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On the 27 November 2025, Kuehne+Nagel hosted a webinar that unpacked key customs changes across the UK, EU and US.

The session—which attracted over 800 participants—gave an in-depth, expansive and expert view on core customs legislation, and the business impact of these shifts.

Ready to learn about these customs changes?

Watch the webinar recording and read our Q&A for expert answers to audience questions.

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Speakers:

  • Marc Bernitt, Head of Customs EMEA and Asia, Kuehne+Nagel, a customs expert with over 30 years’ experience in global customs compliance.

  • John Roberts, UK Customs Sales Manager, Kuehne+Nagel, a customs expert with over 14 years’ experience in logistics and customs solutions.

Moderator:

  • Anaïs Schatz, Global Customs Business Development Manager at Kuehne+Nagel, a sustainability-focused customs expert with over 5 years’ experience in regulatory matters including CBAM and EUDR.

Agenda highlights:

  • CBAM developments: The EU Carbon Border Adjustment Mechanism (CBAM) will take full effect in 2026, followed by the UK’s CBAM in 2027.

  • US tariff updates: How recent changes to US tariffs are reshaping global trade flows.

  • The UK’s new trade strategy: Announced in June 2025, the UK government’s new trade strategy redefines the nation’s approach to international commerce. What are the implications for UK-EU relations, and how might this reshape opportunities for your business?

  • Fiscal representation in the EU: Fiscal representation combines regulatory obligations with strategic advantages, making the application process an important step for businesses.

  • Regime 42 changes: With France set to abolish Regime 42 in 2026, UK exporters must prepare for the transition and adopt the necessary procedures to safeguard their operations.

Webinar Q&A

EU and UK Trade

A UK exporter must have both a French VAT number and an EU EORI to use Regime 40 (CPC 4000) using Delivery Duty Paid (DDP) routing by France (then free circulation to other EU countries).

For DDP the UK exporter would need to apply for Dutch or Belgian VAT and apply for Article 23 license or BE 14000 license depending on chosen entry point to the EU. The UK exporter would require indirect representation in the EU and the UK exporter is then responsible for the monthly VAT filings. Another option is that limited fiscal EU representation can also be utilised for the Netherlands and Belgium.

Any non-EU business using a Spanish VAT number or storing/managing goods in Spain must appoint a Spanish fiscal representative. A Spanish VAT registration alone is not compliant.

The UK’s new trade strategy includes several initiatives aimed at reducing medium-term costs for FTL imports. Key measures include the rollout of the Single Trade Window and digital trade corridors to streamline customs processes, AI-driven upgrades to the Customs Declaration Service (CDS), and infrastructure improvements at ports through freeport programmes. These changes, combined with trusted trader schemes and mutual recognition agreements, are designed to cut administrative burdens, speed up border clearance, and lower logistics costs by 2027.

The Autumn Budget introduces direct cost impacts such as the removal of the £135 low-value import relief, which will increase customs declaration fees and handling costs for small consignments. Indirectly, measures like the Carbon Border Adjustment Mechanism (CBAM) from 2027 and broader customs modernisation may raise compliance costs and influence supply chain strategies. These changes align with the UK’s trade strategy to modernise processes while maintaining cooperation under the UK–EU Trade and Cooperation Agreement

As a UK exporter, if you are currently using Regime42, typically there are no obligations to provide VAT declarations as this is handled by your limited fiscal representative if you are allowed to use their global vat number. From January 1, 2026, fiscal agents cannot file under Regime 42 on behalf of non-EU businesses.

If you’re shipping DDP into the EU as a non-EU business, an indirect customs representative alone does not replace a fiscal representative as many countries still legally require a fiscal representative for VAT compliance. If the UK exporter has a French VAT registration and EU EORI and imports under Regime 40, no additional fiscal representative is required because the French VAT number covers EU compliance.

The UK is implementing EUDR principles through its Environment Act 2021, requiring due diligence and reporting on deforestation-risk commodities like cattle, cocoa, palm oil, and soy. However, it falls behind the EU in scope and enforcement, with secondary legislation still pending, so UK exporters must comply with EUDR for EU trade. More up to date information can be found on our web page.

US trade

Shipments must be made directly from the first transaction point i.e. the original shipper in the exporting country directly to the US. If the first in this transaction is the distributor or subsidiary this has no effect on the overall validity of the application. What’s important is that the first transaction leads to a direct shipment to the US without any transshipments.

CBAM

No. Pharmaceutical products are not included in the CBAM regulation. CBAM currently applies only to a limited list of sectors, namely iron & steel, aluminium, cement, fertilisers, electricity and hydrogen, plus some downstream products under these HS codes. So, there is no CBAM implication for pharma, neither for imports into the EU nor for exports to the UK.

Finished safety valves are not CBAM goods, unless they contain a CBAM sub-component imported separately under steel or aluminium HS codes.

Yes. Registration as a CBAM declarant can be done later, when you start importing CBAM-covered goods.

As long as you only deal with safety valves (HS 8481), you do not need to register for CBAM, neither in the EU nor in the UK.