This article is for retailers, online marketplaces, fulfilment providers, carriers and logistics partners involved in moving eCommerce goods across international borders. It explains why customs compliance cannot be treated as the responsibility of one supplier alone, where accountability can become unclear and what businesses should establish before goods begin moving.

With UK and EU reforms placing greater responsibilities on sellers and online platforms, understanding who creates, checks and submits customs information is becoming increasingly important.

Outsourcing customs activity does not outsource responsibility.

An international eCommerce order may pass through a retailer, marketplace, fulfilment provider, carrier, customs agent and final-mile delivery partner before it reaches the customer.

Each business performs a different part of the process. But when the product description is unclear, the commodity code is incorrect, or the customs value does not match the transaction, who is responsible? The answer is not simply the business that submitted the customs declaration.

Customs compliance is a shared process, but responsibility for the underlying information must still be clearly assigned. A customs agent can prepare and submit a declaration, identify inconsistencies and advise on customs requirements. It cannot, however, manufacture accurate product information that does not exist or correct commercial data that was wrong at source.

This distinction is becoming increasingly important as customs authorities expect more detailed information earlier in the transaction and governments move responsibilities closer to overseas sellers and online marketplaces.

Customs compliance begins with the data owner.

The information needed for customs clearance is created long before a parcel reaches the border. The seller is usually best placed to know what the product is, what it is made from, where it was manufactured and how much it was sold for. A marketplace may control the product listing, customer payment and collection of taxes or duties. The fulfilment provider knows what was packed, while the carrier holds the transport information.

The customs agent brings these different pieces of information together to complete the customs process. The quality of the declaration therefore depends on the quality of the data received from across the supply chain.

If a seller provides a vague description such as “clothing”, “accessory” or “gift”, other parties may not have enough information to determine the correct classification. If the declared value does not reflect the transaction, a carrier or agent may have no independent way to identify the correct amount. If the country of origin has been assumed rather than properly established, the wrong duty may be applied. This is why customs compliance cannot begin at the point of declaration. It must begin with the creation and management of product data.

Online marketplaces are becoming increasingly important within this process. Under the EU Import One Stop Shop, or IOSS, suppliers and qualifying electronic interfaces can collect VAT at the point of sale for imported consignments not exceeding €150. In certain circumstances, a marketplace can be treated as the deemed supplier for VAT purposes.

However, IOSS is a VAT simplification. It does not remove the need for a valid customs declaration or accurate customs data. The party collecting VAT, the importer, the customs declarant, and the business supplying the product information may still be different organisations. European Commission guidance on low-value consignments.

The direction of travel is towards greater marketplace involvement. The European Commission’s proposed customs reforms would make online platforms key participants in ensuring that duties and VAT are paid at purchase. European Commission overview of EU customs reform.

The UK is moving in a similar direction. Under proposed reforms to the customs treatment of low-value imports, overseas sellers and online marketplaces would be responsible for collecting customs duty and accounting for it through a new system. The arrangements are expected to take effect by October 2028 at the latest. UK Government response on low-value import reform.

These developments reinforce a wider point: customs responsibilities are moving closer to the product listing, checkout and point of sale. Retailers and marketplaces will need to treat customs data as a core part of the eCommerce transaction, rather than information assembled only when the parcel is ready to leave.

Outsourcing the declaration is not the same as transferring responsibility

Appointing a customs agent is an important way for businesses to access specialist knowledge and manage complex customs processes. It does not mean the trader can step away from the accuracy of the information being declared.

In the UK, an agent can act as either a direct or indirect representative:

Under direct representation, the agent submits the declaration in the trader’s name and on its behalf. The trader remains responsible for the customs debt and the accuracy of the underlying information.

Under indirect representation, the agent acts in its own name but on behalf of the trader. The agent and the principal may then be jointly and severally liable for the customs debt. HMRC can seek payment from either party. HMRC guidance on customs debt liability.

The type of representation therefore matters, but neither arrangement removes the need for accurate information from the business that understands the products and transactions.

Customs agents have responsibilities of their own. They must understand the authority under which they are acting, maintain appropriate records, conduct reasonable due diligence and question information that appears inconsistent or implausible.

A strong customs relationship is therefore a partnership. The retailer or marketplace provides accurate, complete and properly governed data. The customs agent applies specialist knowledge, challenges potential errors and ensures the information is used within the correct customs process.

Carriers and logistics providers also have defined responsibilities. For example, the carrier moving goods into Great Britain is responsible for ensuring that an Entry Summary Declaration is submitted. A third party may lodge it on the carrier’s behalf, but the carrier remains responsible for making sure the submission takes place. HMRC guidance on Entry Summary Declarations.

This demonstrates the difference between performing an activity and owning responsibility for it. A task may be delegated to another business, but the legal or operational obligation may remain with the original party.

Responsibility must be agreed before the parcel moves

The greatest compliance risks often appear in the gaps between businesses. A marketplace may assume the seller has validated the commodity code. The seller may expect the carrier to classify the goods. The carrier may assume it will receive declaration-ready information from the fulfilment provider. The customs agent may receive only the limited data transmitted through the shipping label.

