What to Expect as an Importer or Exporter in 2027

2027 will be the year several major EU reforms move from "on paper" to real payments and real liability. From 1 February 2027, importers declaring CBAM goods (cement, steel, aluminium, fertilisers) will be able to buy CBAM certificates for the first time, and by 30 September 2027 they must submit their first annual CBAM declaration for 2026 imports. From 1 January 2027, the VAT "one-stop shop" (OSS) system is being expanded, and the new EU Customs Authority (EUCA) begins its first activities. For large and medium-sized companies from 30 December 2026, and for small companies from 30 June 2027, the EU Deforestation Regulation (EUDR) enters into force, relevant to coffee, cocoa, rubber, timber and soy supply chains. These changes require registrations, data sources and digital processes to be sorted out in advance — in this article we lay out exactly what an importer or exporter working with European, African and South American markets needs to do.

Why 2027 is a turning point for international trade

Usually regulatory changes arrive one at a time and are fairly easy to fold into everyday work. 2027 stands out because at least four separate but equally important reforms converge at one point: the EU customs union reform, the CBAM carbon border tax, the EU Deforestation Regulation (EUDR), and the ViDA VAT digitalisation package. All of them share a common thread — the European Commission wants more data about supply chains before goods even reach the border, and is increasingly shifting responsibility for accurate data onto importers, their representatives and platforms themselves, rather than solely onto carriers.

A second reason is that during 2025–2026 several of these reforms were postponed or simplified (especially EUDR and CBAM), which left many companies with the false impression that "everything has been pushed to later years" and no preparation is needed yet. In reality, some obligations (e.g. purchasing CBAM certificates, EUDR for large companies, ICS2 becoming fully operational) start right at the 2026–2027 turn, and delaying preparation means real financial and operational risk — from held-up shipments to extra charges calculated retroactively.

EU customs union reform: a new authority and the end of small-parcel exemptions

On 27 March 2026, the European Parliament and the Council reached agreement on the largest reform of the EU customs union since 1968. The reform creates a new EU Customs Authority (EUCA), based in Lille, France, which will begin part of its operations as early as 2027. The authority's role is to coordinate risk management, monitor online marketplaces, and gradually migrate customs IT infrastructure to a single shared EU Customs Data Hub.

Timeline for the EU Customs Data Hub

The Data Hub will not appear for everyone at once. The EU Customs Data Hub will become operational for e-commerce shipments from 2028, available on a voluntary basis for other businesses from 2031–2032, and mandatory for all importers only in the 2034–2038 period, depending on the outcome of a review. This means the major technical integration for companies like Profmaris (maritime freight forwarders) still lies ahead, but 2027 is the year the authority starts taking shape, implementing acts are drafted, and requirements for trusted traders are refined.

"Trust and Check" traders

The reform introduces a new trusted-trader category — "Trust and Check" — which will sit alongside the existing Authorised Economic Operator (AEO) scheme. For companies that disclose their entire supply chain and give customs access to real-time data, shipments will be able to be released into free circulation with practically no active customs intervention. For logistics and forwarding companies working with regular importers/exporters to Africa and South America, it's worth assessing now whether client flows already meet the future "Trust and Check" criteria — this could become a competitive advantage in 2028–2032.

The end of the small-parcel era

The most practical change for many companies is the removal of the small-parcel customs duty exemption and de minimis threshold. From 1 July 2026 until 2028, a fixed duty of EUR 3 per product category applies to shipments valued up to EUR 150, after which this temporary measure will be replaced by standard tariff classification — duties will be calculated from the very first euro, with no exemption. At the same time, online marketplaces (platforms) become "deemed importers" and are responsible for collecting duties and VAT at the point of purchase, rather than leaving this to the consumer or carrier. This change also directly affects logistics providers handling e-commerce shipments from Asia or other regions — the volume of documentation and declarations will grow, and shipments containing inaccurately declared product categories will face stricter checks.

CBAM: the carbon border tax becomes a financial reality

CBAM (Carbon Border Adjustment Mechanism) is an EU charge that adjusts the price of imported goods — cement, iron and steel, aluminium, fertilisers, electricity and hydrogen — based on the CO2 embedded in them, to prevent production from "leaking" outside the EU. The definitive CBAM phase began on 1 January 2026, but financial obligations only arise in 2027.

