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2028 EU customs reforms introduces Deemed Importer

Business using IOSS may incur customs duties debt on import distance sales from March 2028

The EU European Commission unveiled major Customs Union 2028 reforms last month which included the creation of a new ‘Deemed Importer’ model. These are traders importing goods into the EU to EU consumers (distance sellers) who will have the option to incur a customs duties debt at the point of import and use the Import One-Stop Shop IOSS return.

March 2028 – Removing the €150 import duties threshold

The trigger for the Deemed Importer is the proposal to withdraw the €150 customs duties exemption on low-value consignments being shipped to consumers. From March 2028, these consignments will be subject to customs duties.

This means e-commerce sellers or deemed supplier marketplaces will have to charge simplified bucket tariff and duties in the checkout on relevant sales. But rather than paying the duties at the border at clearance, they can incur a Customs debt. And they may settle this via the VAT IOSS return. IOSS covert the VAT charged on the same consignments, and was introduced with the EU VAT e-commerce package in July 2021.

The basic requirement for the Deemed Importer status is that the trader must be eligible for IOSS reporting.

EU VAT reforms

Reform (click for details) Update
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2030? Digital Reporting Requirements and e-invoicing harmonisation Likely delay to 2030
Structured e-invoices supercede paper invoices Likely delay to 2030
EC Sales lists replaced by Digital Reporting Requirements Likely delay to 2030
2028 EU Customs reforms Published May 2023
€150 import consignment threshold removed Published May 2023
2026 DAC8 harmonised crypto asset reporting Approved May 2023
2025 VAT registration thresholds equivalence foreign businesses 1 Jan 2025
Virtual events VAT rule changes 1 Jan 2025
Single VAT Registration in the EU - extension of OSS Likely delay to 2026
Marketplace deemed supplier extended to EU sellers Likely delay to 2026
Proposal for VAT treatment of the platform economy Likely delay to 2026
EU IOSS mandated for marketplaces Likely delay to 2026
Call-off stock VAT simplification ends Likely delay to 2026
Harmonisation of B2B Reverse Charge rules Likely delay to 2026
Financial Services VAT exemption reform proposals Consultation complete; proposal awaited
Tour operator margin scheme VAT reforms EC undertaking fresh review
2024 Payment providers' seller transaction reporting and bookkeeping obligations In effect since 1 Jan 2024
2023 DAC 7 - marketplace reporting harmonisation In effect since 1 Jan 2024
2022 IOSS reforms to prevent double taxation On hold
EU reduced VAT rate freedoms Entered into force 6 April 2022
VAT in the Digital Age proposals Published Dec 2022
EU DAC8 cryptocurrency tax reporting proposals Published Dec 2022
VAT Gap Initiative Q3 2022
EU Definitive VAT System On hold
2021 One-Stop-Shop (OSS) single EU VAT return In effect since 1 July 2021
Ending €22 import VAT exemption; new IOSS return In effect since 1 July 2021
Marketplace deemed supplier EU VAT reforms In effect since 1 July 2021
2020 EU four Quick Fixes for VAT In effect
Tax authorities anti-VAT fraud cooperation In effect
Tax Action Plan - 25 VAT and other tax reforms roadmap See 'VAT in the Digital Age' and others
2019 Simplification of e-services VAT compliance and thresholds In effect
Single and multi-use vouchers In effect
2018 Lower e-book and publications VAT rates In effect, although not all EU states have adopted the option


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