Everyone has performed their part, but no one has taken ownership of the whole data journey. By the time the problem is identified, the parcel may already be moving. The result can be an incorrect duty calculation, delayed clearance, unexpected customer charges, a rejected declaration or a retrospective customs debt. When the same weakness is repeated across thousands of consignments, a small data problem can become a significant commercial and compliance risk.

For every international sales route, businesses should be able to answer:

• Who determines and approves the commodity code?
• Who confirms the customs value?
• Who establishes and evidences the country of origin?
• Who will act as importer?
• Who calculates and collects duties and taxes?
• Who supplies the customs and safety and security data?
• Is the customs agent acting directly or indirectly?
• Who investigates and corrects inaccurate information?
• Who retains the supporting evidence and audit trail?

If these questions cannot be answered clearly, the compliance model is not clear enough.

Contracts can help define the responsibilities of each party, but contractual wording alone will not make customs data accurate. Responsibilities must also be reflected in operational processes, system integrations, data checks and exception management.

The question businesses should ask is not simply, “Who submitted the declaration?” It is, “Who created the information, who checked it and who was expected to act if something did not look right?”

Customs compliance can be shared across several businesses. It cannot be left to assumption.

As responsibility moves closer to the point of sale, the businesses best prepared for future reforms will be those that define ownership early, maintain reliable product data and involve their customs partners before goods begin moving.

Outsourcing customs activity can provide valuable expertise and operational support. What it cannot do is outsource responsibility for getting the underlying information right.

A significant escalation in the trade dispute between the United States and Canada took effect on 22 August 2026, when the US introduced additional 50% tariffs on a specified range of Canadian goods.

The measures followed the breakdown of negotiations between the two countries and were introduced under Section 338 of the US Tariff Act of 1930. This provision allows the US President to impose duties of up to 50% in response to trade practices considered discriminatory towards American commerce.

The tariffs apply to covered goods entered for consumption, or withdrawn from a warehouse for consumption, from 12:01 a.m. Eastern Time on 22 August 2026.

According to the Office of the United States Trade Representative, the original Section 338 actions covered nearly US $20 billion of Canadian imports. Canadian Prime Minister Mark Carney has described the affected trade as approximately C$28 billion.

Which products are affected?

The new tariffs cover specified Canadian-origin products across a range of consumer and commercial categories. These include certain wine and spirits, dairy products, clothing and textiles, furniture, sporting goods such as hockey equipment and fishing rods, and seeds.

However, this is not a blanket 50% tariff on every Canadian product entering the US. The applicable treatment depends on the product’s precise classification under the Harmonized Tariff Schedule of the United States, or HTSUS.

Significant exclusions have also been reported, including certain energy products, potash, fish and critical minerals. Goods already subject to separate Section 232 tariffs are also excluded from the new Section 338 measure.

Businesses should therefore avoid making assumptions based solely on a broad product category. Two apparently similar goods may receive different treatment depending on their composition, origin and eight-digit HTS classification.

USMCA status does not automatically provide an exemption

One of the most important points for companies trading across the US-Canada border is that qualification under the United States-Mexico-Canada Agreement does not automatically remove the additional Section 338 duty from an affected product.

USMCA origin remains relevant to the wider tariff treatment of a shipment, but a covered product may still attract the additional 50% duty even where it qualifies for preferential treatment under the agreement.

This distinction highlights the importance of understanding each tariff measure separately. Preferential origin, standard customs duty, Section 338 tariffs, Section 232 measures and any other applicable trade remedies can operate under different rules.

Businesses need to establish:

• The correct HTS classification for each product
• Whether the goods meet the relevant country-of-origin rules
• Whether the HTS code is included in the Section 338 action
• Whether a stated exclusion applies
• Whether other duties or trade measures could also affect the entry
• Which party is contractually responsible for the resulting costs

At a tariff rate of 50%, an incorrect assumption can have a substantial financial impact. It can alter the landed cost of a product, reduce or eliminate its margin and potentially make an established supply chain commercially unviable.

Canada prepares retaliatory measures

Canada has announced that it intends to respond on a dollar-for-dollar basis, with retaliatory tariffs scheduled to take effect on 8 September 2026.

The proposed Canadian measures are expected to target US goods in sectors including steel, dairy, household appliances, agricultural equipment, pulp and paper, and electronics.

Businesses exporting from the US into Canada should therefore assess their potential exposure now rather than waiting for the countermeasures to take effect. This should include reviewing Canadian tariff classifications, origin information, pricing arrangements and any contracts that determine who must pay additional import duties.

Companies operating supply chains in both directions may face exposure to measures introduced by each country. The combined effect could reach beyond the direct duty payable, influencing sourcing decisions, inventory planning, transport routes, retail pricing and customer demand.

Tariffs are a wider commercial issue

The immediate task for affected importers and exporters is to establish whether their individual products fall within the measures. The wider lesson, however, extends beyond customs compliance.

