With major trade regulations coming into effect next year, customs teams are working hard to prepare. So, what impact will incoming legislation have on customs operations, and what adjustments should you consider making to protect your resilience?

Three customs realities for 2026

When it comes to cross-border trade, being proactive and staying ahead of the curve is crucial. In 2026, there are three realities to keep in mind.

#1 – Being compliant gives you a competitive advantage

What’s changing in 2026

Three key trade regulations will come into force next year, and how you adapt to these could be critical to supply chain success.

Import Control System 2 (ICS2, Release3) – the EU’s Import Control System (ICS2). This is an upgraded version of ICS1, designed to improve safety and security in the international movement of goods, where new data requirements are added to the Entry Summary Declaration (ENS). With the implementation of ICS2, Release3, an ENS must be submitted to ICS2 regardless of transport mode, where the ENS also require more detailed and accurate data.

Carbon Border Adjustment Mechanism (CBAM) – a tool designed to put a fair price on carbon emitted during the production of carbon-intensive goods entering the EU. The CBAM will require importers in scope of the CBAM regulation to obtain the status of an “authorised CBAM declarant”, and declare emissions embedded in their imports as the basis for CBAM certificates.

EU Deforestation Regulation (EUDR) – a restriction designed to prevent specific products identified as contributing to forest degradation (commodities like cattle, wood, cocoa, soy, palm oil, coffee, rubber, and some of their derived products, such as leather, chocolate, tyres, or furniture) from being imported into and exported out of the EU.  Under EUDR, operators must be able to prove products derived from commodities specified above have not originated from, or contributed to, forest degradation. This must be provided in the form of a Due Diligence Statement – applicable to large and medium-sized companies from 30 December 2025, and to micro and small enterprises from 30 June 2026. Without a statement, the relating import and export will not be approved by customs.

Why it matters

In these specific cases and others like them, the longer it takes to adapt, the more challenges can occur during actual implementation, which can cause delays or worse.

Customs resilience is about how fast you can operationalise these changes across your markets to deliver compliant processes that can facilitate reliable border crossings and minimise delays, giving you the edge over competitors who are slower to adjust.

What should you do?

Many companies are shifting their compliance focus, taking a more proactive, cross-functional approach to monitoring regulatory trends – often with legal, operations, and product teams collaborating to ensure compliance considerations influence a company’s strategic agenda. This can surface important questions around operational resilience and risk management, such as:

• How do you manage the data linked to these (and other) qualitative data requirements within your business?
• What processes are in place to meet key compliance requirements?
• Do you understand what's expected, and does your team possess the expertise to make the right decisions to ensure you’re compliant?
• Can you leverage risk detection automations to remove strategic ‘blind spots’ in decision-making?
• What are you doing to streamline these processes to avoid supply chain delays?

Answer these questions and you’ll be in a strong position – with reduced risk of disruption – when conditions inevitably change.

#2 – Data readiness will enable smoother border crossings

For the ISC2, Release 3 and EUDR in particular, pre-arrival data quality is going to play a significant role in avoiding disruptions.

That's because a complete ENS, containing a host of different data elements, needs to be submitted prior to the arrival. In most cases, that will mean doing so prior to leaving the exporting country; in some cases, it will even mean prior to loading in the exporting country. Then, based on this data, the customs authorities will perform a safety and security risk analysis. If incorrect data is submitted that needs corrected before the ENS can be approved, then the goods may be left at departure, leading to hold-ups and delayed arrivals at destination.

Meanwhile, for the EUDR, the import into the EU or export out of the EU will be rejected if a Due Diligence Statement (DDS) is not approved. If the DDS data is missing or incorrect, the customs declaration cannot be created, and goods will be stuck at the border. The customs declaration requires specific reference codes to the relating and approved DDS. And as the DDS must be submitted into a different system than customs declarations, this sequence of submissions needs to be carefully managed to ensure the correct data is in place so that everything runs smoothly.

