Trade & Customs Watch is our weekly briefing on the customs, tariff and trade-regulatory developments that matter to businesses moving goods across borders and to the administrations that control them. Each item is drawn from the primary record and linked to it, with a short note on what it means in practice.
The week in brief
The European Union’s new Union Customs Code is now on the statute book as Regulation (EU) 2026/2108, published in the Official Journal on 19 September, which turns last week’s political agreement into a fixed, dated timetable running from a parcel handling fee this November to a mandatory EU Customs Data Hub in 2034. The Commission also moved the carbon border adjustment mechanism from law into operation, publishing the guidance, registry-access procedure and manuals that accredited verifiers will work from, and separately reported that the 50-tonne de minimis threshold exempts 0.87 per cent of embedded emissions against a statutory ceiling of 1 per cent. In the United Kingdom, substantially expanded sectoral sanctions on Iran entered into force on 29 September, reaching shipping, insurance, finance, energy and a new set of controlled-goods schedules. Among administrations, the Nigeria Customs Service opened a nationwide integrity perception survey with the World Customs Organization, and a pre-feasibility study for the Busia, Malaba and Lwakhakha border posts on the Northern Corridor was published, recommending a risk-based, technology-led corridor model over further physical expansion.
European Union: the new Union Customs Code is published, and the timetable is now fixed
Official Journal of the European Union, 19 September 2026. Regulation (EU) 2026/2108 of the European Parliament and of the Council, establishing the Union Customs Code and the European Union Customs Authority and repealing Regulation (EU) No 952/2013, was published in the Official Journal on 19 September. The Commission’s EU customs reform page sets out the phased implementation that follows: a Union handling fee on goods imported into the EU is to be introduced by 1 November 2026, with the amount set by delegated act; the EU Customs Authority is to be established in 2027, with some activities starting that year; e-commerce operators gain access to the EU Customs Data Hub in 2028; other businesses may use the Data Hub voluntarily from 2031; and its use becomes mandatory for all businesses importing into the EU in 2034. The same page records the temporary €3 customs duty per item applied to low-value consignments from 1 July 2026, following the removal of the €150 duty exemption.
What it means. Until now, the reform could only be described in terms of proposals and political agreement; it can now be cited by regulation number, and the dates above are legal milestones rather than estimates. For importers and their intermediaries, the practical sequence is clear: the low-value parcel measures bite first, the institutional change comes next, and the migration from declarations lodged in twenty-seven national systems to data supplied to a single Union hub is a decade-long transition that will be driven by delegated and implementing acts still to come. Businesses should treat 2028 and 2034 as the outer limits, not the planning dates, since the regulation also allows voluntary early use and the Commission has every incentive to encourage it. For administrations outside the EU that are designing single-window or customs-management replacements, the regulation is the most detailed legal blueprint yet published for a data-centric, declaration-free model, and it is now stable enough to be used as a comparator.
European Commission: operational resources for CBAM verifiers
European Commission, Directorate-General for Taxation and Customs Union, 28 September 2026. The Commission published a set of resources for CBAM verifiers: verification and accreditation guidance focused on verifiers who will check emissions reports from operators of installations outside the EU producing CBAM goods imported from 1 January 2026, together with the rules for national accreditation bodies; a procedure describing how verifiers obtain access to the CBAM Registry from 1 September 2026, setting out the roles of verifiers, accreditation bodies, the Commission and national competent authorities; three user documents for the Registry portal; and three training videos covering the registered-verifier application, change requests and collaboration with third-country installation operators.
What it means. The definitive CBAM regime now has working infrastructure, not only a legal text. Importers of covered goods should note two consequences. First, verifier access to the Registry is already open, so the question to ask suppliers is no longer whether their installation will be verified but by whom, and whether that verifier is accredited and registered. Second, the Commission has published the verifier’s own rulebook, which means importers and their non-EU suppliers can see in advance what a verifier will test and prepare the emissions data accordingly. For administrations building comparable verification or registry functions, the sequencing is instructive: the operational plumbing has been opened ahead of full enforcement, as a distinct workstream from the legislation.
European Commission: the CBAM de minimis threshold assessed
European Commission, Directorate-General for Taxation and Customs Union, 30 September 2026. The Commission published its assessment of the CBAM de minimis threshold, required under Article 2a(3) of the CBAM Regulation. For the period from 1 April 2025 to 31 March 2026, the 50-tonne single mass-based threshold would exempt 0.87 per cent of embedded emissions, which remains below the 1 per cent limit. The Commission must repeat the assessment annually and may amend the threshold by delegated act where the calculation deviates by more than 15 tonnes from the current level.
What it means. The threshold stands, but the margin is thin. Importers who have organised their flows so that annual volumes of covered goods sit under 50 tonnes should recognise that the exemption is a parameter the Commission is legally obliged to recalculate every year, and that a shift of less than 0.13 percentage points in the data would trigger the power to tighten it. The exemption is a compliance fact for this year, not a stable structural feature on which to build a sourcing strategy. The sensible course is to keep the records and the emissions data that would be required if the threshold fell, so that a change in the delegated act becomes a reporting task rather than a scramble.
