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The UK’s new Vaping Products Duty is moving from policy design into operational implementation. HMRC has updated its guidance on the new duty and the associated Vaping Duty Stamps Scheme, giving manufacturers, importers, warehousekeepers, wholesalers and retailers a clearer view of what they need to do before the regime starts.

The duty will apply from 1 October 2026 to vaping products, whether or not it contains nicotine. Businesses that manufacture vaping products in the UK, store vaping products under duty suspension, or handle vaping duty stamps will need HMRC approval, which can take up to 45 working days.

Vaping duty stamps and the transitional period

The new duty will be supported by a Vaping Duty Stamps Scheme. The stamp is intended to help HMRC and the supply chain identify products on which duty has been accounted for and to support enforcement against illicit or non-compliant products.

The key dates are as follows:

• 1 April 2026 – 30 November 2026, transitional stamps are available for purchase
• 1 September 2026, digital stamps are available for purchase
• 1 January 2027, only digital stamps may be affixed to products
• 1 April 2027, all vaping products outside duty suspension must have a stamp affixed.

UK and overseas manufacturers should ensure that their stamp arrangements are agreed in advance, with all products released to free circulation after 1 October 2026 requiring a stamp by law.

New retailer and wholesaler guidance

If you only sell or distribute duty-paid vaping products wholesale or retail, you do not need to apply for approval for Vaping Products Duty or the Vaping Duty Stamps Scheme, however you will need to ensure that your products comply with the stamp requirements.

The new guidance notes that businesses should undertake checks on products prior to sale and must keep clear business records for at least 6 years, covering supplier details, invoice numbers, when products were produced, and what checks you undertook to ensure products were legitimate.

What businesses should do now

From 1 October 2026, liable vaping products released for consumption in the UK will generally need to be stamped at or before the excise duty point. For products produced or imported before 1 October 2026, the transitional rules mean that products outside duty suspension must be stamped by 1 April 2027.

Businesses in the vaping supply chain should now assess whether they require approval, map where duty points arise, and confirm who will be responsible for ordering, affixing and managing vaping duty stamps.

The new regime affects not only manufacturers and importers, but also businesses that store, move, buy or sell vaping products in the UK supply chain. Businesses will need to understand whether they are handling duty-paid, duty-suspended, stamped or unstamped stock at each stage.

Please reach out to Jamie Mcleod to understand how Crowe UK can support you with Vaping Products Duty readiness, including approval applications, supply chain mapping, duty point analysis, stamp controls and process documentation.

HMRC has published draft legislation and guidance confirming that Alcohol Duty will be brought within the wider penalty reform regime for late submission and late payment. The changes will affect producers of alcoholic products who are required to submit Alcohol Duty returns and pay Alcohol Duty to HMRC.

The reform replaces the existing Alcohol Duty penalty approach with rules that are already familiar from VAT and Income Tax Self-Assessment. HMRC’s stated aim is to make penalties more consistent, fair and effective by distinguishing between occasional mistakes and repeated non-compliance.

What is changing?

For late submission, Alcohol Duty will move to a points-based penalty system. A producer will receive one point each time an Alcohol Duty return is submitted late. A financial penalty will only arise once the relevant points threshold is reached.

For monthly Alcohol Duty obligations, the threshold will be five points. This means a producer would generally need to miss five filing deadlines within a 24-month rolling period before incurring a late submission penalty. Once the threshold is reached, a £200 penalty applies, and each subsequent late submission while at the threshold will trigger a further £200 penalty.

Late payment penalties

The late payment rules are designed to encourage prompt payment, with the penalty linked to both the amount outstanding and the length of time it remains unpaid. No late payment penalty should apply where the Alcohol Duty liability is paid within 15 days of the due date.

If the duty remains unpaid between 16 and 30 days after the due date, a first penalty of 3% of the outstanding amount may apply. If any duty is still unpaid after 30 days, further penalties can apply, including an additional charge calculated by reference to the amounts outstanding at day 15 and day 30.

Why this matters

The changes are helpful for businesses that occasionally miss a filing deadline, as a single late return will not automatically result in a financial penalty. However, the regime creates a clear compliance risk for producers with recurring issues in their month-end duty processes, system controls or agent instructions.

Alcohol producers should also note that the late payment regime can become costly where duty remains unpaid beyond the short grace period. Businesses with seasonal cashflow pressures, manual approval processes or complex production and removal arrangements should ensure payment controls are robust.

What businesses should do now

Alcohol producers should review their return preparation and payment processes to ensure filing and payment deadlines are clearly owned, monitored and evidenced. In particular, businesses should check that Alcohol Duty return calendars are up to date, internal review steps do not create avoidable delays, and payment approvals are aligned to HMRC due dates.

Where returns are prepared using production, stock movement or duty accounting data from multiple systems, businesses should consider whether data gaps or reconciliation issues could increase the risk of late submission.

Crowe’s Customs and International Trade team can support alcohol producers with Alcohol Duty compliance reviews, process mapping and controls testing to help reduce the risk of late filing and late payment penalties. Please reach out to Jamie Mcleod to discuss how we can support.

The UK Government has released additional guidance on how the revised steel safeguard framework will operate in practice. This includes further detail on transitional exemptions, quota administration, and country-specific treatment.

However, it is important to note that we are still awaiting confirmation of the details of the final measure. As such, aspects of the regime, particularly around practical application, may continue to evolve.

Refresher – the new measure from July 2026

From 1 July 2026, the UK will implement a significantly tighter steel safeguard regime. Tariff-free quota volumes will be reduced by approximately 60%, and any imports outside quota will be subject to a 50% safeguard duty, in addition to standard customs duties.

For affected businesses, the commercial impact will be highly sensitive to timing. Imports outside quota will give rise to a material cost exposure.

Transitional exemption – limited protection for existing contracts

A key development is the introduction of a short-term transitional exemption for goods linked to pre-existing contracts.

Where a contract was entered into before 14 March 2026, goods imported between 1 July 2026 and 30 September 2026 may be exempt from the 50% out-of-quota duty. This applies both to direct imports and to goods released from Customs Warehousing during that period, provided they relate to qualifying contractual commitments.

From a practical perspective:

• the exemption is evidence-driven – contracts, invoices and proof of payment must support the claim
• HMRC may request evidence after clearance – robust audit readiness will be essential
• specific declaration requirements apply, including use of document code 9Y16.

Importantly, goods benefiting from this exemption will not count towards quota usage in the first quarter. This provides a limited window of protection for existing arrangements, but only where eligibility can be clearly evidenced and is capable of withstanding audit scrutiny.

Quota administration – increased pressure on access and predictability

Quota access will continue to operate on a first-come, first-served basis. With reduced volumes, competition for quota is expected to intensify. In practice:

• faster quota exhaustion is likely across many categories
• early-quarter availability may be less predictable, particularly where transitional exemption volumes sit outside the system.

Carry-forward and access to unused quota

The updated framework introduces more structured rules around unused quota:

• claims for quarterly quotas will be suspended at the end of the 19th working day of the month following the end of quarters 1 to 3
• any unused quota (country-specific or residual) will carry forward to the next quarter within the same quota year and remain available for goods of the same origin
• carried-forward quota will become available from the 20th working day after quarter-end.

Any remaining balance at the end of quarter 4 will lapse. However, Q4 quota volumes may still be claimed retrospectively for up to three years after import, subject to standard conditions.

This represents a shift from the previous regime. While it introduces some intra-year flexibility, the practical benefit is likely to be limited in a tighter quota environment.

Country-specific treatment

The updated guidance confirms that safeguard measures will continue to be suspended for goods originating in Ukraine.

How businesses can respond

The revised framework increases the need for active management of safeguard exposure. Practical steps include:

• strengthening quota management processes to maximise access at the point of import
• reviewing shipment timing and supply chain planning to align with quota availability
• considering the use of Customs Warehousing to control the timing of release into free circulation and manage exposure.

More broadly, businesses should assess the financial impact of different import scenarios, particularly where reliance on quota access is high, while recognising that some aspects of the final regime may still change.

Crowe supports clients in assessing exposure under the new regime, including analysis of historic import patterns, modelling quota exhaustion scenarios, and identifying areas of concentrated risk. This can provide a clearer view of potential cost exposure and inform appropriate mitigation strategies.

For more information, please contact Jamie Mcleod or your usual Crowe contact.

The European Commission has confirmed the CBAM certificate price for Q2 2026 imports at €75.28 per tonne of CO₂e.

That is almost unchanged from the Q1 price of €75.36, so expected CBAM costs remain broadly stable for now.

This matters because CBAM is no longer just a future compliance obligation. It is now a measurable cost that importers and suppliers can start building into pricing, quotes and commercial discussions.

For 2026, certificate prices are being published quarterly, based on the weighted average of EU ETS auction clearing prices. From 2027, prices will move to weekly publication.

Although certificates cannot be purchased until February 2027, liability has applied from 1 January 2026. Importers will therefore need to apply the certificate price for the quarter in which the relevant goods were imported.

The Q2 price gives some short-term stability, but businesses should not treat this as fixed. Carbon prices can move, and the expected EU ETS review may be an important driver over the coming months.

The certificate price is also only one part of the calculation. Final CBAM liability will still depend on emissions data, default values, benchmarks, the phase-in factor and any carbon price already paid in the country of production.

The practical point: businesses importing into, or exporting to, the EU should now be modelling CBAM as a real commercial cost, not a theoretical future issue.

The European Commission has published its first detailed state-of-play update on CBAM verifier accreditation, providing a clearer picture of how the verifier market is developing ahead of the definitive CBAM regime.

Under the definitive CBAM regime, importers using actual emissions data will need that data to be independently verified by an accredited CBAM verifier. The first accredited verifiers are expected to emerge from around September 2026.

The latest Commission update shows that progress is being made, but accreditation capacity remains limited:

• 24 national accreditation bodies have agreed to provide CBAM accreditation
• 9 are currently ready to accept applications
• 8 have agreed to accredit third-country applicants
• just 3 are already accepting third-country applications.

Among the major EU economies, Germany, Spain, Italy, the Netherlands, Belgium, Finland and Sweden are already accepting accreditation applications, while France has indicated it is not yet ready to do so as of July 2026.

The update is particularly relevant for verification companies outside the EU. Italy, the Netherlands and Sweden are currently the only accreditation bodies listed as already accepting applications from third-country verifiers.

For businesses importing CBAM goods into the EU, the publication provides some reassurance that the accreditation framework is now operational. However, the relatively small number of accreditation bodies currently accepting applications suggests verifier capacity could remain constrained during the early stages of the definitive regime.

As suppliers prepare to provide actual emissions data, businesses should continue engaging with their supply chain and monitoring verifier availability, particularly where reliance on verified actual emissions will be critical to future CBAM reporting.

For more information, please contact Jamie Mcleod.

HMRC, working with the British Standards Institution, has now published a new voluntary standard for customs intermediaries in the UK: PAS 41201:2026. The standard is intended to promote greater consistency, transparency and professionalism across the sector, particularly in the preparation and submission of customs declarations. 

The standard comes into effect on 30 June 2026 and provides a practical framework for what good practice looks like in the customs intermediary market. Although voluntary, it gives a clear indication of the direction of travel for the sector.

What does the standard cover?

The standard sets out expectations for customs intermediaries across several key areas, including due diligence, training, systems and controls, transparency, and operational resilience. It is aimed at organisational practices rather than individual declarants, and is designed to support a more structured and consistent approach to customs activity. 

In practical terms, the standard expects intermediaries to have more formal processes around:

• onboarding and due diligence on clients
• written procedures for handling declarations and supporting data
• regular staff training and continuing professional development
• internal audits and error correction
• clearer communication on services, pricing and responsibilities
• business continuity and resilience planning. 

A more detailed operational framework

The standard is not just high-level guidance. It includes a number of specific expectations around how intermediaries manage their day-to-day operations. For example, it requires documented internal audit procedures, including annual reviews of systems and processes and quarterly checks on submitted declarations. It also expects a sample-based approach to declaration testing, together with documented follow-up where issues are identified. 