For these reasons, there is a critical need for accurate, complete datasets. Any data gaps or errors risk delays, extra checks, or goods being denied entry. To drive first-time-right submissions – and build operational resilience – it’s vital to get your data in order with automated, validated, pre-arrival data accuracy and completeness.

#3 – Integration will reduce clearance variance

While customs complexity has often stemmed from fragmentation, there is growing momentum for more integrated ways of working.

This comes from a key milestone in June 2025, where EU Member States agreed a negotiating mandate on customs reform to modernise processes and move toward more data-led, joined-up supervision.

Many company leaders will feel they need to go further and cultivate an aspiration to achieve a fully integrated supply chain among their teams, recognising that their integration level is a key success factor for both compliance and keeping cargo moving. As specialists in integrated logistics, Maersk can support businesses on this journey towards improved integration and resilience.

The shift is part of a wider trend for more resilient supply chains. By consolidating responsibility, you may streamline handovers and reduce the risk of errors, delays, and variances. Or, put another way, integration can help create a more predictable customs journey with greater control.

Five focus areas for your customs setup

Now we’ve looked at what matters for customs resilience, let’s turn our attention to more actionable steps. Use the following questions to evaluate how quickly and consistently your organisation can turn change into compliant, low-variance customs outcomes.

Regulatory operationalisation

• What’s your average time from regulatory change notice to first compliant shipment by market, and who is responsible for reducing that timeframe?
• Can your customs partner synchronise updates (classification, procedures, documentation) across all countries within a defined service level agreement?
• How do early warning signals translate into pre-agreed actions with roles, triggers, and timelines?
• What other internal processes are critically linked to your supply chain (e.g. compliance & legal)?
• What adjustments are required to mitigate operational pain points? Are you able to monitor how effectively these changes are implemented across your supply chain?

Data readiness and pre-clearance

• What percentage of declarations required rework in the last 12 months due to missing or incorrect source data?
• Which shipments are eligible for pre-clearance processing, and how early is data validated before arrival?
• Do you combine automated data validation with expert oversight to improve first-time-right rates without adding risk?

Cost predictability

• What are your top three cost-to-serve drivers in customs (e.g., border time, inspections, admin rework), and how has variance changed year-on-year?
• Where can AEO status reduce the likelihood of hold-ups, and is that reflected in your service level agreements and planning assumptions?

Partner model and accountability

• How many handoffs occur from arrival to release, and which delays are attributable to multi-broker fragmentation?
• Do you have a single point of contact and integrated playbooks with your logistics provider to act first during disruption?

Technology and visibility

• Do operations leaders have a real-time exception view for customs milestones, with triggers to reroute or expedite?
• Are scenario planning/‘what-if’ tools used to estimate landed cost and duty impacts before rules take effect?
• How do you pair automation with expert validation to avoid errors and ensure actionability?

If your answers surfaced gaps in speed, variance, or visibility, the fix is often not ‘more effort’. This may be a broader indicator that operations need to be better integrated across your supply chain, enabling expertise, data, and governance to influence decisions and have an appropriate presence in workflows – and Maersk Customs Services has the expertise and experience to guide you through this.

What a stronger 2026 setup looks like

Data accuracy, customs readiness, and supply chain integration level will be key drivers of supply chain resilience in 2026. Here are three unique ways Maersk Customs Services can help:

• Early preparation of declarations where possible, to compress border time.
• Advanced digital solutions combined with expert oversight to deliver compliant shipments first time.
• Integrated partner model, across customs and transportation, to reduce handovers and accelerate response time when conditions change. Partnering with Maersk provides you with one contact point, resulting in increased visibility of flows, particularly when integrated with other services from Maersk.

Above all else, a stronger customs setup will enable your organisation to be better prepared for the incoming legislation – and better equipped to handle any unforeseen changes – to reduce the risk of delays and hold-ups at the border. And with Maersk as your customs partner, you can navigate these changes efficiently and with confidence.

Want to assess your customs readiness for 2026? Book a 30-minute consultation with one of our customs experts.

For more information on Maersk Customs Services, learn more here.