United Kingdom: expanded Iran sanctions in force from 29 September
Department for Business and Trade, Foreign, Commonwealth and Development Office and Office of Trade Sanctions Implementation, Notice to Exporters 2026/18, published 8 September 2026. The notice records that the Iran (Sanctions) (Amendment) Regulations 2026, made on 7 September and in force from 29 September 2026, amend the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 and the Iran (Sanctions) Regulations 2023. The measures introduce new financial, trade and transport restrictions and a set of new schedules (1A to 1I) of controlled goods and technology, covering energy-related goods, gold, precious metals and diamonds, maritime goods, natural gas, oil and petroleum products, petrochemicals, sectoral software and technology, and nuclear-related items. The trade prohibitions extend beyond export to supply and delivery, including third-country trade, transfers of technology, making goods and technology available, and associated ancillary services. The regulations also provide for the specification of ships, port-entry and registration restrictions, prohibitions on aircraft landings, restrictions on UK credit institutions’ dealings with Iranian banks, a prohibition on insurance and reinsurance for Iranian-connected persons save in humanitarian cases, and a ban on the import of oil, petroleum products, natural gas, petrochemicals and gold from Iran.
What it means. This is a change of regime rather than an incremental listing. Businesses whose screening is built around designated persons will miss most of it, because the new restrictions attach to goods, sectors and activities. Exporters, freight forwarders and traders should map the new schedules against their product range, remembering that the prohibitions capture third-country supply and brokering, not only shipments leaving the United Kingdom. Shipping, marine insurance and trade-finance providers face sector-wide prohibitions that require a review of existing contracts and cover. Where a transaction touches any of these sectors and has an Iranian connection, the only safe assumptions from 29 September are that it is prohibited unless licensed and that the notice directs enquiries to the Office of Trade Sanctions Implementation and the Office of Financial Sanctions Implementation.
Nigeria Customs Service: nationwide integrity perception survey opened with the WCO
Nigeria Customs Service, NCBN News, 30 September 2026. The Service’s broadcasting outlet reported the launch on 28 September of the Customs Integrity Perception Survey, a joint initiative of the Nigeria Customs Service and the World Customs Organization that gathers anonymous feedback from officers and from external stakeholders, including licensed customs agents, importers, exporters, warehouse operators and transporters, on integrity, transparency and operations. Officers receive the survey through official email; external participants access it through QR codes or links with one-time passwords distributed by the Service’s public relations unit, with zonal coordinators mobilising participation.
What it means. Integrity perception surveys are the diagnostic instrument of the WCO’s integrity programme, and the point of them is the gap between how an administration sees itself and how the trade sees it. The findings are rarely published; what becomes visible over time is whether the resulting action plan changes behaviour at the border. Traders operating in Nigeria have a direct interest in responding, since this is one of the few structured channels through which clearance experience reaches the Service’s leadership in a form the Service has said it will use. Administrations elsewhere that are contemplating an integrity programme should note the design: an externally supported methodology, anonymity for respondents, and a stakeholder sample that goes beyond brokers to the warehouse and transport operators who see the border every day.
Northern Corridor: a pre-feasibility study for Busia, Malaba and Lwakhakha
TradeMark Africa, July 2026 (published September 2026). The Northern Corridor Strategy Pre-Feasibility Report, prepared by CRISIL for TradeMark Africa through Trade Catalyst Africa, records 2025 daily truck volumes of 1,824 at Malaba, 1,061 at Busia and 431 at Lwakhakha, with average processing times of around five hours at Malaba and three and a half hours at Busia, extending to seven to ten hours at peak periods. It recommends moving from a conventional infrastructure-led approach to a technology-enabled, risk-based border management framework across the three posts, financed through a blended structure of grants, long-term development-finance debt, private equity and user fees, and records a willingness to pay of USD 20 to 50 per truck crossing where measurable improvements in border performance are achieved. A joint meeting of the Commissioners General of the Kenya Revenue Authority and the Uganda Revenue Authority on 24 March 2026 endorsed proceeding to the feasibility stage on the integrated approach.
What it means. The conclusion that matters is the one about sequencing: the study puts corridor-wide risk management, scheduling and digital processing ahead of new physical capacity, which reverses the usual order of border-post investment. For the administrations concerned, the endorsement at Commissioner General level means the next stage will test whether the two revenue authorities can operate joint risk and scheduling rules, not only shared buildings. For operators on the corridor, a performance-linked user fee is now on the table, and the credibility of that model will rest on whether time savings can be measured independently and consistently at each post. The study is a pre-feasibility document, and its figures should be read as a baseline for the next stage rather than as commitments.
Trade & Customs Watch is compiled from primary sources: HMRC, the Department for Business and Trade, the European Commission’s Directorate-General for Taxation and Customs Union, the World Customs Organization and national customs administrations. Items are summarised; the linked record is authoritative. Commentary is our own and is general in nature, not advice on any particular transaction. To discuss what any of these developments means for your business or administration, contact us.