There is also a stronger focus on evidence and record keeping. Intermediaries are expected to retain records of appointments, instructions, due diligence checks, complaints and supporting documentation, generally for six years. The standard also requires clearer procedures for seeking clarification where information is incomplete or inconsistent.

Training is another major theme. Relevant staff are expected to receive induction training early in their employment, ongoing professional development, and annual training on suspicious activity and breach reporting. The intention is to ensure that employees involved in customs declarations remain up to date and are able to identify issues before declarations are submitted.

What does this mean for traders?

While the standard applies directly to customs intermediaries, traders are likely to feel the effects in practice. Businesses may see more robust onboarding, more requests for supporting information, and greater focus on validating the data used in customs declarations. They may also benefit from clearer information on service scope, pricing, complaints handling and declaration status.

Over time, the standard may help create a more consistent level of service across the market and give traders a better basis for assessing the strength of their intermediary relationships. That said, the overall impact will depend on how widely the standard is adopted.

A practical call to action for intermediaries

For customs intermediaries, the standard should not be seen as something to note and revisit later. Even though it is voluntary, it is likely to become an important benchmark for best practice across the sector.

Intermediaries should now consider carrying out a gap assessment against the standard and reviewing whether their current arrangements are sufficiently robust in areas such as client due diligence, documented procedures, audit frameworks, staff training, pricing transparency, subcontracting controls and record retention. Early action will put businesses in a stronger position both commercially and from a compliance perspective.

For traders, this is a good opportunity to review current intermediary arrangements and ensure that expectations, responsibilities and data requirements are properly understood on both sides.

If you would like to discuss the new standard in more detail and assess its potential impact on your current processes, please contact Jamie Mcleod or your usual Crowe contact.

The UK has reached agreement in principle on a Free Trade Agreement with the Gulf Cooperation Council (GCC), covering Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the UAE.

The agreement is expected to deliver tariff liberalisation once in force. Based on current trade flows, around £580 million in duties on UK exports could be removed annually, with approximately £360 million eliminated on day one. The UK has also committed to removing tariffs on GCC exports to the UK from entry into force.

The GCC is a key trading partner, with total UK-GCC trade worth approximately £53 billion. The agreement is expected to expand goods market access and simplify certain border processes.

Tariffs will be reduced or removed across a range of sectors, including food and drink, medical equipment and advanced manufacturing.

The deal also includes customs and border-related measures, notably:

• faster customs clearance, including release within 48 hours, or within 6 hours for perishable goods where the relevant requirements are met;
• provisions aimed at simplifying customs procedures and documentation requirements; and
• measures to support more predictable and transparent border processes.

The agreement has been reached in principle and will now proceed to legal finalisation and ratification. No timeline for entry into force has been confirmed, and businesses should expect a period of legal and domestic approval before the provisions take effect.

What should businesses do now?

Businesses trading with the GCC should review their duty exposure and supply chains to identify where preferential access may apply once the agreement enters into force, including potential impacts on both exports and imports. Consideration should also be given to rules of origin and how these may affect eligibility for preferential tariffs. The Crowe UK customs team can support with assessing this exposure and planning next steps. For assistance, please contact Jamie Mcleod or your usual Crowe contact.

The EU Council has now agreed its position on strengthening EU CBAM ahead of negotiations with the European Parliament. In broad terms, the Council has backed a wider downstream scope, tougher anti-circumvention measures and a temporary exemption mechanism where the inclusion of a CBAM good causes severe harm to the EU internal market.

Why this matters

As currently designed, CBAM is focused mainly on a defined set of carbon-intensive basic goods, including iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. The latest reform is intended to address the risk that carbon leakage shifts into downstream goods manufactured outside the EU using those same materials. The Council text makes clear that the extension should focus in particular on steel- and aluminium-intensive goods facing the highest carbon leakage risk.

The downstream package has also continued to grow. On the basis of the draft lists currently in play, the December 2025 proposal was framed around 180 additional CN codes, while the June 2026 text now adds a further 200 additional CN codes. That underlines how materially the downstream package is expanding.

What kinds of goods are in view

The new additions go well beyond raw materials and semi-finished goods. They include products such as handsaws and saw blades, boilers, turbines, refrigerators and freezers, heat pumps, filters, fire extinguishers, cranes, fork-lift trucks, electric motors, generators, transformers, vehicle parts, trailers, metal furniture and prefabricated steel buildings.

That is consistent with the wider policy direction in the Council text, which says the scope should extend further down the value chain and that the Commission should continue assessing whether additional downstream goods should be brought into scope in future.

Anti-circumvention and evidence requirements are tightening

One of the clearest themes in the Council text is that anti-circumvention is becoming more central to CBAM design. The regulation gives the Commission greater scope to identify higher-risk goods or combinations of goods and origin and to require additional evidence where necessary. It also makes clear that the Commission and competent authorities may request evidence that imported goods were produced at the declared installation and at the declared time of production.

This is particularly relevant for more complex goods. For certain products, the Council text envisages evidence on the installation where raw material was first produced in liquid form and then cast into its first solid state – the so-called ‘melt and pour’ requirement. In practice, that points to a greater emphasis on upstream production evidence, including mill certificates or similar documentation, where actual emissions are being relied on.

The Council text also confirms that emissions from pre-consumer aluminium and steel scrap should be taken into account when calculating embedded emissions in goods, and that any claim that scrap is post-consumer scrap should be backed by robust and verifiable evidence.

A useful practical point for 2027 certificate calculations

There is also an important practical easement in the latest Council text. For 2027 quarterly certificate calculations, authorised CBAM declarants may use 2026 actual embedded emissions data. Before the 2026 annual declaration is submitted in 2027, that data may be used even where verification is still pending. For businesses managing certificate positions, that is a helpful clarification in the early years of the definitive regime.

Temporary exemption remains in play

Another important outcome is that the Council has retained a temporary exemption mechanism. This would allow goods to be removed temporarily from scope where their inclusion causes severe harm to the Union internal market in serious and unforeseen circumstances. The Council text keeps that mechanism but adds clearer conditions and guardrails around how it could be used. This is likely to be one of the more closely watched points in the next phase of the legislative process. 

What happens now

The next step is for the European Parliament to adopt its own position. Once that has happened, negotiations between the Council, Parliament and Commission can begin, with the stated aim of reaching agreement before the end of the year.

How Crowe can help

Crowe supports clients across the full CBAM lifecycle, from initial exposure assessment through to ongoing compliance delivery. This includes analysis of historic import patterns, product scope reviews, supply chain mapping, carbon cost modelling and identifying areas of concentrated risk, helping businesses understand potential exposure and inform appropriate mitigation strategies.

Alongside this, Crowe offers end-to-end managed CBAM support for businesses looking to outsource some or all of the compliance process. This can include supplier engagement, data collection, emissions calculations, reporting support and broader programme management, depending on the level of support required.

For more information, please contact Jamie Mcleod or your usual Crowe contact.

From 1 July 2026, the EU will remove the €150 duty exemption for low-value imports and introduce a temporary €3 customs duty per item.

The measure will apply until 1 July 2028, when the EU expects to move to a fuller customs duty model for low-value e-commerce imports.

What is changing?

The current duty relief for consignments up to €150 will be removed. In its place, a €3 duty will apply per declaration item for goods sold in distance sales and imported into the EU.

How the €3 duty works

The charge is not simply applied per parcel. It applies by declaration line / item, based on tariff classification and the way goods are declared.

For example:

• multiple identical goods declared under one item may attract one €3 charge
• goods falling under different classifications may trigger multiple €3 charges.

This makes classification, product descriptions and declaration structure more commercially important.

Why it matters

The EU is targeting the rapid growth in low-value imports and the perceived imbalance between non-EU e-commerce sellers and EU-based retailers.

For businesses selling low-value goods into the EU, this may affect:

• landed cost and margin
• pricing models
• customs data requirements
• product classification controls
• marketplace and fulfilment arrangements
• responsibility between sellers, platforms, carriers and customs representatives.

The duty is legally a customs duty, not a handling fee, and should not be confused with the separate EU handling fee proposals.

Although the €3 charge is temporary, the direction of travel is clear. The EU is moving away from simplified low-value duty relief and towards a more data-driven customs model.

Businesses selling into the EU should use this period to review their exposure, improve product data, assess classification accuracy and understand how their logistics providers intend to declare affected shipments.

On 23 June 2026, the UK Government confirmed its intention to introduce new measures to tackle deforestation in supply chains. This includes a proposed due diligence regime in Great Britain (GB) and confirmation that the EU Deforestation-free Regulation (EUDR) will apply in Northern Ireland (NI).

These changes will increase supply chain transparency requirements for a range of commonly traded commodities, requiring impacted businesses to undertake upstream due diligence to ensure products are deforestation-free.

Great Britain (proposed regime)

The UK Government plans to introduce new rules under the Environment Act 2021, requiring businesses with turnover above £1 million to carry out due diligence on “forest risk commodities”, broadly aligning with the scope of the EUDR.

In-scope commodities are expected to include wood products, cattle, cocoa, coffee, palm oil, rubber and soy, along with certain derived products. As a result, a wide range of UK businesses are likely to be captured by these measures.

Under these measures, UK businesses will need to establish a due diligence system for imported goods, maintain records and report on compliance which will include verifying that goods are produced in line with local laws as well as collecting granular data (i.e., geolocation). 

It is expected that the UK Government will run a consultation period later this year to allow UK businesses to input and shape the measure, with implementation at some point in 2027. 

Northern Ireland (EUDR)

As part of the announcement, the UK Government also confirmed that goods entering NI will be subject to the new EUDR from 30 December 2026 (medium and large businesses), reflecting NI’s continued alignment with EU rules under the Windsor Framework.

This means that impacted NI businesses, and those moving goods into NI, will need to comply with EUDR requirements. Businesses must be able to demonstrate that goods are deforestation-free and submit due diligence statements before placing products on the market.

With just over five months to EUDR implementation, businesses need to move quickly to ensure that they can comply with the regulations if moving goods into NI, or the wider EU market.  

What businesses should do now?

While deforestation regulations have been delayed multiple times in the EU, we now expect implementation to occur at the end of this year and the UK to follow with an equivalent measure shortly after, so businesses undertaking immediate preparation will be best placed to comply from Day One: 

• assess exposure to forest risk commodities in supply chains, capturing commodity codes, origin and supply chain flows
• review systems to ensure required data elements are fully available or can be obtained (including geolocation)
• engage suppliers early on traceability and evidence requirements
• monitor UK developments following the consultation period and prioritise GB-NI and GB-EU flows to ensure EUDR readiness for the end of 2026. 

Crowe’s Customs and International Trade team can support businesses with better understanding the new regulations, assessing whether your supply chains will be impacted and how to respond so reach out to Jamie Mcleod or your usual Crowe contact for more insights. 

The UK Trade Remedies Authority (TRA) has published its intended recommendation to extend the existing anti-dumping measure on imports of wire rod from China for a further five years. If adopted, the measure would continue until 30 January 2031, with duty rates remaining unchanged at 7.9% for the Valin Group and 24% for all other Chinese exporters.

Wire rod is used in a range of downstream applications, including construction materials, vehicle components and general industrial and engineering products. The measure applies to certain hot-rolled bars and rods in irregularly wound coils of iron, non-alloy steel or alloy steel, other than stainless steel, originating in China.

The TRA’s review concluded that, although imports from China into the UK have been negligible during the review period, dumping and injury to UK industry would be likely to recur if the measure expired. The TRA pointed to China’s significant wire rod export capacity, falling global export prices, and the vulnerability of UK producers as key factors in its assessment.

The TRA also found that extending the measure would meet the UK’s economic interest test. While maintaining the duty may increase costs for downstream users, the TRA considered that this was outweighed by the benefit of reducing the risk of renewed injury to UK producers and supporting a more stable domestic supply base.

Interested parties have until 16 July 2026 to comment on the Statement of Essential Facts before the TRA makes its final recommendation to the Secretary of State.

