Since Brexit, customs clearance for the movement of goods between Ireland, the UK and EU has been constantly evolving, with further changes planned for next year. The challenge for those involved in trade between these markets is the time and effort needed to keep pace with shifting requirements. This is made worse by deadlines being constantly revised and pushed back, both in the UK and EU, which has led to considerable uncertainty within the international freight sector.
Many road transport operators are still constrained by paper-based systems or are leaving preparations for incoming changes until the last minute. A certain amount of complacency has also crept in because there had been some leeway, especially for checks for goods coming into the UK, meaning it was possible to make mistakes and keep things moving.
Moving forward, greater levels of digitisation, automation and electronic reporting will be crucial to avoid severe consequences in terms of added costs, delays and operational risk. Businesses involved in the international movement of goods will need to move away from manual and paper dependencies, while also investing in data integrity, internal compliance systems and audit reporting.
As well as the delayed introduction of the EU’s Import Control System 2 (ICS2) Phase 3 and France’s Enveloppe Logistique Obligatoire (ELO), now both planned for early 2026, there will be a host of other customs changes that freight operators will need to consider and prepare for. This means the margin for error to ensure goods are not delayed or refused entry at EU or UK borders is rapidly shrinking, while at the same time the threat of stricter fines and penalties grows.
In the UK, companies will be granted free, self-service access to their customs declaration data from March 2026, the same information HMRC looks at. The shift means expectations on internal compliance and data integrity will rise, with organisations held accountable to spot errors proactively, so it will be crucial to have clean, auditable customs systems.
Under recently published UK statutory amendments (Customs Miscellaneous Amendments 2025), there are also several forthcoming changes to how declarations, temporary admissions, and oral / “by conduct” declarations operate. Additionally, the HMRC 2025–26 transformation roadmap signals further automation, digitalisation, and a push toward transparency and predictive compliance.
Meanwhile, France will abolish limited/ad hoc fiscal representation under Regime 42 for non-EU businesses. This is one of the more painful ones for UK companies currently relying on fiscal representation shortcuts as a full VAT registration and full tax compliance obligations will now be needed. Moreover, some other EU jurisdictions may follow or impose similar stricter rules on non-EU sellers relying on representation or simplified regimes.
While not strictly customs-related, the rollout of the EU’s Entry / Exit System (EES) & biometric checks is planned to be fully operational by mid-April, so operators can expect stricter identity and travel scrutiny. Delays at border crossings are also a real risk, especially in peak periods, so throughput, queuing and border infrastructure will be under added stress. It will therefore be important to build buffer time into any schedules as well as validate that drivers and staff are EES-compliant.
There are also longer-term changes in the pipeline that will need systems to provide real-time chain-of-custody, risk metrics, and data transparency. The EU is driving a customs reform that introduces a single EU Customs Data Hub and a new EU Customs Authority. The vision is for data to be submitted once into a unified environment, so risk analysis is undertaken by the customs authorities and clearance is based on trust and classification, with minimal intervention on low-risk flows. Over time, “trusted” traders may benefit from near-automatic clearances with limited active customs checks.
There is a growing realisation that international freight businesses will need to adapt to survive, with those failing to do so facing significant risk. Many processes that work today may be insufficient in 2026 and beyond, so some operators may be in for a shock over the next 12 months. Keeping on top of the proposed UK and EU changes will be key to avoiding disruption, while maintaining competitiveness.