The 2026 start-up comes with key regulatory changes in the European Union that directly affect international logistics, customs and import/export operations.

The activation of new ex-ante control systems, together with the entry into operation of environmental mechanisms and the adjustment of other regulations, introduces new documentary and compliance requirements for companies moving goods to or from the European market.

These changes have a direct impact on international transportation planning, transit times and supply chain management since the beginning of this year.

These measures are part of the European Union’s strategy to strengthen the prior control of goods, integrate environmental criteria into international trade and improve the traceability of supply chains, in a context of increased regulatory pressure and digitization of customs processes.

 

What has changed in 2026 and why it is relevant to international logistics

The beginning of 2026 concentrates several simultaneous regulatory changes in the European Union that directly affect international logistics, customs and foreign trade operations.

This is not a single isolated regulation, but rather the coincidence of different regulatory fronts that reinforce the prior control of goods, expand documentary obligations and increase compliance requirements for importers, exporters and logistics operators.

These changes have an impact both on the entry of goods into Community territory and on the planning of international transport and supply chain management, especially in a context of increased digitization and traceability required by European authorities.

 

Three regulatory fronts marking the 2026 kick-off

Three key elements converge at the beginning of this year to explain why 2026 is a turning point for logistics and international trade in Europe:

✔️ The consolidation of the ICS2 system, which strengthens security controls and requires more detailed information prior to the arrival of goods in the EU.

✔️ The entry into operation of the CBAM, which introduces new obligations linked to carbon emissions associated with certain industrial imports.

✔️ The adjustment in the EUDR implementation schedule, which, although postponed, maintains regulatory pressure on the traceability of certain imported products.

Each of these fronts acts on different aspects – safety, environment and traceability – but together they increase the operational complexity of import and export operations.

 

A direct impact on documentation, timing and logistical planning

The main consequence of these changes is an increase in the requirements for advance information and documentary accuracy. Companies must no longer only comply with traditional customs formalities, but must also provide more complete, structured data in advance.

This directly affects:

✔️ Transit times, by introducing stricter pre-checks.

✔️ International transportation planning, which is increasingly dependent on the availability of correct data in advance.

✔️ Coordination between the different actors in the supply chain, such as shippers, freight forwarders, carriers and customs agents.

In this context, data management and regulatory compliance become a critical element to avoid delays, goods blockages or cost overruns in logistics operations.

 

ICS2: the new pre-clearance system to strengthen EU Customs

From September 1, 2025, Import Control System 2 (ICS2) is operational for all modes of transport, with temporary and limited derogations in some Member States and for certain operators. In 2026, it is fully consolidated as a mandatory framework, with exclusive adoption of v3 messaging as of February 3, 2026 for all modes of transport.

This system replaces and extends previous customs control mechanisms, with the aim of anticipating risks before the physical arrival of shipments in the Community territory.

The implementation of ICS2 represents a significant change in the way data is managed in international transport, as it requires that key cargo information is available and validated prior to shipment or border arrival, depending on the mode of transport.

 

What is ICS2 and what information does it require prior to arrival of the goods?

ICS2 is a European customs risk analysis system based on the advance submission of the Entry Summary Declaration (ENS). This declaration must include much more detailed information than in previous systems.

Among the required data are, among others:

📄 Precise description of the goods.

🧾 Tariff codes

🏷️ Complete data of sender and consignee

⚖️ Weight, number of packages and type of packaging

🚢 Means of transportation and route information

The purpose of this level of detail is to enable customs authorities to perform safety and security checks before the goods arrive in the EU, reducing risks related to fraud, security or compliance.

 

What modes of transport are affected by ICS2

By 2026, ICS2 already affects all major modes of international transport bringing goods into the European Union:

🚢 Maritime transport, including containerized and non-containerized cargo

✈️ Air transport both general cargo and express shipments

🚛 Ground transport by road and rail

🔄 Multimodal operations, when the goods enter the EU after a combined journey.

This implies that ICS2 is not an obligation limited to a specific type of operator, but has a cross-cutting impact on the international supply chain.

 

Who is responsible for reporting

The ICS2 system establishes clear responsibilities on who must submit the information, depending on the type of operation and the role of each logistic actor.

In practice, they may be involved:

👤 Carriers

📦 Freight forwarders

🏢 Logistics operators

🔗 Other intermediaries acting as ENS filers.

This distribution of responsibilities requires greater coordination between the parties, since a lack of information or errors in the data can affect the entire operation, even if the failure does not occur in the last link of the chain.

 

What happens if the information is incomplete or incorrect?

One of the most relevant changes introduced by ICS2 is that controls are carried out prior to the arrival of the goods. This means that documentary problems are no longer detected only at the border.

If the information submitted is incomplete, incorrect or not transmitted within the required deadlines, the authorities may apply control and risk mitigation measures, among them:

⏳ Requests for additional information

🚫 Retention of goods for inspection purposes

🛑 Operational restrictions that may prevent loading or entry into Community territory until the incidents are rectified.

These situations can result in delays, mismatches in logistics planning and additional costs, especially in operations with tight deadlines or time-sensitive supply chains.