What businesses should do now

Businesses importing wire rod, or purchasing Chinese-origin wire rod through their supply chain, should review whether their products may fall within scope and ensure that the continued duty cost is reflected in landed cost calculations, pricing and sourcing decisions.

This is also a useful reminder that UK trade remedy measures remain an important part of customs cost management. Businesses should keep existing measures and expiry reviews under review, particularly where additional duties could affect supply chain strategy or commercial margins.

Crowe’s Customs and International Trade team can support businesses with product scope reviews, customs data analysis and assessing the commercial impact of trade remedy measures.

The UK and India have confirmed that the UK-India Free Trade Agreement will enter into force on 15 July 2026, giving businesses a short window to prepare before they can start trading under the new terms. The Government has described the agreement as the most comprehensive trade deal India has ever brought into force, with expected long-term benefits including increased bilateral trade and significant tariff reductions.

For UK exporters, the agreement creates opportunities in sectors such as whisky, automotive, cosmetics, medical devices and food and drink, with some tariffs being reduced immediately and others phased down over time.

However, the agreement is also highly relevant for UK importers. The UK will reduce tariffs on a range of Indian-origin goods, including clothing, footwear and some food products. This could create meaningful duty saving opportunities for businesses importing from India, particularly in retail and consumer goods supply chains.

New origin evidence requirements

Businesses should not assume that tariff reductions will apply automatically. Preferential tariff treatment will depend on the goods meeting the relevant rules of origin and the correct evidence being held.

This is particularly important because the evidence requirements under the UK-India FTA are different from those businesses may currently use under DCTS. In particular, for imports of Indian-origin goods, neither a Form A nor a standard DCTS-style origin declaration will be sufficient to claim preference under the FTA.

Instead, preference may be claimed using one of the agreed forms of proof of origin, including an origin declaration completed by the exporter or producer, a certificate of origin issued by an issuing authority, or importer’s knowledge. Where importer’s knowledge is used, the importer must hold sufficient supporting evidence, and this should be approached carefully in practice.

What businesses should do now

With the agreement taking effect on 15 July 2026, businesses should now review both their export and import flows with India.

For importers, the key actions are to:

• identify Indian-origin goods that may benefit from reduced UK duty rates
• check whether those goods meet the relevant product-specific rules of origin
• engage with Indian suppliers on the new origin evidence requirements
• update internal guidance so teams do not continue relying on DCTS evidence where an FTA preference claim is intended
• ensure customs agents are given clear instructions on when preference should, and should not, be claimed.

The opportunity is significant, but it will not be automatic. Businesses that want to benefit from the agreement from day one will need to have the right origin analysis, supplier evidence and customs declaration processes in place.

To discuss the duty saving opportunities under the UK-India Free Trade Agreement, or to review whether your imports or exports may qualify for preferential treatment, please contact Jamie Mcleod or your usual Crowe contact.

The UK’s new steel trade measure comes into force on 1 July 2026, replacing the current steel safeguard regime.

For importers, the headline position is clear: there will be less tariff-free quota available, and the cost of importing above quota will be much higher. The government has confirmed that overall tariff-free quota volumes will reduce by around 51% compared with the existing safeguard measure, with out-of-quota imports subject to a 50% duty.

That is a significant change from the current 25% safeguard duty and means quota management will become a much more important commercial issue for businesses importing steel products into the UK.

The finalised measure applies to 20 steel product categories, focused on products the government considers capable of being made in the UK. These include a range of flat, long and tubular steel products, including hot-rolled sheets and strips, metallic coated sheets, merchant bars, rebars, hollow sections and welded tubes.

Our analysis of recent import volumes against the finalised quota levels suggests that quota pressure is likely to be significant in a number of categories. In some cases, 2025 import volumes were materially higher than the new annual quota levels, particularly for hot-rolled products, merchant bars, rebars, angles and sections, hollow sections and welded tubes. This means quota exhaustion is not a remote risk; for some products and origins, it could become a regular feature of the new regime.

What changed from the proposed measure?

The final version is not identical to the provisional position published earlier in the year.

Most notably, the total quota volume is now approximately 3.2 million tonnes, which remains significantly below the current safeguard regime but is around 21% higher than the previously published provisional volumes. In practical terms, that slightly eases the position in some areas, but it does not remove the overall tightening of the regime.

There have also been scope changes. The government has removed 11 commodity codes and added two codes following further industry engagement.

The practical point is that importers should not rely on earlier scope assessments. Commodity codes should be checked against the final list before the measure starts.

How the quota system will operate

The measure will operate through quarterly tariff rate quotas, with access granted by HMRC on a first come, first served basis. Unused quota may roll forward into the next quarter within the same quota year, but it will not carry over into the following quota year.

This makes timing important. Where quota is available, imports can enter without the additional duty. Where quota is exhausted, the 50% duty applies to the value of the goods before other import duties are applied.

There is also a limited transitional arrangement. Relevant goods contracted before 14 March 2026 and imported between 1 July and 30 September 2026 should be exempt from the 50% out-of-quota duty and should not count towards quota volumes, subject to evidence requirements.

For Category one, there is also a separate authorised use quota for certain downstream processing. Unlike the main quota structure, this includes a 40% country cap for any individual country or territory.

Ukraine-origin steel goods are excluded from the new measure, with existing preferential arrangements continuing to apply, subject to the relevant rules of origin being met.

What should importers be doing now?

Importers should now:

• Check scope and classification – confirm whether products fall within the final commodity code list and make sure classifications are supported by technical evidence.
• Model exposure – compare expected imports against the final quota levels by category, origin and quarter.
• Review quota claim governance – agree who decides when quota should be claimed, how customs agents are instructed, and how supporting evidence is retained.
• Review contracts and Incoterms – check who bears the cost if goods arrive after quota has been exhausted.
• Consider special procedures – assess whether customs warehousing, inward processing or authorised use could help manage exposure where goods are stored, processed, re-exported or used in qualifying downstream activity.

The final measure is less restrictive than the earlier provisional position, but it still represents a major tightening of the UK steel import regime.

From 1 July 2026, importers will need to manage steel imports much more actively, with closer control over quota availability, declaration accuracy, shipment timing and contractual duty risk. Businesses that understand their exposure early will be better placed to manage cost, avoid disruption and make informed sourcing decisions.

The European Union has confirmed the final details of its new steel import regime, which applies from 1 July 2026 and replaces the existing steel safeguard measures.

The new regime significantly reduces the volume of steel that can enter the EU duty-free. Overall tariff-free quota volumes will fall to 18.3 million tonnes per year, which the Commission says is an average reduction of around 47% compared with the previous safeguard quotas. Any imports outside quota will be subject to an additional 50% duty.

The new framework is made up of two linked regulations:

• Regulation (EU) 2026/1384, which establishes the new steel import measure; and
• Implementing Regulation (EU) 2026/1457, which sets out how the quota volumes are distributed between countries and product categories.

Why has the EU introduced the new measure?

The EU’s position is that global steel overcapacity remains at unsustainable levels and is driving trade diversion into the EU market.

The Commission has pointed to global overcapacity of more than 620 million tonnes, forecast to rise to 721 million tonnes, alongside increasing restrictions in other major markets. The EU has therefore opted for a tougher tariff quota system to protect its steel industry following the expiry of the previous safeguard measures.

Imports within quota can continue to enter duty-free, but once quota is exhausted, the 50% additional duty is intended to act as a significant deterrent to further imports.

FTA partners receive better treatment

A key feature of the final system is that the EU has given more favourable treatment to countries with free trade agreements.

The Commission has confirmed that half of the total 18.3 million tonne quota has been reserved exclusively for FTA partners, with the other half available to all trading partners, including FTA partners, on a non-discriminatory basis.

Many FTA partners have also received secure country-specific allocations based on historic trade flows. This means that while the average quota reduction across the regime is around 47%, many FTA partners are expected to see a materially smaller reduction in market access.

UK exporters: a better outcome than the headline figures suggest

The UK appears to have secured a relatively strong outcome.

The UK has received country-specific quota allocations across a broad range of commercially important product categories, including:

• hot rolled product
• cold rolled products
• metallic coated products
• tin mill products
• merchant bars
• wire rod
• hollow sections; and
• welded pipes.

This matters because UK exporters are not simply left to compete in general residual quotas. In many categories, the UK has its own allocation and may also benefit from wider FTA quota mechanisms once country-specific quota volumes are exhausted.

The practical takeaway is that the UK has not avoided the impact of the new EU regime, but it has been treated more favourably than the headline 47% reduction might suggest.

Northern Ireland arrangements preserved

The regulations also preserve specific arrangements for movements of steel of UK origin from Great Britain into Northern Ireland.

The main regulation amends the existing EU quota framework to ensure that qualifying UK-origin steel moved directly from Great Britain to Northern Ireland can continue to benefit from relevant EU tariff rate quota treatment. The implementing regulation then provides dedicated quota lines for certain GB-to-NI movements.

This is important for businesses relying on GB-to-NI steel supply chains and reflects the EU’s commitments under the Windsor Framework.

Melt and pour evidence will be required

The new regulation also introduces a new compliance requirement around melt and pour.

From 1 October 2026, importers will need to provide verifiable evidence of the country where the raw steel or iron was first produced in liquid form and cast into its first solid state. The regulation refers to evidence such as a mill test certificate.

At this stage, melt and pour is an evidence and monitoring requirement rather than the basis for quota eligibility. However, the Commission must assess by 30 June 2028 whether the country of melt and pour should become the basis for accessing quotas in future.

Importers should therefore start engaging with suppliers now to ensure they can obtain the required documentation.

What businesses should do now

Businesses importing steel into the EU, exporting steel from the UK to the EU, or moving steel from Great Britain to Northern Ireland should now:

• map products to the relevant EU steel category
• check whether the country of origin has a country-specific quota
• assess whether FTA quota access is available
• compare forecast volumes against available quota
• factor in the potential cost of the 50% out-of-quota duty
• prepare for melt and pour evidence requirements from 1 October 2026; and
• review whether existing supply chains remain commercially viable under the new quota structure.

Final thought

The new EU regime is more restrictive, more expensive and more complex than the previous safeguard system. However, the final allocation confirms that the EU has sought to soften the impact for FTA partners, including the UK.

For UK steel exporters, the position is therefore mixed but more positive than initially feared. Market access will be tighter, but the UK has secured meaningful quota coverage across a wide range of key categories, alongside preserved arrangements for Northern Ireland.

Businesses should now move quickly from policy monitoring to product-level impact assessment. The commercial impact will depend not only on whether goods are in scope, but on the specific product category, origin, available quota, timing of imports and supporting documentation.

For more information, please contact your usual Crowe contact.

From 1 July 2026, the UK is introducing a significantly tighter steel safeguard regime. For many businesses, the practical impact is straightforward: more imports are likely to fall outside tariff free quota, and that means higher duty costs and greater pricing volatility.

The Government’s headline position is an overall 60% reduction in tariff free quota volumes across the regime. The reduction will not be uniform: some categories are expected to see much deeper cuts, meaning the impact will vary sharply by product type, origin and timing. Final detail is still expected in the coming weeks and categories, commodity codes and quota volumes may change, but businesses should not wait for the final notice before preparing.

In a tighter quota environment, safeguards become an operational and commercial issue, not a technical footnote:

• Quota can run out quickly on a market-wide basis.
• If quota is unavailable (or not claimed correctly), importers can face significant unplanned duty.
• Errors in classification or origin can push goods into the wrong quota pool, or remove quota access entirely.
• Where steel sits inside fixed price projects or long lead procurement, duty shocks can land directly on margin.

What businesses should do now

1. Confirm what you import (scope)
Start by identifying the steel inputs you import and tightening the basics: ensure the commodity code and origin being used are correct, consistent and aligned across suppliers, your internal systems and your broker instructions.

2. Put quota management under control
Make “claim quota where available” the default position on all relevant entries, and assign clear internal ownership for keeping your scope and category mapping up to date as the final measure is published, checking that quota has been correctly claimed and accepted, and escalating quickly where quota is missed, rejected or closed.

