The 2025 customs playbook

The Council of the European Union has released a progress report on the Customs Union reform package. The European Commission aims to reach a consensus on this proposal by the end of 2025, with the first operational phase of the reform starting in 2026. Member States have emphasised the need to prioritise rules concerning e-commerce to ensure better compliance with non-financial requirements and provide customs authorities with appropriate control tools. 

The EU Customs reform aims to simplify customs processes by embracing digital transformation, replacing traditional declarations with a data-driven approach to import supervision. A new EU Customs Authority will oversee an EU Customs Data Hub, which will streamline customs IT infrastructure and improve risk management and customs checks. 

For more details please visit our global page.

The Combined Nomenclature for 2025 will apply from 1 January 2025. The European Commission has introduced new subheadings to facilitate the monitoring of specific goods such as ‘sharks and shark fins,’ ‘tomatoes,’ ‘biofuels,’ ‘liquid urea,’ ‘wood waste’ and ‘laminate floor covering.’ 

Companies should evaluate the effects of these changes to prevent any surprises, delays or incorrect declarations.

With one of the last significant changes having been the requirement to report effective emissions data from 1 July 2024, further steps will be taken on 1 January 2025. A new portal section in the CBAM Registry will enable installation operators from outside the EU to upload and share their emissions data with reporting declarants. Registration for installation operators will open from 1 January 2025, and the ‘authorised CBAM declarant’ status will become mandatory for the import of CBAM goods in the EU customs territory from 1 January 2026. Importers can start registering as authorised CBAM declarants as per 1 January 2025.

For more information please read our blog post.

The revised PEM Convention introduces simplified and modernised rules of origin, with more flexible, product-specific rules and relaxed provisions on cumulation, duty drawback, tolerance and transport conditions. Until 1 January 2026, two sets of alternative rules of origin will apply in the PEM area, allowing exporters and suppliers to choose either set. At the same time, proofs of origin issued before 1 January 2025 will still be valid if goods are in transit or under customs supervision on that date. Exporters using the revised rules must indicate ‘REVISED RULES’ on proofs of origin by 31 December 2025. 

You can find more information in our blog posts.

• PEM Convention revision accepted
• The revised PEM Convention: what it means for your business

Centralised Clearance for Import (CCI) allows economic operators to submit a customs declaration for goods at the supervising customs office in a Member State other than the one in which they are presented. It is available for use by European businesses in Bulgaria, Estonia, Spain, Luxembourg, Latvia, Lithuania, Poland, Romania, Croatia and Italy. Other Member States are planning to join the scheme over the coming year.

The second phase of the CCI system, scheduled for 2 June 2025, will expand the system’s capabilities, including the processing of simplified and supplementary declarations, entry in the declarant’s records, excise and goods within fiscal territories. Businesses must be authorised economic operators for customs simplifications to benefit from the CCI system.

Read more here.

The incoming administration in the United States plans to introduce a 10 to 20% tariff on all imports and a potential 60% tariff targeting imports from China. These increased tariffs could lead to higher costs for businesses and potential disruptions to supply chains. 

The European Court of Justice’s ruling in the Harley-Davidson case highlights the need for transparency and thorough documentation to justify the economic viability of production strategies, especially when relocations coincide with the imposition of trade measures.

Explore our dedicated US trade and tariffs page.

Swiss customs is undergoing a transformation, including revision of the Swiss customs act, the establishment and implementation of a new organisational structure and the digitalisation of its processes. The new clearing system, Passar, will gradually replace the legacy systems e-dec Import and e-dec Export, with the latter being usable until 31 December 2025. The ‘Garanzia’ monitoring tool will be operational for managing guarantees from July 2025.

The new customs legislation is still in the political process. After its adoption through the national council in 2024, the Council of States adopted it on 17 December 2024 and will discuss content-related details later. Adoption of the legislation is followed by the procedure for the revision of differences in parliament. Once this has been completed, the law will be a subject to an optional referendum, which means that a referendum period of 100 days must elapse before the law can enter into force. It is expected that new customs act will enter into force in mid-2026 at the earliest.

For more detailed information visit our knowledge hub.

We support your business

PwC supports businesses in all areas to strengthen the processes and interactions. Our team of customs experts is always ready to help you to navigate through the constantly changing world of customs and global trade. PwC Switzerland offers comprehensive customs services to help businesses navigate these challenges effectively. Our services include:

• Customs valuation consulting: We provide expert advice on the correct valuation of goods to ensure compliance with customs regulations. Accurate valuation is essential to avoid penalties and ensure smooth customs clearance.
• Preferential origin management and customs duty optimisation: Our team supports businesses in managing preferential origin to benefit from reduced duty rates under various trade agreements. We also help in identifying opportunities for customs duty optimisation to reduce overall import costs.
• Customs classification review: We assist in reviewing the customs classification of goods to ensure they are correctly classified according to the Harmonised System (HS) codes. Proper classification is critical for determining applicable duties and compliance with import regulations.

Furthermore, we have developed a Trade Activator tool that can visualise the cross-border business of your company based upon customs (or broker) data in multiple jurisdictions, including Switzerland. We help you visualise and subsequently analyse your cross-border trade in order to detect future savings possibilities and to mitigate risks.

We can help you with SAP GTS topics as well. Our team of functional and technical GTS consultants is experienced in doing migrations, implementations and all kinds of GTS enhancements and also offers maintenance and monitoring support for your GTS system through its helpdesk organisation.

Contact us