CBAM 2027 timeline

An important relief measure for smaller importers — a CBAM simplification regulation adopted in October 2025 established a single 50-tonnes-per-year exemption threshold (replacing the earlier EUR 150 shipment-value threshold). Importers whose total annual import of CBAM goods (cement, iron, steel, aluminium and fertilisers) does not exceed 50 tonnes are fully exempt from CBAM obligations — relevant for Profmaris clients importing smaller batches of steel structures or equipment as part of oversized cargo shipments.

The practical risk lies not in the charge itself but in data quality. If an importer cannot obtain verified actual emissions data from the manufacturer, conservative default values apply, which are typically higher than real figures. Companies importing steel structures, aluminium profiles or fertilisers from Africa, South America or Asia should therefore start collecting supplier emissions data now, rather than waiting for the September 2027 deadline.

EUDR: deforestation regulation deadlines are approaching

The EU Deforestation Regulation (EUDR) requires companies to prove that goods imported into or exported from the EU — cattle, cocoa, coffee, palm oil, rubber, soy and timber, along with derived products (e.g. leather, chocolate, paper) — are not linked to deforestation that occurred after 31 December 2020. The regulation has already been postponed twice, so the latest, legally confirmed timeline (Regulation (EU) 2025/2650, published on 23 December 2025) is as follows:

EUDR entry-into-force deadlines

Alongside the postponement, the obligations themselves were also simplified: a full Due Diligence Statement (DDS) with precise geographic coordinates now only needs to be submitted by the first operator placing a product on the EU market — subsequent traders and resellers no longer need to submit a separate statement, only keep records for inspections. Small primary producers in low-risk countries are allowed to state a postal code instead of exact coordinates.

Profmaris' niche — African and South American routes — intersects directly with EUDR: coffee (Colombia, Brazil, Ethiopia, Uganda), cocoa (West Africa), rubber and timber are classic EUDR commodities. Companies importing these goods or their derivatives should contact suppliers about geolocation data now, rather than leaving it to the last week before the 2026–2027 deadline, when systems will be overloaded with applications.

VAT digitalisation: the ViDA reform and OSS expansion

ViDA (VAT in the Digital Age) is an EU VAT system modernisation package aimed at reducing VAT fraud through e-invoicing and real-time data reporting, and simplifying VAT registration for cross-border trade. The package entered into force on 14 April 2025, but its specific deadlines run all the way to 2035.

ViDA implementation stages relevant for 2027–2028

For Lithuanian businesses, the key point is that mandatory e-invoicing for cross-border B2B trade across the EU only enters into force from 1 July 2030, but several EU countries (Poland, France, Belgium, and later Germany) are introducing national e-invoicing requirements much earlier. Companies trading with partners in these countries should start digitalising their invoicing flows already in 2026–2027, so the transition to the common EU standard in 2030 isn't abrupt.

ICS2: security data before cargo reaches the EU border

ICS2 (Import Control System 2) is the EU's advance cargo information system, under which all economic operators — carriers, forwarders, importers — must submit security data (an Entry Summary Declaration, ENS) about every shipment before it arrives in the EU, Norway or Switzerland. The system has been rolled out in phases since 2021, and on 3 February 2026 it became mandatory for all modes of transport — sea, air, road and rail.

The final transition period ends on 1 June 2026, when five EU countries (Croatia, Latvia, Poland, Romania and Slovakia) stop using the old ICS1 system for road transport. From that date, any carrier or forwarder shipping goods to these markets with data that doesn't match the ICS2 v3 format will have their declaration rejected, and the shipment may be held at the border. By the end of 2026, multiple filing is also expected to be introduced, allowing the carrier, forwarder and trader to each submit part of the ENS data — this should ease the burden on maritime forwarding companies that currently depend on the carrier providing complete data.

For forwarders working with container shipping and oversized cargo (e.g. RoRo routes from Klaipėda), the practical recommendation is to check that all HS codes for shipped goods meet at least 6-digit precision and that product descriptions don't use prohibited generic terms (stop words), the updated list of which is published on the EU CIRCABC platform.