3. Build a simple commercial contingency plan
Agree in advance how the business will respond if quota becomes constrained, so decisions are fast and consistent. This should cover practical levers such as adjusting shipment timing where feasible, splitting shipments or managing declaration timing, exploring alternative sourcing, and ensuring customer pricing and contracts appropriately address duty volatility.

Customs special procedures can help

Where exposure is material, customs special procedures should be part of the toolkit:

• Customs Warehousing can help by holding goods under customs control and releasing them when quota is available (or avoiding the duty altogether if goods are re-exported rather than released to UK free circulation).
• Inward Processing may be relevant where imported steel is used in manufacturing and the output is exported, potentially avoiding safeguard duty on qualifying re-export flows (subject to authorisation and robust controls).

These are not quick fixes in late June. If they may be relevant, feasibility work should start now.

What to watch next

Over the coming weeks, businesses should monitor confirmation of:

• final scope and category mapping (commodity codes)
• final quota volumes and allocation mechanics
• operational guidance that will govern how quota is claimed and administered in practice

How Crowe can help

Crowe can support with a focused readiness approach covering: classification and origin assurance, safeguards exposure mapping using import data, quota governance and broker instruction design, and feasibility assessments and implementation for special procedures (including customs warehousing and inward processing).

For more information, please contact Jamie Mcleod or your usual Crowe contact.

The European Commission has issued draft rules on how carbon costs paid outside the EU may reduce an EU importer’s CBAM certificate requirement. The consultation is open until 10 June 2026. Even if the detail changes, the practical direction is clear: CBAM cost forecasting will increasingly depend on evidence quality and supplier readiness, not just headline carbon prices.

The draft does not pre approve specific countries or schemes but instead sets out the conditions and evidence that must be met. That shifts the focus to what suppliers can prove in practice, and how reliably importers can use that information in their CBAM models.

Why this matters for cost forecasting

Most businesses now need to model CBAM using two lanes:

• “Actuals” lane (lower cost if you can evidence it): your supplier provides verified, installation‑level emissions and an evidence pack showing what carbon price was actually paid.
• “Defaults” lane (higher risk / higher uncertainty): you fall back on default emissions and default carbon price assumptions, which can produce a materially higher CBAM outcome.

That is why businesses should move away from single number estimates and build best / expected / worst case scenarios. For many importers, a sensible starting worst case is: default emissions values and limited usable carbon price deduction.

What this means for practical compliance

The draft pushes CBAM into a familiar trade compliance space: controlled processes, consistent product mapping, and audit ready files.

It also reinforces that this is not just a calculation exercise. To use the “actuals” lane, suppliers will need verification and independent assurance over the underlying information. In practical terms, the ability to evidence carbon price relief will depend on whether suppliers can produce documentation that stands up to third party review, and whether the importer can rely on it in their CBAM planning.

Critically, any “carbon price paid” deduction is based on the net cost after reliefs and compensation (for example, free allocation and rebates). In plain terms: headline ETS prices are not enough. Importers will need the “net paid” story, supported by evidence that can be checked.

Finally, businesses should note the timing risk: although the draft has arrived late, it is intended to apply from 1 January 2026. That adds to the administrative burden for operators and importers already working to tight verification and reporting timelines.

UK exporters: important context 

For UK exporters, this is commercial as well as compliance. EU customers will increasingly ask: can you support the evidence needed to reduce our CBAM cost? If not, they will assume a higher CBAM exposure and build that into pricing and supplier decisions.

This sits alongside a wider strategic issue: UK–EU ETS linkage negotiations are ongoing. Until linkage is agreed and implemented, UK exporters should plan on CBAM remaining part of the conversation with EU buyers and should not assume carbon costs will be automatically recognised in a way that protects competitiveness.

What businesses should do now

EU importers should:

• Model worst case now: create a CBAM cost range per product and supplier (best / expected / worst), and use that range in budgeting and pricing decisions.
• Segment suppliers: identify who can support the “actuals” lane versus who will force you into defaults.
• Build a repeatable evidence pack process: treat CBAM data like origin or valuation support - controlled inputs, clear ownership, and document retention.
• Put it into procurement: make CBAM data delivery, timing, and cooperation with assurance checks part of supplier terms, not an annual scramble.

Note for operators and distributors: these importer actions depend on what you can provide, so suppliers who can deliver verified emissions data and a clear “net carbon price paid” evidence pack will help EU customers forecast more accurately and avoid default (higher) assumptions.

For more information, please contact Jamie Mcleod or your usual Crowe contact.

On 28 April 2026, the European Parliament voted in favour of the EU’s revised Generalised Scheme of Preferences (GSP). The updated scheme is expected to apply from 1 January 2027 and run for the following decade. 

GSP remains the EU’s unilateral preference regime that grants reduced or zero tariffs for eligible goods originating in developing and least developed countries.

What stays the same

The overall structure is retained, with three arrangements:

• Standard GSP (reduced/zero tariffs across a broad range of tariff lines for eligible developing countries)
• GSP+ (enhanced preferences for eligible countries that meet additional sustainability and governance conditions)
• Everything But Arms (EBA) (duty-free, quota-free access for least developed countries, except arms and ammunition)

There is no fundamental change to product coverage, and the reform does not introduce a new rules of origin model. Traders should still expect preference claims to depend on correct classification, origin determination, and evidence.

What changes from 2027

• EBA becomes open-ended. EBA will have no expiry date, providing greater long-term predictability for supply chains sourcing from least developed countries.
• Stronger conditions and enforceability. The revised GSP tightens the link between preferences and compliance with international standards, including human rights, labour rights, climate and environment, and good governance. Monitoring and transparency are strengthened, and a new accelerated “urgent withdrawal” route is introduced for exceptionally grave cases.
• GSP+ reapplication. Current GSP+ beneficiaries will need to reapply under the new rules. A two-year grace period runs to the end of 2028, during which existing beneficiaries are expected to continue to benefit while they prepare reapplications. Applications will be supported by an implementation plan covering the expanded set of relevant international conventions.
• More robust safeguards. The reform reinforces tools to protect EU industry and sensitive agricultural sectors. This includes streamlined safeguard and surveillance mechanisms and a new automatic safeguard for rice, which can suspend preferential treatment where imports surge materially above historic levels and introduce a tariff-rate quota approach thereafter.

What businesses should do now

Most businesses will not need to change their approach to determining origin, but they should take the opportunity to confirm where they rely on GSP preferences to manage landed costs, whether they have appropriate documentation and a consistent internal process to support preference claims, and what the commercial impact would be if preferences were suspended or safeguards applied. 

Where there is uncertainty, a short, targeted review can quickly identify exposure, highlight weaknesses in controls and evidence, and set out practical remedial actions.

For more information, please contact Jamie Mcleod or your usual Crowe contact.

After many years in negotiation, the EU has begun provisional application of the EU–Mercosur Interim Trade Agreement (iTA) from 1 May 2026. This is the point at which EU importers can start accessing preferential duty rates on qualifying goods imported from Argentina, Brazil, Paraguay and Uruguay, provided the agreement’s rules of origin and origin procedures are met. Provisional application creates an immediate opportunity, but it also means businesses need to get the mechanics of preference claims right from day one, particularly around evidence, broker instructions and record keeping.

What changes for EU importers

The iTA allows eligible goods originating in Mercosur to enter the EU at preferential rates set out in the tariff schedule. In practice, the key issue is not the headline tariff cuts but whether you can evidence preferential origin in a way that withstands customs scrutiny. Preference will only be available where the importer can support the claim with the correct origin proof, and where the goods meet the agreement’s origin rules (including product-specific processing requirements and transport conditions).

When can preference be claimed?

EU importers can claim preferential treatment at the time of importation by making the claim in the customs declaration for release for free circulation. If preference is not claimed at clearance, the agreement provides a route to claim retrospectively within two years of importation, subject to having valid origin evidence.

There is also a transitional measure for “pipeline” shipments. Where goods were in transit or held in temporary storage (including bonded warehouses or free zones) on the date provisional application started, preferential treatment can still be applied provided the proof of origin is submitted within six months of the start date, and any required evidence supporting the transport/non alteration conditions can be produced if requested.

What proof of origin is required?

The iTA is built around a statement on origin model. In practice, EU importers should expect to receive a statement on origin placed on an invoice or other commercial document that clearly identifies the goods shipped. The statement must follow the prescribed text and should not be altered. A statement on origin is generally valid for 12 months from the date it is made out and should be submitted within that period. Late presentation may be accepted only in limited circumstances, and specific rules can apply where goods are presented within the validity period and placed under certain special procedures before release to free circulation.

Rules of origin: key features to understand early

The origin framework follows a familiar structure: goods are originating if they are wholly obtained, made exclusively from originating materials, or sufficiently worked/processed in the exporting Party in line with the product-specific rules. Two areas commonly cause issues during implementation. First, cumulation is limited: only bilateral cumulation applies between the EU and Mercosur, so wider cumulation assumptions should not be built into origin assessments. 

Second, transport/non alteration conditions still matter: storage or splitting in third countries may be possible, but importers should be prepared to evidence compliance if customs requests it.

What EU importers should do now (high level)

If you import goods into the EU from Mercosur, the quickest way to capture benefit and reduce risk is to run a short readiness check focused on: which product lines are eligible and where the savings are material; whether suppliers can provide compliant origin statements consistently and on time; whether broker instructions and declaration set-up support correct preference claims; and whether internal controls ensure that origin statements are retained, linked to shipments, and can be produced quickly if a claim is verified.

Crowe can support with a targeted review to quantify the opportunity, identify gaps in origin evidence and governance, and put in place a practical process so preference claims are both realisable and defensible as volumes scale.

For more information, please contact Jamie Mcleod or your usual Crowe contact.

HMRC has updated the process for submitting Post Clearance Amendments (PCAs) on import declarations. The change is practical: businesses should expect HMRC to request a more complete “evidence pack” as part of the submission, and incomplete or poorly supported requests are more likely to be delayed or rejected.

What has changed

Under the updated process, PCA submissions may now require supporting evidence up front, including:

• Movement Reference Number (MRN) or entry number.
• New importer name, address and EORI.
• Evidence of empowerment for creation of the original declaration.
• A clear explanation of the error and why it occurred.
• The commercial invoice.

HMRC’s position on appropriate use

HMRC has reinforced that PCAs cannot be used to change the facts of a movement after the event. They are intended only to correct genuine errors. HMRC has also warned that incorrect submissions or deliberate non-compliance may result in rejection and could lead to further compliance action.

Avoid delays

HMRC has indicated that customers with outstanding PCA requests will be contacted with an update. Businesses have also been asked not to submit duplicate requests unless specifically requested, as duplicates may cause delays.

What you should do now

If you anticipate PCA activity, ensure you can assemble the required evidence quickly and that internal approvals, broker instructions and record-keeping support a consistent narrative of what went wrong and why the correction is appropriate. If you are unsure whether a PCA is the right route, or what evidence HMRC will expect in your circumstances, please get in touch.

For more information, please contact Jamie Mcleod or your usual Crowe contact.

The EU’s new steel trade measure has moved a step closer. Following political agreement between the European Parliament and the Council in April 2026, the European Parliament adopted the agreed text on 19 May 2026. The measure is intended to replace the current EU steel safeguard regime, which expires on 30 June 2026, with entry into force still targeted for 1 July 2026 once the remaining formal steps are completed.

What is changing?

The new regime significantly tightens market access for steel imports into the EU:

• Lower tariff-rate quotas (TRQs): duty-free imports will be capped at 18.3 million tonnes per year, around 47% lower than 2024 quota levels
• Higher out-of-quota duty: imports above quota will face a 50% customs duty, up from 25% under the current safeguard
• Broader product scope: the agreed text applies to 30 categories of steel products, with the Commission required to carry out an early review within six months on whether the scope should be extended further, followed by another review within 12 months and then every two years
• Quarterly flexibility in year one: unused quota volumes may be carried forward from one quarter to the next during the first year, with future treatment to be determined by the Commission

In practical terms, this means significantly less steel will be able to enter the EU duty-free, and businesses are more likely to incur materially higher duty costs once quotas are exhausted.

