21 September 2027 Platforms take on Customs Deemed Importer obligations:
Duties, excise and VAT collections; import reporting; and product liabilities
The 2027-28 EU Customs reforms mark the most significant modernisation of European trade law in decades. For e-commerce, the change is dramatic: digital platforms and marketplaces will become deemed importers, taking on the legal responsibilities previously left with consumers or couriers.
From 21 September 2027, platforms are no longer just intermediaries in e-commerce. They become deemed importers, carrying full responsibility for customs duties, VAT, compliance, and product safety.
This major reform aims to protect consumers, create fair competition between EU and non-EU sellers, and provide customs authorities with greater visibility into the booming cross-border e-commerce market.
What are platforms in Customs context?
In the context of the 2027-288 EU Customs Reforms, a “platform” generally refers to an online marketplace or digital interface that facilitates the sale and importation of goods into the EU, particularly from non-EU sellers. A platform could be companies like Shein, Temu, Amazon, AliExpress, etc.—basically, any digital service where non-EU sellers can list products and consumers in the EU can buy them directly.
What Is a Deemed Supplier Platform?
A deemed supplier platform is a digital platform or marketplace that facilitates the distance sale of goods imported into the EU. From 21 September 2028, you are treated as a deemed supplier if you:
- Facilitate B2C distance sales of imported goods.
- Are authorised to use or report via the Import One-Stop Shop (IOSS).
- Take on the role of importer for customs purposes, responsible for duties, VAT, and compliance.
- Collect customs duties and VAT at checkout, regardless of shipment value.
This brings customs rules into line with e-commerce package VAT rules, where platforms have already been deemed suppliers since the 2021 e-commerce VAT package.
Customs Definition of Importer
Under the Current Union Customs Code (UCC)
The importer is: The person in whose name the customs declaration for release for free circulation is lodged, or the person on whose behalf that declaration is made.— Union Customs Code, Article 5
This person is:
- Responsible for customs duties, import VAT, and excise.
- Accountable for compliance with EU product standards and restrictions.
- The party who brings goods into free circulation within the EU customs territory.
Under the 2027-28 Customs Reform
The definition is expanded:
- For e-commerce distance sales, the platform is the deemed importer.
- Consumers will no longer be liable for customs charges upon delivery.
- Platforms must submit structured shipment data to the new EU Customs Data Hub.
Key Obligations for Deemed Importer Platforms
Platforms that qualify as deemed importers will face the following responsibilities:
1. Customs Liability
- Collect and pay customs duties and VAT at checkout.
- No exemptions: the €150 low-value relief is abolished.
2. Regulatory Compliance
- Ensure goods comply with EU safety, product standards, and restrictions.
- Platforms are liable if unsafe or non-compliant goods are sold.
3. Tariff Simplification (Duty Buckets)
- Use simplified duty bucket categories instead of full tariff codes.
- Apply the correct rate during checkout.
4. Data & Documentation
- Upload structured pre-arrival data to the EU Customs Data Hub.
- Maintain transaction records for at least 10 years.
5. Legal Accountability
- Platforms are legally liable for errors, fraud, or mis-declarations.
- Subject to EU-wide audits by the EU Customs Authority.
6. Trust & Check Status (Optional)
- Platforms may apply for Trust & Check trader status.
- Benefits include simplified declarations, faster clearance, and fewer inspections.
- Requires proven compliance reliability.