 

Operational impact on importers, exporters and logistics operators

The implementation of ICS2 forces companies to review their internal processes and the way they manage logistics and customs information. Anticipation and data quality become a critical element of daily operations.

For importers and exporters, this means:

📑 Ensure that business information is closed prior to shipment.

🤝 Coordinate with suppliers and logistic partners from the source

⏱️ Reduce reliance on last-minute corrections

For logistics operators and freight forwarders, ICS2 reinforces their role as information managers, not only as transport organizers.

 

CBAM in 2026: carbon border adjustment enters operational phase

The year 2026 marks a significant operational change for the Carbon Border Adjustment Mechanism (CBAM). After a transitional period focused on reporting, the system moves towards a more demanding application, with direct effects on imports of certain industrial products and on the customs management associated with these operations.

The objective of the CBAM is to equalize the cost of carbon between products manufactured within the European Union and those imported from third countries, incorporating the environmental factor as another element of border control.

 

What changes in 2026 with respect to the transitional phase

During the transitional phase, obligations focused mainly on the reporting of carbon emissions associated with imported products. In 2026, CBAM enters a more advanced operational phase, which reinforces the importer’s responsibilities.

The main changes include:

📌 The need to be registered as an authorized CBAM declarant in order to import goods subject to the mechanism.

📊 Consolidation of the obligation to calculate and verify emissions associated with each import.

🧾 Further integration of CBAM in customs and documentary processes, aligning it with import declarations.

In addition, adjustments and simplifications to the final CBAM regime have been approved during 2025, including postponing the start of the sale of certificates to February 1, 2027. These changes are intended to ease the transition to the definitive system and give importers and authorities more room to adapt processes, although they do not eliminate the preparation and data collection obligations during 2026.

Although the actual purchase and delivery of CBAM certificates starts in February 2027 (covering imports made in 2026), 2026 becomes the key year for preparing systems, data and processes, as imports made during this fiscal year will serve as the basis for subsequent purchase and delivery obligations (first declaration and annual delivery in September 2027).

 

Which products are subject to CBAM

The CBAM applies to a specific set of products considered carbon-intensive. In 2026, the scope of application is maintained on the following main categories:

🏗️ Cement

🔩 Iron and steel

🧱 Aluminum

🧪 Fertilizers

⚡ Electricity

🧬 Hydrogen

These goods are subject to specific controls at the time of import, which introduces new information and traceability requirements for operators dealing with these trade flows.

 

New import information requirements

One of the most relevant aspects of CBAM is that it shifts part of the reporting burden to the origin of the goods. In order to comply with the regulations, importers must have reliable data on:

🌱 Direct emissions generated during production.

🧮 Calculation methodologies used by the producer.

🏭 Technical information on source facilities.

This information must be integrated into the import processes, which affects both customs document management and the relationship with suppliers and manufacturers outside the EU.

 

Impact of CBAM on logistics and the supply chain.

From an operational point of view, CBAM introduces a new variable in international logistics planning. It is not only a potential cost, but a factor that conditions decisions related to:

🔄 Supplier and sourcing selection

📦 Medium- and long-term import planning

🗂️ Documentary management and coordination with customs agents

⏱️ Dispatch times, if information not available or validated

For the supply chain, CBAM reinforces the need for transparency and traceability upstream, integrating environmental criteria into processes traditionally focused on price, lead time and availability.

 

EUDR: deferral and what it means for import and export in the EU

The European regulation against deforestation (known as the EUDR) has returned to the center of regulatory news in Europe after a postponement of its implementation was confirmed. Although the regulation was already approved and in place at the legal level, the timetable is adjusted to give companies and authorities more time to prepare systems, data and processes.

For international logistics and import/export operations, deferral does not eliminate the obligation: it simply shifts the point at which it will begin to be fully enforced, maintaining pressure on traceability. The postponement does not eliminate the obligation for international logistics and import/export operations.

 

What has been approved and what are the new dates?

The key change is the new implementation schedule, which widens the preparation window:

🗓️ Medium/large operators and traders: application as of December 30, 2026

🗓️ Micro and small enterprises (as defined by the EU): application as of June 30, 2027

This postponement is part of the need to ensure that the information system and control processes can absorb the volume of data required, and the operational readiness of the ecosystem (companies, authorities and logistics chains).

 

What does the EUDR cover and why does it affect logistics?

The EUDR regulates the entry and exit of certain products: not only their import, but also their marketing within the EU and export from the EU where applicable.

The principle of the standard is that covered products may only be traded or exported if it is demonstrated that:

🌳 Are “deforestation-free” (not linked to deforestation or forest degradation according to the criteria of the standard).

⚖️ They have been legally produced in the country of origin (in compliance with applicable local regulations).

🧾 They are supported by a due diligence process and an associated formal statement.

This impacts logistics because it introduces requirements that rely on origin data, traceability and documentation that must travel with the goods (or, at a minimum, be available and referenced) before the product is placed on the market or crosses borders.