New “melt and pour” requirement

Another key development is the introduction of a “melt and pour” requirement. This identifies the country in which the steel was first produced in liquid form and cast into its first solid shape, with the aim of improving traceability and reducing circumvention through further processing in third countries.

The agreed framework goes beyond a simple documentary requirement. The country of melt and pour will be one of the factors considered when allocating quotas to third countries, and the Commission must assess within two years whether it should become the primary basis for quota allocation.

The measure applies to imports from all countries except EEA countries for quota and duty purposes, although EEA-origin goods will still be subject to the melt and pour requirement.

Why this matters

These changes are being driven by sustained global steel overcapacity and the resulting pressure on EU markets. The objective is to protect EU steelmaking capacity, preserve jobs and support longer-term industrial and decarbonisation objectives.

For steel importers and downstream users, the regime will become more restrictive and operationally more demanding. Reduced quotas and a higher duty rate increase landed cost exposure, while the melt and pour requirement will require stronger supply chain visibility and supporting documentation. Businesses should also monitor the forthcoming implementing acts covering country allocation of quotas and the evidential requirements for compliance.

For help assessing the impact of the new rules and preparing for the changes from 1 July 2026, please contact Jamie Mcleod or your usual Crowe contact.

The UK Government has today published the second of two tranches of draft secondary legislation for the UK Carbon Border Adjustment Mechanism (CBAM), alongside supporting notices that will have force of law.

This marks another significant step towards UK CBAM implementation from 1 January 2027, moving the regime from policy design into detailed operational legislation.

What has been published?

The draft secondary legislation sets out key administrative and technical requirements for UK CBAM, including provisions covering:

• Embodied emissions
• Monitoring, reporting and verification of emissions data
• Systems and methodological boundaries for emissions calculations

Alongside the legislation and notices, the Government has also published a CBAM System Boundaries document, which provides further clarity on how emissions should be assessed across covered goods and production processes.

The draft legislation, notices and system boundaries document are all available via the Government’s consultation publication.

Purpose of the technical consultation

This is a technical consultation, intended to ensure the secondary legislation delivers the policy correctly and effectively in practice. It is not a further consultation on CBAM policy design.

The consultation seeks practical feedback on how the legislation and supporting notices operate, particularly from those who will be required to comply with the regime.

For many businesses, this is one of the final opportunities to influence the workability and precision of the UK CBAM legislative framework before implementation.

How to respond

Responses to the consultation should be submitted by 11:59pm on 21 May 2026.

• Email responses to: [email protected]
• Subject line: “CBAM technical consultation response”
• Responses should clearly reference the relevant parts of the draft legislation and the System Boundaries document

Background: earlier consultation

The first tranche of draft secondary legislation was published on 10 February 2026, also for a six week technical consultation, alongside draft notices with legal effect. That earlier publication set out the high level legislative framework for UK CBAM. Today’s release builds on this by addressing technical administration, data and verification requirements.

Further information on the February consultation, including an overview of the legislation, remains available via HMRC.

Updated CBAM policy summary

Alongside the draft legislation, the Government has also published an updated CBAM Policy Summary. This document is intended to help businesses understand:

• How UK CBAM is structured under the primary legislation
• How draft secondary legislation will operate in practice
• Which businesses and supply chains are likely to be affected

The updated summary is particularly useful for importers beginning to assess governance, data and systems readiness ahead of 2027.

What businesses should consider now

With implementation less than twelve months away, businesses impacted by UK CBAM should be considering:

• Whether their imports fall within CBAM scope
• How embodied emissions data will be sourced, verified and retained
• Responsibility splits between importers, agents and suppliers
• Alignment between UK CBAM and EU CBAM processes
• Forward looking pricing and contract impacts

Engaging with this consultation provides an opportunity to address operational complexity, ambiguity or unintended consequences before the legislation is finalised.

For further discussion on how these developments may affect your business, please contact Jamie Mcleod or your usual Crowe contact.

On 24 March 2026, the European Union and Australia concluded negotiations on a long awaited EU–Australia Free Trade Agreement (FTA), ending almost eight years of talks. The agreement sits alongside a broader push by the EU to diversify trade relationships and reinforce rules based trade at a time of ongoing geopolitical and tariff uncertainty.

While ratification is still required, businesses trading between the EU and Australia should begin preparing for significant changes to tariffs, origin rules and customs compliance.

Headline outcomes

The agreement will remove duties on nearly all EU exports to Australia, with the vast majority becoming tariff free on entry into force and the remainder phased out over several years. In parallel, almost all Australian goods exports to the EU will become duty free once fully implemented. For importers and exporters, this will materially affect duty exposure, landed costs and pricing structures.

Sensitive agricultural sectors are addressed through tariff rate quotas (TRQs) rather than full liberalisation. Expanded quotas apply to products such as beef, sheep and goat meat, sugar and selected dairy products, with staged implementation over time. Businesses importing these goods will need to actively manage quota availability and ensure accurate customs declarations to avoid unexpected duty liabilities.

Rules of Origin

Preferential tariff treatment under the FTA will only apply where detailed rules of origin are met. Product specific origin rules cover a wide range of sectors including manufacturing, chemicals, machinery, automotive components and food products.

This places renewed importance on:

• accurate tariff classification
• robust origin analysis and supplier declarations
• ongoing controls over non originating inputs

Origin compliance is likely to be a key focus of customs audits once the agreement is operational.

Customs simplification

The agreement includes commitments aimed at streamlining customs procedures, including greater use of electronic documentation, clearer advance rulings and increased transparency. While these measures should support faster border clearance, they also raise expectations around data accuracy and record keeping.

What happens next?

Before the agreement takes effect, it must be formally adopted and ratified by both the EU and Australia. Entry into force is therefore not immediate, but businesses should expect implementation planning during 2026.

Businesses trading with Australia should now consider:

• reviewing supply chains against new origin rules
• updating duty and landed cost models
• preparing systems and procedures to support preferential claims
• assessing quota exposure for sensitive products
• training teams on FTA specific customs requirements.

How we can help

Crowe’s Customs and International Trade specialists can support businesses with FTA impact assessments, origin modelling, preference compliance, customs data reviews and audit readiness, helping ensure organisations are well positioned to benefit from the EU–Australia FTA while managing compliance risk.

To discuss what these developments mean for your business, please contact Jamie Mcleod or your usual Crowe contact.

The UK Government has published further guidance on the forthcoming UK–EU Sanitary and Phytosanitary (SPS) Agreement, intended to make agri food trade easier, cheaper and more predictable. 

The agreement forms part of the wider EU–UK reset and is designed to reduce SPS related friction for movements between Great Britain (GB) and the EU, while also supporting smoother flows from GB to Northern Ireland. Government guidance indicates an intended implementation in mid 2027, with transitional arrangements for sectors facing more complex changes.

What is the SPS Agreement?

Under the proposed model, the UK would align with EU SPS rules across a defined scope, creating a Common SPS Area for SPS purposes. This is intended to reduce the need for routine SPS certification and physical border checks, with controls increasingly managed through ongoing compliance and systems rather than systematic intervention at the border.

The agreement is focused on SPS measures only. It does not remove wider post Brexit requirements such as customs declarations, VAT formalities or rules of origin.

What is in scope?

The agreement covers a broad range of agri food and related rules, including:

• food and feed safety and hygiene
• animal and plant health
• food labelling, composition, traceability and nutrition related measures
• organics and agri food marketing standards
• pesticides, biocides and relevant aspects of veterinary medicines.

While divergence from EU rules has often been limited since EU exit, some businesses may need to adjust where UK and EU requirements have moved apart.

What is expected to change?

Based on current guidance, the agreement is expected to deliver significant simplification for SPS movements between GB and the EU, including:

• removal of Export Health Certificates and phytosanitary certification for in scope trade
• removal of routine SPS border checks on EU movements
• reduced pre notification and intervention requirements
• resumption of certain previously restricted trade, with products such as fresh sausages and burgers, certain shellfish and seed potatoes regaining access.

These changes are expected to reduce costs, improve transit times and increase supply chain predictability for SPS goods moving in both directions.

Timing and transition

For many traders, this agreement represents the most significant reduction in SPS related border friction since 2021. Mid 2027 has been marked as the earliest realistic implementation date.

Businesses should expect transitional measures, with DEFRA explicitly acknowledging that some sectors will require additional time to adjust.

The SPS Agreement will require updates to border and compliance systems as certification processes shift from paper based controls towards more streamlined, digital checks. Traders and intermediaries should expect changes to official control systems, document codes and broader data requirements as the UK aligns with EU SPS frameworks.

What do traders need to do?

• Review the proposed SPS scope – identify areas where your business has diverged from EU requirements.
• Assess operational impacts – labelling, documentation, supplier compliance, logistics, NI routes.
• Provide feedback on DEFRA's 'Call For Information' – particularly on transition periods, certification needs and implementation challenges. The window is now open and closes on 26 April 2026.

Crowe’s Customs and International Trade team can support you in understanding how the SPS Agreement and forthcoming border system changes may affect your supply chain, compliance processes and future readiness. 

To discuss what these developments mean for your business, please contact Jamie Mcleod or your usual Crowe contact.

The UK Steel Strategy, published 19 March 2026, sets out a comprehensive industrial and trade framework designed to reverse long‑term decline, strengthen national security, and position the UK as a global leader in clean, modern steel production. It is backed by up to £2.5 billion in government investment, channelled largely through the National Wealth Fund.

At its core, the strategy introduces major new trade measures to protect UK steelmaking from cheap imports, particularly in the context of global overcapacity. A target has been set to increase UK-produced steel to account for 50% of total domestic usage.

Steel safeguards – what are they?

Steel safeguards are a trade defence measure that place tariff‑rate quotas (TRQs) on specific steel products. Imports within quota enter tariff‑free, while imports above quota face an additional tariff, which is currently 25%. They exist to prevent sudden surges of cheap imports (often diverted from other markets) causing serious damage to domestic producers. 

The UK adopted these rules post‑Brexit, continuing the EU’s approach, and they have been kept under regular review because of persistent global overcapacity and the ongoing risk of import diversion. The new strategy replaces the UK’s existing steel safeguards, which expire on 30 June 2026 and cannot be legally extended further.

What is changing?

Steel quota availability 

• From 1 July 2026, the UK will reduce the existing steel quota availability by up to 60% compared to current levels.
• These steel quotas will be applied specifically to steel products which are capable of being produced in the UK.

Steel safeguard duty amount

• For imports which fall outside of the steel quotas, imports will face a 50% duty rate – double the existing 25% duty rate.
• This brings the UK in line with similar measures in the EU, US, and Canada.

Who do these measures affect?

UK steel producers

• Direct beneficiaries, gaining significantly stronger protection against cheap imports.
• Supported through finance and the shift toward electric arc furnaces and low‑carbon production methods.

Downstream manufacturers

• Will face higher input costs on steel which does benefit from being imported tariff-free using the already more limited quotas.
• Some exemptions will remain for steel products which are not produced in the UK, but these appear narrower than importers hoped.

Steel exporters to the UK

• Particularly affected if exporting categories already produced domestically in the UK.
• Will see restricted access and likely less demand.

Key things to be aware of

The new framework represents a substantial tightening of the UK’s import controls. With quota availability being drastically cut, competition for tariff free access will intensify, and businesses will need to manage imports more carefully across each quarter. 

Once quotas are exhausted, the increased out of quota tariff will mean that traders reliant on imported steel will need to reassess sourcing, pricing, and contracting strategies early to adapt effectively to the changes. Accurate classification and origin determination will also now become even more important. 

What is the significance?

This announcement marks one of the UK’s most significant trade policy interventions in years – a pivot toward industrial security and managed trade. While this move strengthens the UK steel industry’s resilience, it inevitably reshapes the operating environment for sectors that rely on imported steel.

