International trade and customs FAQs.
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EUDR FAQs
The EUDR has officially been passed and is in force since 29 June 2023. However, from 30 December 2025 any party exporting these goods to or from the European market must be able to prove that they do not come from a deforested area or are related to deforestation in any form. Meaning you have EUDR obligations from then on.
Extension of original implementation date
The obligations under the EUDR were originally supposed to come into effect by 30 December 2024 for large businesses and 30 June 2025 for micro and small businesses.
In response to requests from global partners, the European Commission had proposed an additional 12 months as a phased implementation period for the EUDR. This was approved by the European Parliament on 14 November 2024.
Despite this delay, we advise businesses to start preparing now. The IT system for registering due diligence statements is expected to be operational by December 2024.
No, there will be no transitional phase for the EUDR.
The EUDR applies specifically to products containing the following raw materials:
- Cattle
- Cocoa
- Coffee
- Oil palm
- Rubber
- Soy
- Wood
Annex I in Regulation (EU) 2023/1115 specifies the commodity codes of the relevant commodities and products. The area from which the goods originate is irrelevant here.
Relevant commodities and relevant products may not be placed or made available on the market or exported, unless all the following conditions are fulfilled:
- They are deforestation-free
- They have been produced in accordance with the relevant legislation of the country of production
- They are covered by a due diligence statement
As defined in Article 2(15) of the Regulation, an operator is a natural or legal person who places relevant products on the market (including through imports) or exports them in the course of commercial activity.
Operators must provide a due diligence statement with the regulated products listed above. Once the declaration is signed, the operator confirms that it has exercised due diligence. Due diligence includes the following:
- The collection of necessary information, data and documents
- Risk assessment measures
- Risk mitigation measures
Operators must provide the required information that shows compliance with the listed goods. This means that if a product, which falls under one of the categories listed above, is imported or exported, it must be accompanied by an indication of:
- Whether the product is deforestation-free
- Whether the product was produced in accordance with the relevant legislation of the country of production
- That the product is accompanied by a relevant due diligence statement
This information must be available for five years from the date of placing the goods on the market. The information must include a comprehensive product description, indicating the relevant raw materials used to manufacture the product. Other information requirements can be found in Article 9 of Regulation (EU) 2023/1115.
Operators carry out a risk assessment to verify the compliance of their products with the requirements of the EUDR. Products may only be placed on the market or exported if there is no or only a negligible risk of non-compliance of the relevant products. A comprehensive list of criteria can be found in Article 10 of Regulation (EU) 2023/1115.
If there is a risk of non-compliance, economic operators suggest applying risk mitigation procedures to the product. In this way, the risk is reduced.
The risk mitigation measures may include:
- Requiring additional information, data or documents
- Carrying out independent surveys or audits
- Taking other measures pertaining to information requirements
The regulation is set up to combat deforestation. Other objectives of the rules include: preventing products bought or used by Europeans from contributing to deforestation, reducing carbon emissions for at least 32 million tonnes a year and mapping all deforestation caused by farmland.
- EUR-Lex: Regulation (EU) 2023/1115
- News article: EU Deforestation Regulation (EUDR).
Our friendly team of customs experts is here to help. Give us a call to speak to someone immediately, or kindly fill out the contact form above and a member of our team will respond within one business day.
CBAM FAQs
CBAM is the abbreviation for Carbon Border Adjustment Mechanism. It is a legal mechanism for carbon adjustment at the border, that aims to achieve a CO2 correction by introducing an additional tax on goods imported into the European Union. In this way, the system ultimately ensures fair competition between EU companies and companies from outside the EU in terms of CO2 emissions.
The EU CBAM applies to goods that fall into the categories: iron and steel, cement, fertilizers, aluminium, electricity, and hydrogen. Whether a product falls under the EU CBAM depends on the CN code of the product. The relevant CN codes are listed in Annex I of Regulation (EU) 2023/956.
Yes, there is a transitional phase for CBAM. This phase has started on 1 October 2023 and will run until 31 December 2025. Since this transitional phase reporting obligations are in effect.
The EU CBAM has officially been passed and is in force at present. However, the permanent CBAM system enters into force on 1 January 2026, meaning you will start paying financial levies from then on.
The following dates are key dates in the EU CBAM timeline:
- 31 October 2023: The first reporting period for EU CBAM emissions begins.
- 31 January 2024: Deadline for filing the first EU CBAM report on emissions from the previous reporting period.
- 30 April 2024: Deadline for the first quarterly declaration of 2024.
- 31 December 2024: End of the first reporting period under the transitional phase of EU CBAM.
- 1 January 2025: Start of the second reporting period under the transitional phase of EU CBAM.
- 30 June 2025: Deadline for the second quarterly declaration of emissions for 2025.
- 1 January 2026: The permanent EU CBAM system enters into force, requiring importers to buy CBAM certificates to compensate for the CO2 emissions of their imports.
