, 2025 onwards, it will be mandatory for them to use ICS2.

ICS1 will be fully phased out by September 1, 2025, which means all economic operators will be required to use ICS2 only from that day.

December 30, 2025 – Commence operation of due diligence systems for medium and large operators and traders

From December 30, 2025, EUDR rules will also apply to medium & large operators and traders. These entities must exercise due diligence with regards to all products in scope of the regulation from each of their suppliers. This requires a due diligence system to be in place. This change simultaneously marks the end of a 12-month additional phasing-in period, which was granted by the European Union in 2024.

Micro and small enterprises will need to comply from June 30, 2026 onwards

January 1, 2025 – Updated Commodity Code Structure and Declaration Table

An overview of the commodity code changes for 2025 can be found in the 8 Digit Commodity Code Correlation Table 2024/2025 and Update to Commodity Code Structure, which was published on November 6, 2024.

UK changes maintain dynamic alignment with the EU. These updates also include Northern Ireland Agriculture Quotas and updates to suspensions.

January 31, 2025 – Mandatory reporting for importing EU-goods and reduction of declaration data

From 31 January 2025, any goods imported from the EU to Great Brittain must be covered by a Safety and Security declaration, also known as Entry Summary Declarations (ENS). This procedure has been put in place in support of the fight against illicit goods entering the UK. 

Carriers or hauliers are legally responsible for submitting Safety and Security declarations. A party other than the carrier, such as the importer or an intermediary, can lodge the declaration on the carrier’s behalf, although the carrier is still responsible for making sure the Safety and Security declaration is submitted.

Completing Safety and Security declarations has been made easier by decreasing the amount of information that is required to be completed.

January 31, 2025 – Replacement of document code 999L for import declarations

From 1 February 2025, code 999L will not be valid and declarants will need to use an alternative document code to apply a waiver to their declaration. At the same time, document code Y999, which operates in a similar fashion to 999L, will also be removed from most tariff measures.

See an overview of the National waiver document codes replacing 999L or view the full list in Data Element 2/3 Documents and Other Reference Codes (National) of the Customs Declaration Service (CDS)

After 31 January 2025, import declarations that use the 999L waiver document code will not be accepted. This can lead to disruptions in your goods movements, if not adjusted.

More information on this change can be found in our Help Center article: HMRC Announce Removal of Document Code 999L (and Y999)

April 1, 2025 – Maritime house level filing

From 1 April 2025, safety and security data reporting requirements also apply to maritime houses. This is part of the third implementation phase of the ICS2 system, which has different transition periods for sea carriers, house filers, and road and rail carriers.

September 1, 2025 – Road and rail filing

From September 1, 2025, safety and security data reporting requirements also apply to road and rail carriers. This implementation date marks the completion of implementation phase 3 of the ICS2 system.