In addition to this, the Steel Strategy will operate alongside the upcoming UK CBAM, which will add a carbon‑based charge to imported steel. While the Steel Strategy limits the volume of lower‑cost imports through tighter quotas and increased tariffs, UK CBAM will influence the price of those imports based on carbon intensity. Combined, the two measures mean importers will need to consider both market‑access restrictions and carbon‑related border costs when managing future supply chains.

Next steps

Further clarity on administration, scope, and timelines is expected over the coming months, as the government releases implementation guidance and begins engaging with industry on how the new trade measures will function day to day. 

As always, the Crowe Customs team is available to help UK businesses adapt to these developments – offering support with impact assessments, classification and origin reviews, and the strategic planning needed to manage future supply‑chain and compliance requirements.

For more information, please contact Jamie Mcleod or your usual Crowe contact to discuss this further.

The EU and India have announced a new Free Trade Agreement, released on 27 January 2026 after an extended period of negotiations. Public statements from both sides indicate that the agreement covers a broad scope of tariff liberalisation and regulatory cooperation, and it is expected to have a significant impact on bilateral trade flows once implemented.

However, the agreement is not yet in force. It will only apply once all legal, parliamentary and domestic approval procedures have been completed in both jurisdictions. Until the ratification process is finalised, current tariff rates, customs procedures and market access conditions will continue to apply without change.

Both sides have framed the agreement as a strategic partnership, signalling a commitment to deeper integration during a period of heightened global protectionism. While European industry groups have broadly welcomed the deal, some sectors, such as steel, have emphasised the need to address non tariff barriers alongside tariff liberalisation.

Market access for EU exports to India

India has committed to reduce or eliminate tariffs on 96.6% of EU exports - an unprecedented level of liberalisation for the Indian market. Some of the most substantial changes apply to traditionally protected sectors.

The automotive sector will see the most dramatic shift. Tariffs on EU vehicles, which currently reach up to 110%, will fall to 10% under an annual quota of 250,000 units. This is expected to significantly expand opportunities for European manufacturers.

Across industrial goods, including machinery, chemicals, pharmaceuticals and a wide range of iron and steel products, tariffs will be progressively reduced or removed. This will eliminate several billion euros of annual duty costs and enhance competitiveness for EU exporters. Aerospace products will also benefit from near complete tariff elimination.

High-value agri food goods will enjoy noticeably improved access. Duties on wine will be lowered in stages from their current 150% level, while tariffs on olive oil will fall to zero within five years. Further reductions apply to spirits, beer and processed foods. However, both sides have preserved protections for sensitive agricultural sectors such as dairy, sugar and certain meat products.

Indian exports to the EU

The EU will provide preferential access for more than 99% of Indian exports. This is expected to benefit several major export sectors, including textiles and apparel, leather goods, jewellery, marine products and various agri food lines.

The enhanced EU access arrives at an important moment for India, given increasing tariff pressures in other major markets. These changes sit against the backdrop of India’s existing preferential access to the EU market.

Existing tariff preferences

India has historically benefited from the EU’s Generalised Scheme of Preferences (GSP), but over the past decade the EU has progressively graduated many Indian product sectors out of the scheme as export competitiveness increased. As a result, by the time the new FTA was concluded, most major industrial exports were already outside GSP, with only a limited range of products still receiving reduced duties. Recent regulatory updates indicate a further broad suspension of remaining GSP preferences for India from 2026, meaning that many Indian exports must rely on standard MFN tariffs until the new FTA enters into force.

CBAM and the green transition

The agreement does not include an exemption for India under the EU’s Carbon Border Adjustment Mechanism (CBAM). Instead, the EU has committed €500 million over two years to support India’s industrial decarbonisation and green transition. This funding will be particularly relevant for carbon intensive sectors preparing for future EU carbon reporting and pricing obligations.

UK-India FTA update

The UK and India also recently signed a Free Trade Agreement in July 2025; however, it has not yet entered into force. There remains no confirmed timeline for implementation, but it is understood that:

• the agreement is highly unlikely to be applied provisionally or retrospectively
• both parties must complete domestic ratification process before the agreement can take effect
• implementation is still hoped for during the first half of 2026, but this timeline may be delayed to later in the year.

Once the UK-India FTA does enter into force, the UK will remove almost all tariffs on Indian goods from day one, while India will phase out duties on UK exports gradually over a multi year schedule. Legally, the agreement can only take effect 60 days after both parties complete ratification, and until that point no changes to tariffs or market access apply.

Next steps

The EU-India agreement will now proceed to the European Parliament, EU Member States and India’s cabinet for approval. While there is optimism that the FTA could enter into force later in 2026, this is not yet guaranteed. Businesses should continue to plan on the basis of existing duty structures until formal confirmation is issued.

We will continue to monitor developments in both the EU-India and UK-India FTAs and provide further updates as new information becomes available. If you would like to discuss the potential implications for your business, please contact Jamie Mcleod or your usual Crowe contact.

The UK and Indonesia formally launched a new Economic Growth Partnership (EGP) on 19 January 2026, establishing a structured framework to deepen cooperation across trade, investment, and economic development.

The arrangement sets out shared priorities intended to support businesses in both countries and promote fair competition.

DCTS ‘Graduation’

In other news, UK government has also confirmed that Indonesia will lose access to the Developing Countries Trading Scheme (DCTS) preferences from 1 January 2027. This means Indonesia’s exports to the UK will no longer benefit from reduced or zero tariffs under the scheme, which is designed to support sustainable growth in economic countries. A formal assessment concluded that Indonesia has reached a level of development that no longer warrants preferential access under DCTS.

This follows the graduation of certain Indonesian goods from the Standard Preferences tier which took effect on 1 January 2026. Chapters in scope include fats and oils, basketware and wickerwork, footwear, and musical instruments.

What does this mean for UK traders?

From 1 January 2027, UK importers will pay full ‘third country’ customs duty rates on all Indonesian-origin products that previously qualified under DCTS. 

Over the short to medium term, UK businesses sourcing goods from Indonesia should anticipate higher landed costs. Conducting a targeted review of supply chains is advisable, particularly given the heightened importance of accurately determining origin and tariff classification.

For exporters, the EGP is also expected to improve overall market access by easing non‑tariff barriers and enhancing cooperation in key growth sectors.

Looking ahead

These developments mark a period of transition as the UK and Indonesia work to strengthen their economic relationship while moving away from unilateral trade preference schemes.

We will continue to monitor the situation closely and share updates as further details emerge. If you would like to discuss the implications in more depth, please contact Jamie Mcleod or your usual Crowe adviser.

The European Commission has concluded its partial interim review of anti dumping measures on ceramic tableware and kitchenware originating from China.

The definitive implementing regulation was published in the Official Journal on 6 February 2026, and under EU law it enters into force on the following day. As a result, the revised duty applies from 7 February 2026.

What has changed?

A single anti dumping duty rate of 79% now applies to all Chinese producers of ceramic tableware and kitchenware covered by the relevant commodity codes (which are unchanged).

Previously, the EU applied a tiered structure of anti dumping duties, with a residual rate of 36.1%, lower rates for cooperating exporters, and even lower individually assessed rates for certain producers. This system has now been replaced entirely, with a uniform country wide rate of 79% applied to all Chinese exporters.

Businesses involved in importing ceramic tableware and kitchenware should consider the new duty rate could affect their operations, including potential impacts on landed costs, supply chain arrangements, and customs planning.

In addition, businesses importing similar goods into the UK should monitor future updates from the UK Trade Remedies Authority in case of any potential review of the UK's own anti dumping measures on ceramic tableware and kitchenware originating from China.

How Crowe can help

Crowe’s Customs and International Trade team can advise on the implications of this measure for your supply chain, duty planning and customs compliance. Please contact Jamie Mcleod or your usual Crowe contact to discuss this further.

The European Commission has published the first CBAM certificate price, setting it at €75.36 per tonne of CO₂e for CBAM in scope goods imported into the EU during Q1 2026.

This price is linked directly to the EU Emissions Trading System (EU ETS) - the EU’s cap and trade carbon market under which EU producers must purchase allowances for each tonne of emissions they generate.

This announcement marks a shift for businesses. CBAM has moved from an expected future requirement to a defined and measurable cost, which can now be modelled with greater confidence.

What has been announced

For calendar year 2026, CBAM certificate prices will be published on a quarterly basis, with each price calculated as the weighted average of EU ETS auction clearing prices over the relevant period:

• Q1 2026: €75.36 (published 7 April 2026)
• Q2 2026: to be published 6 July 2026
• Q3 2026: to be published 5 October 2026
• Q4 2026: to be published 4 January 2027

From 2027 onwards, CBAM certificate prices will be published weekly, reflecting the weighted average of EU ETS auction prices from the preceding week, aligning CBAM more closely with ongoing market movements.

CBAM certificates themselves cannot be purchased until February 2027. However, liability has accrued from 1 January 2026, with the first definitive CBAM declaration and certificate surrender due by the end of September 2027, covering 2026 imports.

Why this matters

A published price materially improves certainty. Businesses can now forecast CBAM exposure, rather than treating it as an unknown future variable.

This affects both:

• EU importers, planning certificate volumes, cash flow and margin impact, and
• Non EU exporters selling into the EU, who increasingly need to understand CBAM costs to support pricing, quotes and long term contracts with EU buyers.

In practice, EU customers are already asking suppliers what CBAM will add to landed cost, and €75.36 per tonne provides a clear reference point.

Complexity has not gone away

Despite improved pricing certainty, ultimate CBAM liability is still not driven by price alone.

Key variables include:

• Whether actual emissions data or default values apply
• The applicable CBAM factor during the phase in period
• The CBAM benchmarks, which can materially affect the number of certificates required

Taken together, these elements mean that headline prices need to be assessed in the context of product specific data and methodology, rather than viewed in isolation.

Key takeaway

CBAM is now a forecastable cost, not a theoretical one. Businesses importing into, or exporting to, the EU should be:

• Modelling CBAM exposure using published prices
• Understanding how benchmarks and the CBAM factor affect liability
• Prioritising emissions data to avoid punitive outcomes
• Building CBAM into pricing, quotes and commercial negotiations

For further discussion on how these developments may affect your business, please contact Jamie Mcleod or your usual Crowe contact.

HMRC is modernising the way authorised warehousekeepers apply for and maintain excise warehouse approvals, as part of a wider modernisation and overhaul of the approval process driven largely by the introduction of Vaping Products Duty from 1 October 2026. 

While vaping products are the driver for this reform, the new digital system will affect a broader population of excise warehousekeepers across the UK – excluding operators of motor and heating fuel warehouses.

Excise warehouses are HMRC‑approved facilities where goods (i.e., alcohol, tobacco, etc.) can be stored in duty suspension until they are released for consumption or exported. To operate an excise warehouse, a business must hold warehousekeeper authorisation, demonstrate robust compliance and control standards, and meet the strict operational and record‑keeping obligations. 

What is changing?

HMRC will replace its legacy paper‑based system with a simplified, digital process. Key updates include:

1. A new single online application form (from 1 April 2026) covering:

• Warehousekeeper authorisation
• Premises approval
• Vaping Products Duty approval
• Vaping Duty Stamps approval

2. A new online amendment form for existing warehousekeepers to update approvals and add new premises.

3. Retirement of legacy forms (EX61, EX68, EX69) for alcohol, tobacco and vaping‑related warehouses.

What to be aware of

• Digital transition: all new applications and amendments will now be handled online.
• Streamlined process: new applicants can request warehousekeeper authorisation and premises approval at the same time.
• Vaping products compliance: any business dealing with vaping products in the UK must ensure they have the correct authorisations in place prior to 1 October 2026.
• Core obligations remain unchanged: requirements under Excise Notice 196, including appropriate due diligence, accurate record‑keeping, inventory controls and compliance with authorisation conditions, will continue to apply.

The move to a digital system is expected to offer a much smoother experience than the current paper‑based system but businesses need to pay close attention to the changes, as HMRC has confirmed that it will update Excise Notice 196 and related guidance on 1 April 2026. 

How we can help

Crowe’s Customs and International Trade team has developed a growing excise advisory offering, supporting businesses in managing their excise obligations and adapting to evolving HMRC requirements. Our team is working closely with clients impacted by the changes in this space and can provide practical, informed guidance on understanding and responding to these changes.