Practical checklist for 2027

Summarising all the changes, we recommend the following action list for importers and exporters:

• Check and, if needed, renew your EORI number and customs representation agreements.
• Assess whether imported goods (steel, aluminium, cement, fertilisers) fall under CBAM, and if so, apply for authorised CBAM declarant status.
• Map your supply chain for EUDR commodities (coffee, cocoa, rubber, timber, soy, cattle) and start collecting geolocation data from suppliers.
• Review your VAT registration needs in other EU countries, especially if selling through platforms or engaged in distance selling.
• Work with your forwarder to check that all ENS/ICS2 data (HS codes, sender/receiver information) is submitted accurately and on time.
• Assess whether your company could qualify for AEO or the future "Trust and Check" status.
• If selling low-value goods into the EU via online stores, recalculate pricing to account for the removal of the duty-free threshold from the first euro.
• Start digitalising your invoicing processes so your company is ready for ViDA e-invoicing requirements by 2030.

Common mistakes to avoid

• Assuming CBAM has been "postponed" — in reality only the purchase of certificates has been delayed, not the emissions accounting obligation itself, which has applied since January 2026.
• Leaving EUDR data collection until the last minute — gathering suppliers' geolocation data from a dozen or more countries can take months.
• Continuing to price based on the old EUR 150 de minimis threshold, which will no longer apply to e-commerce shipments.
• Failing to update product descriptions and HS codes in forwarding systems — this is the most common cause of ICS2 declaration rejections.
• Relying solely on default CBAM emission values, when real data from the supplier could significantly reduce the amount payable.

Summary: the 2026–2028 roadmap

Conclusion

2027 will not be the year of one single major reform — it will be the year several separate initiatives (customs reform, CBAM, EUDR, ViDA, ICS2) move from the preparatory stage into real enforcement, all at once. For companies importing or exporting goods to and from Africa, South America or other third countries, the priority in the second half of 2026 and early 2027 is to get their supply chain, emissions and product origin data in order — rather than waiting until the obligations become mandatory. Companies that invest in data quality and digital processes now will have a real advantage over competitors who delay adapting until the last minute.

Frequently Asked Questions (FAQ)

When will companies first need to pay the CBAM charge in 2027?

CBAM certificates can be purchased from 1 February 2027, and the first annual declaration along with certificate surrender for 2026 imports is due by 30 September 2027.

Does EUDR apply to small companies in 2027?

Yes. For micro and small companies (up to 50 employees, turnover up to EUR 10 million from related goods), EUDR requirements take effect from 30 June 2027, while for large and medium-sized companies they already apply from 30 December 2026.

Does the EUR 150 duty-free threshold for small shipments still apply from 2027?

Not entirely. From 1 July 2026 until 2028, a temporary fixed duty of EUR 3 per product category applies to shipments up to EUR 150, after which this threshold will be fully removed and duties calculated from the first euro.

What is the EU Customs Authority and when does it start operating?

The EU Customs Authority (EUCA) is a new EU agency, based in Lille, France, that will coordinate customs risk management across all 27 EU countries. Part of its operations begin in 2027, while the fully operational system with the Customs Data Hub will be rolled out gradually through 2034–2038.

Is ICS2 already mandatory for all modes of transport?

Yes, since 3 February 2026, ICS2 version 3 has been mandatory for sea, air, road and rail transport across all EU countries, and five countries (Croatia, Latvia, Poland, Romania, Slovakia) are completing the transition from the old ICS1 system for road transport by 1 June 2026.

When will B2B e-invoicing become mandatory across the entire EU?

Mandatory e-invoicing and digital reporting for cross-border B2B transactions across the EU takes effect from 1 July 2030, though the first OSS/IOSS-related adjustments already take effect from 1 January 2027.

Does EUDR apply to Lithuanian companies importing timber or coffee from third countries?

Yes. Any EU-established company that is the first to place EUDR goods — timber, coffee, cocoa, rubber, soy or cattle products — on the EU market must submit a due diligence statement including geographic data on the product's origin.

How can I prepare for CBAM if my supplier doesn't provide emissions data?

If verified actual data cannot be obtained, the European Commission's default values apply automatically, but these are typically higher and can significantly increase the cost of CBAM certificates — so it's worth agreeing on data provision with your supplier in advance.

Note: several dates in this article (particularly the EUDR and ViDA stages) have been changed more than once over the past few years — before making decisions, we recommend checking current information on the official European Commission pages.