- 31 January 2026: From this date, you must be registered and authorised as a 'CBAM declarer' to import goods to the EU.
- 1 January 2030: The CBAM coverage will be reviewed and possibly expanded, with the aim of including more than half of emissions in the EU ETS sectors by the full phase-in of CBAM in 2034.
Importers who import goods into the EU covered by CBAM are expected to:
- Report and submit emissions from their imports
- Purchase CBAM certificates by 1 January 2026 to offset CO2 emissions from their products
- Register with the CBAM Transitional Registry
- Be compliant in complying with CBAM requirements
- Work with their suppliers to reduce emissions from their imports
Make sure you know which of your products are covered by CBAM and what emission factors apply to them. Based on this, determine your CBAM obligations and develop a compliance strategy for calculating emissions, buying CBAM certificates and a way to manage your CBAM obligations. In addition, you need to register to the CBAM Transitional Registry. We recommend preparing as early as possible and getting the necessary information from your suppliers in time to ensure so you can continue to trade smoothly. If you would like expert guidance on the CBAM, you can contact us by filling out the contact form below or give us a call directly. Our customs experts are happy to help.
Click here to enter the CBAM Transitional Registry developed by the EU Commission. Access to this registry should be requested through the National Competent Authority (NCA) of the Member State in which the importer is established.
A list of National Competent Authorities for the Carbon Border Adjustment Mechanism can be found here.
To complete your CBAM report you will need identification documents, documents related to the imported goods, a calculation of the CBAM levies and if applicable a proof of payment.
The UK is also implementing a CBAM which is a separate mechanism but similar to the EU CBAM. Click here for a UK Carbon Border Adjustment Mechanism factsheet from the UK Government.
Our friendly team of customs experts is here to help. Give us a call to speak to someone immediately, or kindly fill out the contact form above and a member of our team will respond within one business day.
Academy FAQs
Absolutely. We offer face-to-face in-house and remote training sessions to our valued customers.
The vast majority of training courses last for half a day, However, this depends on the topic(s) and your needs and knowledge level.
Control Tower FAQs
No, you will receive a dedicated Account Manager and Customer Service Representative who will support you with all operational matters and new queries.
Yes, we can consolidate invoices over any desired timescale and/or group geographical regions together to make for a cleaner administrative process.
Yes, we can provide invoices in EUR, GBP or USD.
We offer various visibility tools, ranging from manually populated status sheets to digital dashboards.
As a full-service customs partner, we offer a wide variety of customs products and services. This includes import and export clearances, transit documents, consultancy and advisory services, reporting, and fiscal representation.
Yes, we have standard models of integration and an IT team that can create bespoke solutions should you need them.
Yes. We understand that best serving your customers often involves the odd shipment into new regions, and we offer support with ad hoc clearances to our existing customers.
Consultancy & Advisory FAQs
We will conduct an in-depth review of your current operations against the licence requirements, identify any gaps and recommend solutions to ensure and maintain compliance.
There are several criteria required for AEO authorisation, including compliance history, sufficient financial solvency, excellent record-keeping, documented security and safety standards, exceptional customs knowledge, and procedural controls.
We provide gap analysis and remediation advice to ensure your successful authorisation.
There are several criteria required for bonded customs warehouse authorisation, including documented security protocols, controlled access and CCTV, approved storage facilities, detailed inventory management and record-keeping procedures, trained staff, proven financial solvency, and customs compliance history.
Our team will help you meet all of the criteria.
Customs Warehousing FAQs
A customs bonded warehouse is a secure facility where imported goods can be stored without immediate payment of duties or taxes. Duties are only paid when goods leave the warehouse for domestic use. If the goods are re-exported, these charges are waived.
Goods can typically be stored in a bonded warehouse for an indefinite period, however this is dependent on your specific country's regulations. This period allows businesses to manage inventory and cash flow effectively, by delaying duty and VAT payments until goods are distributed domestically.
Businesses must meet several criteria for bonded warehouse authorisation. This includes documented security protocols, controlled access and CCTV, approved storage facilities, detailed inventory management and record-keeping procedures, proven financial solvency and a history of customs compliance.
Fiscal Representation FAQs
A fiscal representative is typically required for businesses that are involved in taxable transactions in a country where they do not have a physical presence. This is often the case for companies engaged in cross-border trade within the EU, especially for VAT purposes. Non-EU businesses selling goods or services to EU customers, or involved in import/export activities within the EU, frequently need a fiscal representative to comply with local tax regulations, facilitate VAT registration, and handle tax declarations.
A fiscal representative acts as a liaison between a non-resident business and the local tax authorities. They handle the administrative and compliance aspects of tax regulations on behalf of the company. This includes registering the business for VAT, filing VAT returns, ensuring accurate tax payments, and communicating with tax authorities.
Limited fiscal representation is typically used for specific transactions, like importation, and is available in certain countries. Under this arrangement, the fiscal representative is responsible for VAT obligations related to imports but not for other domestic transactions.
