The new UCC: implementation primer

The Digital Transformation of Customs

EU Customs Digitalisation · University of Liège · Faculty of Law

The shared scenario

Throughout the day, every module returns to one parcel.

A B2C e-commerce consignment — a distance sale, originating outside the EU — enters through the consolidation hub at Charles de Gaulle airport in Paris, with final destination Eindhoven, Netherlands. It travels under the legislation applicable from 1 July 2026.

Module 1 asks: which data fields does it require, and how are they harmonised? Module 2 asks: which systems handle it — ICS2, AIS — and how do they interact? Module 3 asks: how is it risk-profiled, what triggers a flag, and who takes the release decision? Module 4 asks: does it trigger any non-customs formalities — health, safety, CITES — and how does CERTEX handle them? Module 5 asks: could AI or a Digital Product Passport have pre-cleared it before arrival? Module 6 maps the complete answer.

Follow the parcel and the day reads as one argument, not six talks.

Why now

Three facts have made this course unavoidable.

The old model is broken. Customs was built for a world of relatively few, large consignments accompanied by paper documents. More than twelve million low-value parcels arrive in the EU every single day. The document-based model cannot scale to billions of events. The only viable answer is to govern by data — captured early, shared once, and assessed automatically.

The reform has arrived. From the 2023 Commission proposal to the political agreement of March 2026, the EU has enacted the most ambitious customs reform in its history. The EU Customs Data Hub consolidates data into a single digital environment. The European Union Customs Authority builds, operates and governs it. A tailor-made e-commerce regime brings billions of parcels into scope. The deemed importer concept places obligations on platforms and sellers, not consumers.

The EU is not acting alone. The WCO’s 2025–2028 Strategic Plan puts technology, e-commerce and green customs first. The WTO Trade Facilitation Agreement has been binding since 2017. The WCO’s 2026 theme is plain: “Customs protecting society through vigilance and commitment.” Protection at this scale is only possible through data and advance information — exactly the capability the EU reform is building.

Module introductions

Introduction — Setting the sceneWalter Van der Meiren, Director Customs Brokerage, UPS Europe · Collaborateur, Faculté de Droit, Université de Liège

Before we open the machinery, one question for the whole day — and why the world has made it unavoidable. This opening session maps the pressure: why the document-based model has collapsed under the weight of e-commerce volumes, what the shift from paper to electronic to data-driven customs actually means, and how the EU Customs Reform fits inside a global movement led by the WCO and the WTO. It introduces the three ideas to track all day, the shared parcel scenario, and the architecture of the six sessions that follow.

Module 1 — The EU Customs Data ModelNoha Bayoumi, Senior Team Lead, Customs & Security — CHAMP Cargosystems

The common language that lets every customs system understand the same data — and the principle of submitting it only once. Without a harmonised data model there is no interoperability, no reuse, and no single submission. This module takes apart the EU CDM — its legal basis in the UCC, its roots in the WCO Data Model, its four-level hierarchy from business domain to individual data element, and the two annexes (A and B) where the data requirements are written down. It shows, through a worked Czech ENS and PNTS reporting flow, what single data submission looks like in practice. And it maps the ICS2 architecture — the Shared Trader Interface, the Common Repository, CCN2ng, AS4 access points — that makes the model operational.

The module answers Module 1’s share of the central question: what is the shared data, and how is it harmonised?

Module 2 — The UCC Work Programme and IT ArchitectureJérôme Lorig, Head of Product Regulatory Compliance — CHAMP Cargosystems

The law says go electronic. The Work Programme says: here is the build order. This module takes apart the eight core electronic systems that span the full customs lifecycle — ICS2, AIS, AES, NCTS Phase 6, CDS, BTI, PoUS and PNTS — and shows how they connect in a federated architecture governed jointly by DG TAXUD and the Member States.

ICS2 is the role model. Its four design choices — PLACI pre-loading security (born from the 2010 Yemen cargo plot), one canonical message grammar, the Shared Trader Interface, mandatory HS codes — are exactly what the rest of the landscape still lacks. The module is equally honest about the other half: the national patchwork of handling-related procedures, where 27 Member States still speak 27 different technical languages, and where the integration cost of the reform is concentrated.

The module answers Module 2’s share of the central question: where does the data live, and how does it flow?