 

Products and raw materials affected

The EUDR focuses on seven “relevant” commodities and a list of derivative products. The core raw materials are:

🐄 Cattle

☕ Coffee

🍫 Cocoa

🌴 Palm oil

🌱 Soybeans

🛞 Rubber

🌲 Wood

In addition, the obligation extends to specific derivatives (e.g., furniture or paper in the case of wood, or derived food products in other chains), according to the technical list of the regulations.

 

What documentation and data is required in practice

The operational backbone of the EUDR is due diligence, which requires the collection and retention of information to demonstrate compliance. In practical terms, the operation is supported by a Due Diligence Statement (DDS), which is submitted electronically in the system provided by the EU.

At the data level, compliance usually involves having:

📍 Geolocation of plots or production areas (one of the most sensitive points in terms of volume and accuracy).

🧩 Product/batch identification and traceability to connect goods to their origin

📑 Evidence of legality at origin (according to the regulations of the producing country).

🔎 Risk assessment and, if applicable, mitigation measures.

For import/export, this adds an additional layer of document preparation that can condition timing and logistical coordination, especially when there are multiple suppliers, consolidated or complex chains.

 

Impact for importers, exporters and logistics operators

Although the main obligations fall on operators and traders (depending on the role and type of transaction), in practice the EUDR involves other actors because the information must be available, consistent and able to “accompany” the product.

Typical impacts on the logistics chain:

🧾 F urther documentary requirements prior to placing on the market or international movement.

🔗 Need to connect source data with logistic flows (batches, containers, warehouses, distribution).

⏱️ Risk of delays if information is not ready, especially in campaigns with high turnover or multiple origins.

🗂️ Increased pressure on information systems (data exchange with suppliers, internal traceability, document custody).

🤝 More coordination between purchasing, compliance, customs, freight forwarders and warehouses to avoid “bottlenecks” due to lack of data.

In operational terms, the postponement gives room to organize processes, but also sets a clear horizon: the companies that move the goods concerned will have to reach 2026/2027 with consolidated traceability and document management.

 

What importers and exporters should watch out for in 2026

The confluence of ICS2, CBAM and EUDR makes 2026 a key year for reviewing processes in import, export and international logistics. Beyond regulatory compliance, the focus shifts to data anticipation, traceability and operational coordination, elements that condition time, costs and supply chain continuity.

 

Operational checklist

 

Data and documentation (ICS2)

📄 Ensure that commercial and logistical information is finalized prior to shipment, without relying on subsequent adjustments

🧾 Review data quality and consistency (descriptions, codes, weights, actors) between commercial, logistic and customs documents.

⏱️ Verify that pre-arrival submission deadlines are met according to mode of transport

 

Suppliers and emissions (CBAM)

🌱 Identify which imported products are subject to CBAM.

🏭 Request and validate emissions data in advance from manufacturers and suppliers.

🗂️ Integrate environmental information into the usual import and clearance processes.

 

Preparation of traceability (EUDR)

📍 Check whether imported or exported goods fall within the scope of the EUDR.

🧩 Prepare systems to link product, lot and origin in a traceable manner .

📑 Anticipate the collection of information for due diligence, including during the deferral period.

 

Coordination with customs broker and freight forwarder

🤝 Clearly define roles and responsibilities in data generation and transmission.

🔄 Establish stable information flows between shippers, freight forwarders and customs brokers.

🛃 Align criteria to avoid discrepancies that may cause blockages or delays at the border.

 

Why this news matters for companies importing and exporting in Europe

The regulatory changes coming into play in 2026 are not merely administrative. They have a direct impact on operating costs, delivery times, the risk of delays and the documentary burden associated with international trade operations. Anticipation and data quality become as important as the actual transport of the goods.

In an environment where checks are increasingly performed prior to border arrival, lack of preparation can result in supply chain disruptions, last minute adjustments and loss of operational efficiency.

Upcoming milestones to watch out for

🗓️ ICS2: fully operational system for all modes of transport as of 2026

🗓️ CBAM: key base year for imports that will generate subsequent obligations

🗓️ EUDR: mandatory application from December 30, 2026 (and June 30, 2027 for micro and small enterprises)

 

The role of Across Logistics as an international logistics partner

In a context where customs, documentation and traceability requirements are increasing for import and export operations in Europe, having a comprehensive logistics partner can make the operational and compliance difference.

Across Logistics is an international logistics operator with presence in multiple countries (Spain, the Netherlands, China, United Arab Emirates and the United States) and services covering sea, air and land transportation, customs services, warehousing and distribution, as well as solutions for special cargo, temperature controlled and e-commerce.

This service model allows importers and exporters:

🧾 Integrate customs document management with transportation processes.

🚚 Better coordinate international logistic flows, reducing delays and friction

📊 Organize and anticipate the data required for systems such as ICS2 or CBAM.

📦 Have multimodal solutions adapted to the complexity of the operation.

🤝 Simplify collaboration between suppliers, freight forwarders and customs brokers.

The comprehensive approach and ability to manage complex operations make Across Logistics an operational partner for companies seeking efficiency, compliance and continuity in their international supply chain.

Shall we talk?

 

 

 

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