General fiscal representation, on the other hand, covers a broader scope. It includes managing all VAT-related matters for a non-resident business, including imports, sales, and other taxable transactions within the country. General representation is more comprehensive, making it suitable for businesses with extensive operations in a particular country.
Excise Consumption FAQs
Excise duty is typically paid when a specific type of goods, often referred to as excisable goods, are manufactured, imported from the rest of the world or other member states, or sometimes sold. Common examples of such goods include alcohol, tobacco, and fuel. The duty is due at the time of production or importation, but the exact point of payment can vary depending on the country's regulations and the ability of your customs representative.
You are eligible for an Electronic Administrative Document (eAD) when you are involved in the movement of excisable goods under duty suspension within the European Union. The eAD is required for tracking the movement of these goods, ensuring that excise duty is correctly accounted for and paid.
Excise tax is a specific tax levied on certain goods, such as alcohol, tobacco, and fuel, which the merchant is usually responsible for paying. It's charged per unit (like per litre of alcohol) and is often aimed at discouraging the use of certain products. Sales tax, on the other hand, is a general tax applied to the sale of most goods and services and is calculated as a percentage of the sale price. Unlike excise tax, sales tax is not product-specific and is usually visible to consumers at the point of purchase.
Transit Declarations FAQs
A T1 transit document is an EU customs procedure that can be used between the EU and Common Transit countries, which includes the UK. The document allows the movement of uncleared goods across international borders whilst delaying the need to pay for duties and submit customs declarations until they arrive at their final destination or are re-exported. This document also ensures that while the goods are in transit, they are under customs control.
A T2 transit document is used within the European Union for the transit of goods that are in free circulation within the EU. This means the goods have either been produced in the EU or have been imported and all relevant customs duties and taxes have been paid. The T2 document facilitates the movement of these goods travelling via countries that are not part of the EU customs territory, such as Switzerland or Norway.
Export Declarations FAQs
An EORI (Economic Operators Registration and Identification) number is required for all businesses importing or exporting goods in the UK or the EU. For the UK, you must have a GB EORI, and for Norway, you'll require a Norwegian Organisation Number instead. These are used by customs to identify traders and ensure compliance with customs procedures and regulations.
A commercial invoice is the document provided by the exporter to the importer to pay for the goods sold. It details the goods, their value, key transaction information, including the Incoterms® and, in some cases, proof of origin.
An ATA Carnet is an international customs document that allows the temporary importation of goods into another ATA Convention country, without paying duties and import taxes. However, these goods must return to their original country. An ATA Carnet is often used for goods such as professional equipment, or items for exhibitions and events.
Goods that typically require an export licence include military items, dual-use goods, artworks, and endangered species. The best licence depends on the item's nature, destination, and end-use.
The commodity code for your products depends on their nature, intended use and specifications. It's essential for customs declarations and determining duties. If in doubt, consult a member of our team.
Yes, as a full-service partner, and if your shipment is applicable, we can apply for an EUR1 certificate on your behalf. This certificate will help you in claiming preferential duty rates under trade agreements between the EU and certain other countries.
EXW (Ex Works) is an Incoterm where the seller makes the goods available at their premises. The buyer is responsible for all transportation costs, risks, and customs procedures from the seller's location onwards.
Import Declarations FAQs
To import goods into the UK or the EU, it's essential you have an EORI (Economic Operators Registration and Identification) number, along with the commercial paperwork. For UK shipments, you must have a GB EORI. For Norway, you`ll require a Norwegian Organisation Number instead.
You can get an EORI number by applying through your country's official customs website or by using a trade partner like Gaston Schul to support you.
You can register your business by visiting The Brønnøysund Register Centre website.
To register for the Customs Declaration Service (CDS), visit the HMRC website and follow the registration process. You'll need your EORI number, Government Gateway ID, and relevant business details to complete the registration.
For your customs declaration, you`ll need a commercial invoice detailing the transaction, Incoterms®, and goods. You`ll also require a packing list, the correct commodity (HS) code(s), plus any preference certificates or statements relating to your shipment such as an EUR1, REX Statement or invoice declaration. These documents are crucial for customs to assess duties and taxes.
PVA (Postponed VAT Accounting) can be used by VAT-registered businesses in the UK to account for import VAT on their VAT return, rather than paying upfront at the border. It's beneficial for cash flow.
You can claim preference or duty relief if your goods qualify under trade agreements or specific relief programs. To do this, simply provide your proof of origin, such as an EUR1 certificate, REX statement, or invoice declaration, when submitting your commercial paperwork to our team.
Incoterms® define the responsibilities between the buyers and sellers of international shipments, including who pays for shipping, insurance, and customs duties. Your chosen Incoterm (e.g., FOB, CIF, EXW) can significantly impact cost, responsibility, and your customs value, which determines the amount of duty you pay.