Module 3 — The EU Customs Data HubWalter Van der Meiren, Director Customs Brokerage, UPS Europe · Collaborateur, Faculté de Droit, Université de Liège

The systems in Module 2 produce data. The Hub is where that data goes to become intelligence. This module shows how consolidated, event-based, line-item data is ingested by an event-driven microservices architecture, assessed by AI and machine learning, and turned into risk profiles, fraud detection and anomaly analytics at the scale of billions of items.

The Hub does not treat all operators equally. Five e-commerce business models attract five different levels of privilege — from the full Trust & Check operator authorised to take its own release decisions, to the non-IOSS operator subject to standard controls. Verified trust buys real operational advantage, and that incentive structure is how the reform is designed to work.

The IOSS Right-to-Use pilot is the Hub in miniature: transaction-level, event-based, identity-anchored, enforcement by data not inspection. The phased rollout runs from July 2028 (e-commerce Data Hub) through 2031 (all procedures) to 2034 (full transition). The module closes with the public/private tension that Module 5 will pick up from the commercial side: where should public AI infrastructure end, and what does algorithmic accountability actually require?

The module answers Module 3’s share of the central question: who learns from the data, and how?

Module 4 — The Customs and Trade Single WindowFrank Janssens, Senior Trade Facilitation Expert, World Bank · Vice-President, ODASCE · former Head of Unit, DG TAXUD

Customs is not the only authority with a say over goods at the border. Health, environment, agriculture, wildlife protection, fluorinated gases — every one of these non-customs regimes requires its own documentation, its own verification, its own competent authority. The EU Single Window Environment, built around the CERTEX central component, extends the single-submission principle beyond customs to every border authority at once. CERTEX automatically verifies the certificates those authorities require against the same trade data the Hub already holds.

This module maps what a Single Window actually is, how the EU builds one through CSW-CERTEX, and what implementing a national Single Window genuinely requires. It places the Single Window inside the broader governance architecture — alongside EUCA, the Data Hub and the nUCC provisions that make interoperability between customs and non-customs systems legally mandatory.

The module also confronts the green agenda at the border: CBAM, EUDR, forced-labour provenance rules and critical mineral licensing all demand end-to-end supply chain visibility, and all of them land at the same data infrastructure.

The module answers Module 4’s share of the central question: how does interoperability extend beyond customs to every authority that has a say over the goods?

Module 5 — AI, Altana and Emerging TechnologyScott Friedman, Vice President Government Affairs, Altana · former Head, Office of Trade and Economic Security, US Department of Homeland Security

Module 3 approached AI from the side of public governance: accountability, legal basis, data protection, who may see and act on the data. This module meets the same technology from the commercial side — and the contrast is the point.

Altana’s federated supply-chain intelligence network connects importers, logistics providers and government authorities across a shared product passport infrastructure. AI screens for forced labour (UFLPA), sanctions exposure, tariff and classification anomalies, export control flags and continuous multi-tier anomalies — without any central pooling of the underlying data. Each nation, each company, keeps sovereignty over its own information. The skeleton key is federated data plus AI: shared intelligence without shared risk.

The Altana Passport Manager is described as “Global Entry for goods” — a bridge from the private sector into customs, with a sovereign instance for every participating authority. The EU analogue is Trust & Check under Article 25 of the new UCC: verified predictive compliance earns operational privilege. Both approaches point the same direction, from different sides of the public/private line.

The module answers Module 5’s share of the central question: what can private innovation do that public infrastructure cannot, and where should the boundary between them lie?

Module 6 — Course Synthesis and OutlookFrank Heijmann, Customs Counsellor, Permanent Representation of the Netherlands to the EU · lead negotiator for the Netherlands on the new UCC · with all speakers and participants

This session is a conversation, not a lecture. Six structured discussion blocks — legal foundations, EUCA and governance, connecting the systems, AI and private innovation, cross-border data sharing, the future — bring together everything the day has produced. The shared parcel is traced end to end: every module’s contribution mapped onto one complete picture, from the first data element through risk scoring, Single Window clearance, AI pre-screening and final release decision.

Frank Heijmann brings 40 years of customs experience and the perspective of the Netherlands’ lead nUCC negotiator to a session designed to surface the integration points, the pain points and the opportunities that the reform creates — and to land on a shared answer to the question the day began with.

Participants leave with a written synthesis connecting six modules into one argument, a sector-specific briefing note on the nUCC transition timeline, and the ability to explain the digital transformation of EU customs to any audience.