For further discussion on how these developments may affect your business, please contact Jamie Mcleod or your usual Crowe contact.

From 1 June 2026, the UK will begin moving to digital ATA Carnets, as part of the international eATA programme led by the International Chamber of Commerce and World Customs Organisation, and implemented in the UK through UKNATACO and HMRC.

ATA Carnets remain an essential tool for UK businesses temporarily moving goods overseas for exhibitions, demonstrations, filming, professional equipment or repair. While the underlying legal framework does not change, the way Carnets are issued, presented and processed at the border will.

What is changing

The application process remains the same. Businesses will continue to apply through their issuing Chamber and declare goods as they do today.

However, once issued:

• Carnet holders will receive a PIN and QR code electronically
• The Carnet will be accessed via the ATA Carnet App
• At participating ports and airports, customs will scan the QR code, removing the need for routine paper presentations

During the transition, paper Carnets should still travel with the goods and remain the legal fallback.

Timing and rollout

Digital Carnets will go live in the UK from 1 June 2026, with a phased rollout across UK and international border locations. Not all ports and countries are yet enabled, and coverage will expand gradually.

UKNATACO has published lists of pilot locations in the UK, EU and beyond, which businesses should check in advance of each movement.

What businesses should do now

Although this is a technology change rather than a rule change, there are practical execution risks. Businesses that use ATA Carnets should:

• Review internal Carnet procedures to reflect digital presentation
• Agree who will control access to the Carnet App
• Test digital Carnets on low risk movements where possible
• Continue to carry paper Carnets during the transition
• Confirm that proposed routes and ports are digitally enabled

Key takeaway

Digital ATA Carnets represent a welcome modernisation of temporary admission procedures, but, as with many border changes, compliance risk sits in execution rather than legislation.

Early testing and clear ownership of the digital process will be critical to avoiding disruption when the system becomes live in June 2026.

Crowe’s Customs team continues to monitor developments closely and can support businesses preparing for the transition.

Background

In January 2026, US Customs and Border Protection (CBP) issued Ruling HQ H350722, examining whether a foreign, unlicensed company operating an online platform for importers was impermissibly conducting “customs business” without a customs broker’s licence. 

In the US, certain customs activities may only be performed by licensed brokers – a framework that differs from the UK and EU, where customs representation is regulated but does not operate under an equivalent, centralised licensing model.

The platform offered broker‑matching services alongside automation tools such as data extraction, AI‑driven tariff classification, and assistance with importer registration. The ruling reflects increasing CBP scrutiny of technology‑led solutions operating at the interface between importers and licensed brokers.

Key findings

CBP assessed each service individually and drew clear boundaries between permissible technology support and regulated customs activity.

• Broker matching platforms are generally permissible where the unlicensed provider merely facilitates electronic data transmission between importers and licensed brokers and does not participate in entry preparation or filing. However, CBP warned of ongoing risks around Power of Attorney execution and client confidentiality, which remain broker responsibilities.
• Tools that extract entry data were found to constitute customs business. CBP confirmed that identifying which data elements belong on an entry (whether done manually or through automation) is part of entry preparation and therefore requires a broker’s licence.
• AI tariff classification tools may be permissible only where they provide general guidance (typically limited to six‑digit HS codes) and are meaningfully detached from entry preparation. Providing eight-digit or ten-digit classifications for specific goods that will be imported into the US constitutes customs business, and disclaimers do not negate this conclusion.
• Submitting CBP Form 5106 on behalf of importers was clearly prohibited. CBP maintained that completing and filing the form is customs business, as it is a prerequisite to making entry, and may only be done by the importer or a licensed customs broker.

Why does this matter?

This ruling reinforces that technology does not dilute regulatory requirements in customs compliance. CBP has made clear that automation, AI, and offshore processing cannot replace the judgment or licensing obligations of customs brokers. 

For trade‑tech providers, the decision provides clearer guardrails on what services can be offered without a licence. For brokers, it highlights compliance risks associated with outsourcing, platform partnerships, and fee arrangements. For importers, it underscores the importance of understanding who is actually performing regulated customs functions behind digital solutions.

In short, innovation in customs processes is welcome – but only within the established licensing framework.

HMRC guidance

From a UK perspective, in January 2026, HMRC published guidance for software developers using generative AI in products that help customers submit information to HMRC. The guidance sets expectations around transparency, use of reliable source data, human oversight and control, strong data security and privacy measures, and ethical use.

The guidance is not customs specific and is aimed at developers rather than internal business use. However, the principles are relevant to customs functions, where decisions are interpretative and liability does not change simply because technology is involved.

Using AI effectively and compliantly

The CBP ruling and recent HMRC guidance highlights a wider point for customs and trade compliance: AI can improve efficiency, but it does not remove the need for judgement, context and oversight.

Customs decisions often require multiple facts to be linked together and alternative approaches to be considered. AI tools can struggle with this end to end analysis, producing outputs that appear coherent but miss nuance, broader context or viable options.

AI should therefore remain supportive rather than determinative. It can assist analysis and prompt review, but final positions must sit with accountable individuals who can assess the full fact pattern and explain the reasoning behind the position taken.

Clear governance and defined review steps ensure that technology strengthens compliance rather than undermining it. Used properly, AI can enhance customs processes, but it cannot replace human judgement.

To discuss this in more detail, please contact Jamie Mcleod or your usual Crowe contact.

HMRC has notified businesses, who are not established in Northern Ireland, that their XI Economic Operators Registration and Identification (EORI) numbers will be removed within 6 weeks of notification. In their recent email to impacted traders, HMRC flagged that this applied to traders whose registered business address associated with their XI EORI is in an EU Member State. 

The review follows HMRC’s continued work to ensure that XI EORIs are only held where the relevant criteria is met. HMRC has confirmed that removing the XI EORI will not affect the ability to move goods into or out of Northern Ireland. 

Affected businesses should continue using their GB EORI for NI declarations in the Customs Declaration Service (CDS) until HMRC confirms when EU EORIs can be used for NI movements.

As impacted businesses are established in the EU, they will now require an EU EORI for any movements into or out of other EU Member States. 

What actions do impacted businesses need to take? 

Businesses receiving this notice should prepare for their XI EORI’s to lapse and ensure they hold a valid EU EORI, while continuing to rely on their GB EORI for NI movements until HMRC issues further instructions.

To discuss the changes further and understand what actions need to be taken for your business to ensure EU imports and exports can continue, please contact Jamie Mcleod or your usual Crowe contact.

The UK government has published the first tranche of draft secondary legislation for the UK Carbon Border Adjustment Mechanism (CBAM), marking a significant step toward implementation from 1 January 2027. The draft legislation has been released for a six week technical consultation, giving businesses an opportunity to comment on the clarity and functionality of the regulatory text before it is finalised later in the year.

Alongside the draft regulations, HMRC has issued accompanying notices that will have legal force once finalised, as well as an updated policy summary setting out how the regime operates across both the primary and secondary legislation.

Core content of the draft legislation

The draft Carbon Border Adjustment Mechanism (Administrative Provisions) Regulations 2026 outline the detailed processes that businesses will need to follow in connection with CBAM. 

These include:

• Requirements for registration, including the information that must be supplied to HMRC.
• Specifications for CBAM returns, covering the data that must be submitted for each imported CBAM good.
• Detailed rules for reimbursement arrangements where repayments are passed through supply chains.
• The definition and evidential requirements relating to the weight of CBAM goods, including how weight should be determined and recorded.
• Comprehensive record keeping duties, including documentation relating to origin, valuation, weight and supporting evidence.

A separate draft instrument sets out the rules governing the calculation of the CBAM rate, the treatment of Carbon Price Relief (CPR) where an overseas carbon price has been paid, the applicable currency conversion rules, and the record keeping obligations associated with CPR claims.

Together, these documents set the administrative and technical foundations for how CBAM will operate from 2027.

Purpose of the consultation

This consultation is designed to ensure the draft legislation is clear, workable and accurately reflects the policy intent. It is not a further consultation on the underlying CBAM policy. Stakeholders are encouraged to identify any drafting issues, unintended consequences or areas where further clarity would assist with future compliance.

The consultation is open to importers, customs agents, advisers, industry bodies and other interested parties in the UK and internationally. Submissions should be sent to [email protected] by 11:59pm on 24 March 2026, using the subject line “CBAM technical consultation response” and referencing the specific provisions under review.

Supporting documents

HMRC has also published supporting materials alongside the draft legislation, including:

• The draft Administrative Provisions Regulations.
• The draft CBAM Rate and Carbon Price Relief Regulations.
• An updated CBAM Policy Summary, providing an overview of how the regime operates across the legislative framework.

These materials provide additional clarity on the detailed mechanics of CBAM and the compliance expectations for affected businesses.

Next steps: assessing the wider impact of UK CBAM

With UK CBAM scheduled to apply from 1 January 2027, businesses should now begin considering the broader impact of the regime on their operations and supply chains. 

Businesses may also wish to monitor the development of the second tranche of draft legislation, expected in Spring 2026, which will complete the CBAM regulatory framework ahead of full implementation.

To discuss this in more detail and understand how to quantify the impact of UK CBAM on your business, please contact Jamie Mcleod. 

As announced in the Budget 2025, there are a lot of changes set to take place in 2026 for businesses involved in excise duties. Traders will need to navigate rate increases for alcohol and tobacco products, as well as the introduction of the new Vaping Products Duty, which is likely to introduce many businesses to excise for the first time.  

Alcohol Duty uprating from 1 February 2026 

From 1 February 2026, the UK will introduce a new wave of excise duty increases, primarily affecting alcohol products across beer, cider, wine, and spirits. These changes, confirmed in the Budget 2025, will uprate alcohol duty in line with inflation at 3.66%. 

The increases will also apply to Small Producer Relief and Draught Relief, to maintain their benefit against the standard rates.

The uprating will likely have an impact on prices paid by consumers and will also affect all those involved in alcohol product supply chains including producers, importers, warehousekeepers, suppliers and retailers.

How can I prepare?

1. Duty-Suspended Stock Removals 

Where you’re holding duty suspended stock, consider whether undertaking constructive removal before 1 February would be beneficial to account for duties at the current rate, rather than the increased rate. Constructive removals come with strict conditions and recordkeeping requirements which must be fully assessed prior to removal. 

2. Update Systems and Engage Third-Parties 

Ensure all systems reflect the updated rates and undertake extra diligence on alcohol returns to make sure that the new rates are being applied. Open discussions throughout the supply chain to understand and communicate potential additional pass-through costs to your suppliers and / or customers. 

3. Continue to Assess ABVs 

In the immediate response to the UK Alcohol Duty Reforms, many businesses considered reformulation of lower ABV products to ensure these were less than 3.5% ABV. The continued annual increases in duty rates could drive another wave of ABV reassessments and reformulations. 

What else is on the horizon? 

Tobacco Duty 

On 26 November 2025, tobacco duty rates increased by inflation + 2% and on 1 October 2026 the rates will increase again. Rates will rise by inflation + 2% again as well as an additional £2.20 rise per 100 cigarettes or 50g of other tobacco product. 

Vaping Products Duty and Vaping Duty Stamps

Vaping Product Duty and Vaping Duty Stamps will be introduced from 1 October 2026, at £2.20 per 10ml of liquid. The new excise duty will bring stringent compliance requirements, akin to tobacco products, as well as additional costs to the vaping market. 

Manufacturers, importers and warehousekeepers will need to understand the new rules and seek HMRC approval from 1 April 2026, further guidance and legislation is expected shortly. 

Contact us

Crowe’s customs team has experience in supporting our clients across the entire excise product supply chain, from shipping agents to producers and warehousekeepers. To discuss how we can support you, please contact Jamie Mcleod.

The UK and India have confirmed that the UK-India Free Trade Agreement will enter into force on 15 July 2026, giving businesses a short window to prepare before they can start trading under the new terms. The Government has described the agreement as the most comprehensive trade deal India has ever brought into force, with expected long-term benefits including increased bilateral trade and significant tariff reductions.

For UK exporters, the agreement creates opportunities in sectors such as whisky, automotive, cosmetics, medical devices and food and drink, with some tariffs being reduced immediately and others phased down over time.

However, the agreement is also highly relevant for UK importers. The UK will reduce tariffs on a range of Indian-origin goods, including clothing, footwear and some food products. This could create meaningful duty saving opportunities for businesses importing from India, particularly in retail and consumer goods supply chains.

New origin evidence requirements

Businesses should not assume that tariff reductions will apply automatically. Preferential tariff treatment will depend on the goods meeting the relevant rules of origin and the correct evidence being held.

This is particularly important because the evidence requirements under the UK-India FTA are different from those businesses may currently use under DCTS. In particular, for imports of Indian-origin goods, neither a Form A nor a standard DCTS-style origin declaration will be sufficient to claim preference under the FTA.

Instead, preference may be claimed using one of the agreed forms of proof of origin, including an origin declaration completed by the exporter or producer, a certificate of origin issued by an issuing authority, or importer’s knowledge. Where importer’s knowledge is used, the importer must hold sufficient supporting evidence, and this should be approached carefully in practice.

What businesses should do now

With the agreement taking effect on 15 July 2026, businesses should now review both their export and import flows with India.

For importers, the key actions are to:

• identify Indian-origin goods that may benefit from reduced UK duty rates
• check whether those goods meet the relevant product-specific rules of origin
• engage with Indian suppliers on the new origin evidence requirements
• update internal guidance so teams do not continue relying on DCTS evidence where an FTA preference claim is intended
• ensure customs agents are given clear instructions on when preference should, and should not, be claimed.

The opportunity is significant, but it will not be automatic. Businesses that want to benefit from the agreement from day one will need to have the right origin analysis, supplier evidence and customs declaration processes in place.

To discuss the duty saving opportunities under the UK-India Free Trade Agreement, or to review whether your imports or exports may qualify for preferential treatment, please contact Jamie Mcleod or your usual Crowe contact.

The European Commission has proposed major changes to the Carbon Border Adjustment Mechanism (CBAM). Under plans published on 17 December 2025, the CBAM rules would be widened from 1 January 2028 to cover many more products – specifically, goods that contain a lot of steel and aluminium. This would expand CBAM well beyond basic raw materials and bring around 180 additional products into scope. 

These changes are based on feedback gathered during the current transition period and are designed to ensure that carbon costs are applied fairly across whole supply chains, not just to the raw materials themselves. 

At present, CBAM applies only to a small group of carbon intensive materials: iron and steel, aluminium, cement, fertilisers, hydrogen, and electricity. But these materials are used to make a huge range of everyday products – from manufacturing equipment to household appliances. 

As the EU gradually removes free EU ETS allowances, EU manufacturers that rely on carbon intensive materials face higher production costs. In contrast, companies importing finished goods into the EU from abroad do not pay equivalent carbon costs. This creates an uneven playing field and exposes EU industry to two linked risks.

First, some manufacturers may shift production to countries with weaker climate rules to stay competitive – known as downstream carbon leakage. Second, EU buyers may increasingly choose cheaper imported finished goods that are more carbon intensive, which could substitute cleaner EU made products. Together, these trends undermine both EU industry and the climate aims behind EU carbon pricing.

The European Commission’s proposal is designed to prevent these problems. By extending CBAM to downstream products, imported finished goods would face a carbon price that more closely matches the one paid by EU producers. This would help ensure fair competition and support the EU’s wider decarbonisation goals

Scope of expansion

The amendment introduces a new annex covering around 180 downstream CN codes, representing both industrial supply chain items and a smaller share of household goods.

According to the Commission’s impact assessment and accompanying documents:

• 94% of the newly covered goods are industrial components with an average 79% steel/aluminium content, often used in heavy machinery and specialised equipment. 
• 6% are finished consumer goods, including certain household appliances.

Examples of affected downstream product categories

The expanded CN coverage includes:

• Iron and steel products: Rails, gas containers, fencing, and other manufactured steel articles.
• Fabricated metal components: fittings for furniture, and metal closures.
• Machinery and equipment: Engines, pumps, burners, refrigeration units, cranes, conveyors, industrial robots, and core electrical equipment (motors, transformers, conductors).
• Vehicles and parts: Goods vehicles (diesel/electric), chassis, gearboxes, wheels, suspension parts, and trailer components.
• Medical and technical instruments: Metal needles and diagnostic/stimulation devices containing steel/aluminium.
• Metal furniture and modular structures: Office metal furniture, metal‑frame seating, and prefabricated buildings.

These additions reflect a major shift in CBAM design – from upstream commodities to mixed component manufactured goods. Importers of machinery, equipment, and assembled metal goods would become CBAM operators required to calculate, report, and surrender CBAM certificates for embedded emissions.

Emissions in scope

Critically, only emissions embedded in covered input materials (precursors) – such as steel and aluminium, will be subject to CBAM. Emissions from downstream assembly or processing will not be included.

Key operational features include:

• Alignment with EU ETS monitoring rules for installation level emissions.
• Use of actual or default values, with flexibility for mixed use.
• Revised rules for scrap: while scrap remains outside CBAM scope, pre consumer steel/aluminium scrap emissions must now be counted in downstream goods. 
• Stronger verification requirements to tackle mis reporting and circumvention. 

Anti Circumvention measures

The Commission has explicitly linked the expansion to addressing widespread concerns about circumvention practices - such as minor processing outside the EU to avoid CBAM charges.

New measures include:

• Enhanced traceability and reporting obligations.
• Powers to impose additional conditions and require extra evidence in higher‑risk cases, particularly where there are concerns about misdeclaration of emission intensity or insufficient traceability.
• Inclusion of pre consumer scrap emissions to prevent loopholes.
• Strengthened oversight of emission intensity declarations.

These controls aim to safeguard environmental integrity and maintain consistent carbon pricing across supply chains.

Next steps

The legislative process will run through 2026-2027, with implementing acts and technical guidance to follow, including calculation methods and default values. 

Businesses importing steel and aluminium downstream goods should start assessing supply chains and preparing for CBAM compliance well ahead of 2028. For assistance with assessing exposure under the new proposal, please contact Jamie Mcleod or your usual Crowe UK contact.

The EU has officially postponed the application of the EU Deforestation-free Regulation (EUDR) by a further 12 months meaning the regulations now won’t impact most businesses until 30 December 2026. The delay, announced in late December, also included further simplifications to ease the administrative and compliance burden on businesses impacted by the measure. 

What is EUDR?

EUDR aims to reduce greenhouse gas emissions and biodiversity loss through prohibiting the entry and exit of goods in the EU market which cannot be proven as “deforestation-free”. Practically, this means that the EU has targeted several key commodities and their derivatives which must now have enhanced supply chain due diligence and risk assessments. 

The key commodities in scope (and their derivatives) include: 

• Cattle (meat, hides, leather, etc.)
• Cocoa (chocolate, etc.)
• Coffee 
• Palm Oil (industrial acids, fatty alcohols, etc.)
• Rubber (tyres, apparel and accessories of rubber, etc.)
• Soya
• Wood (railway sleepers, flooring, casks, barrels, wooden furniture, etc.)

The products in-scope are driven by the customs classification, and the reporting obligations are driven by the jurisdiction of production, therefore key customs data elements will play a pivotal role in understanding whether your business is impacted. 

What’s now changed?

Initially entering into force on 29 June 2023 with a planned application date of 30 December 2024. Due to pressure from key stakeholders and various EU Member States regarding compliance readiness, EUDR implementation was initially delayed until 30 December 2025, and has now been delayed again to 30 December 2026. 

The recent decision by the EU Council and Parliament has now pushed core EUDR obligations for medium and large businesses to 30 December 2026, and for small and micro enterprises to 30 June 2027, giving both impacted businesses and the EU an additional 12 months to prepare.

In parallel, the EU have agreed a number of targeted simplifications which include:

• removal of books, newspapers, printed pictures
• simplified due diligence obligations
• a further simplification review to be undertaken by the EU Commission by 30 April 2026. 

Act now

Despite the second delay to implementation, it is expected that EUDR will come into 30 December 2026 and businesses should not pause preparations. Businesses that use the delay to Companies that use the coming months to build solid compliance processes will be best placed to avoid disruption on Day One.

1. Identify captured products and map associated supply chains 

Review current product portfolios and trade data across the EU to determine which products are captured by EUDR and begin to map associated supply chains, highlighting key regions and suppliers.

2. Engage suppliers to discuss data requirements

Start communication with upstream suppliers in high risk regions about documentation and information requirements as soon as possible, EUDR requirements are stringent and far reaching so overseas suppliers need time to prepare.

3. Strengthen traceability and reporting systems

Businesses need confidence that they can supply all information they provide to the EU and this must pass through the supply chain, systems and processes must be revisited to ensure they are fit for purpose.

4. Implement revised compliance processes

Fully understand the compliance requirements, from geolocation data to legal production evidence, and build new processes to support collection and submission to EU authorities from Day One.

5. Continue to monitor EU updates

Further updates and simplifications are expected following the EU Comission’s review which could impact EUDR requirements, businesses must remain agile, responsive and up-to-date ahead of implementation.

Contact us

Crowe’s customs team has significant experience in helping businesses understand whether they’re impacted by EUDR and how to respond. To discuss how we can assist further, please contact Jamie Mcleod.

Supreme Court blocks Trump’s previous emergency tariffs

On Friday 20 February, the US Supreme Court ruled that Trump’s previous IEEPA‑based emergency tariffs exceeded presidential authority, striking down a major part of his earlier trade measures. This invalidated the emergency and “reciprocal” tariffs introduced in 2025 and has forced the administration to find a new legal route. From Tuesday 24 February, these tariffs will no longer be collected on goods imported into the US. 

It is important to note that the ruling does not apply to tariffs applied under Section 232 or Section 301, and no mechanism for refund of IEEPA tariffs has been established yet. 

Trump immediately imposed a 10% global tariff using Section 122

Within hours of the ruling, Trump pivoted to a different legal authority (Section 122 of the Trade Act of 1974) and signed a proclamation imposing a 10% temporary global tariff on nearly all goods imported into the US.

The new global tariff will take effect on 24 February 2026, and will remain in place for 150 days, reflecting the administration’s use of Section 122 powers to address what it describes as “fundamental international payments problems” – essentially a response to the US trade deficit.

The measure applies broadly but includes significant exemptions for critical minerals, various agricultural goods, pharmaceuticals and their ingredients, selected vehicles and electronics, and aerospace products, as well as goods entering duty‑free under USMCA and DR‑CAFTA, which the White House outlined in its proclamation and accompanying fact sheet.

Trump signals plan to raise the tariff to 15% (the legal maximum)

On Saturday 21 February, Trump announced on Truth Social that he intends to increase the tariff from 10% to 15%, the maximum allowed under Section 122 and claimed it would take effect immediately. However, no official proclamation or executive order has yet been issued, so the legally operative rate remains 10% for now.

Implications for traders

The rapid legal shift, from the Supreme Court overturning Trump’s emergency tariffs to the administration immediately reinstating duties under Section 122, has created a period of short‑term uncertainty for exporters, as tariff levels may shift again within the 150‑day window.

Section 122 allows for fast changes to tariffs without lengthy investigations, therefore businesses face a more volatile environment, making pricing, contracting, and supply chain planning harder in the next 150-days. At the commercial level, many US buyers are likely to revisit pricing and may push foreign suppliers to absorb some of the surcharge, creating potential margin pressure for exporters in non‑exempt sectors.

Traders need to closely monitor developments in the Section 122 tariffs, potential new investigations being launched under Section 301, and any mechanism for duty refunds for previously paid IEEPA tariffs.

How we can help

With US tariffs continuing to evolve, keeping up with the implications for your business can be difficult. Crowe’s customs team in the UK and US are close to the detail and able to support you in understanding and responding to these changes. To explore what the latest developments may mean for your organisation, please contact Jamie Mcleod or your regular Crowe contact.