Tariff changes can quickly reshape the economics of international trade. A product that was commercially viable under one duty structure may require significant repricing when an additional tariff is introduced. Businesses may also need to reconsider supplier relationships, contractual terms, product ranges or the markets in which they operate.

Companies trading between the US and Canada should review:

• Product classifications and supporting technical information
• Country-of-origin evidence
• USMCA eligibility and documentation
• Landed-cost calculations and profit margins
• Incoterms and contractual responsibility for duties
• Goods already in transit or held in customs warehouses
• Exposure to the forthcoming Canadian countermeasures

This development also demonstrates why customs data must form part of wider commercial planning. Accurate classifications and origin records are essential, but businesses must also be able to translate regulatory changes into reliable landed-cost calculations and timely operational decisions.

The US-Canada trading relationship is one of the largest in the world, and any disruption can have consequences across deeply integrated North American supply chains. With further changes possible as the dispute develops, businesses should continue monitoring official notices and reviewing their exposure at individual product level.

UKP Worldwide will continue to monitor this development alongside the wider tariff and regulatory changes affecting international trade.

Information correct as of 24 August 2026. Tariff measures can change at short notice. Businesses should confirm the treatment of individual products using the relevant official tariff schedules and customs guidance.

For eCommerce businesses selling consumer goods into the European Union, customs compliance is becoming increasingly connected to something that sits much further upstream: product data.

From 1^st November 2026, Product Identifiers (PIDs) become a mandatory part of customs declarations for B2C distance sales of imported goods into the EU.

The requirement forms part of the latest changes to the Union Customs Code and follows the significant changes to low-value eCommerce imports introduced on 1^st July 2026.

While November may still feel some way off, businesses have already been given an important opportunity to prepare. Product Identifiers can be declared voluntarily from 1^st July 2026, providing retailers, marketplaces and their logistics partners with a window in which to identify missing information, test data flows and address potential problems before the requirement becomes mandatory.

This should not be viewed simply as another field to add to a customs declaration. It is another indication of the direction in which European customs is moving. Customs authorities increasingly want more detailed, structured and traceable information about the individual products entering the market.

What are Product Identifiers?

Product Identifiers provide customs authorities with more precise information about the goods being imported and improve the traceability of products sold through eCommerce.

Under the new requirements, three types of identifier are particularly important:

Merchant Product Identifier (M-PID)
This is the unique product identifier assigned by the online seller, marketplace or platform. It could, for example, be a merchant SKU or other unique product reference. The corresponding customs code is C127, and it is mandatory.

Non-Standardised Manufacturer Product Identifier (NS-PID)
This is a product identifier assigned by the manufacturer, producer or product supplier that does not rely on an internationally recognised standard. Examples could include a manufacturer model, style or product reference. The corresponding customs code is C128, and it is also mandatory.

Standardised Manufacturer Product Identifier (S-PID)
Where one exists, this is an identifier based on a recognised standard, such as an EAN, GTIN or ISBN. The corresponding customs code is C129. Where a product does not have a standardised identifier, Y081 is used to declare that no such identifier exists.

Importantly, the requirement applies at item level. This means businesses need to think beyond whether the information exists somewhere within their organisation. They need to consider whether the correct identifiers can be associated with the correct product and transmitted through the supply chain to the party making the customs declaration.  That distinction is important.

A retailer may already have thousands of SKUs within its product catalogue. Its suppliers may hold manufacturer references, while standardised identifiers may sit elsewhere within product information systems. Customs compliance increasingly depends on bringing those different pieces of information together and ensuring they remain connected to the individual item throughout the transaction.

The responsibilities therefore stretch across the eCommerce supply chain. Sellers and marketplaces need to assign and communicate the Merchant Product Identifier. Manufacturers and suppliers are an important source of the manufacturer identifiers. Declarants and customs representatives then need the correct information in order to submit it as part of the customs declaration.

A missing identifier at the point of clearance may therefore have its origins much earlier in the process.

This is really a data readiness issue

The practical question for retailers is not simply, “Do we have this information?”

It is, “Can we reliably get the right information to customs for every applicable product?”

That means reviewing the journey data takes from the product catalogue, supplier or marketplace through order management, warehouse and shipping systems and ultimately into the customs declaration.

Businesses preparing for November should be looking at whether they can consistently provide their Merchant Product Identifier and manufacturer product reference for each relevant item, whether standardised identifiers such as EANs, GTINs or ISBNs are being captured where they exist, and whether their systems can correctly identify where a standardised identifier does not exist.

The voluntary declaration period is therefore valuable. Rather than treating 1 November as the point at which preparations begin, businesses can use the months beforehand to test real product data, identify gaps within catalogues, engage with suppliers where information is missing and confirm that data can pass correctly between systems and partners.

This is particularly important for businesses with large or frequently changing product catalogues. Resolving missing manufacturer references across thousands of SKUs is a very different exercise from adding a new field to a customs declaration.

The PID requirement should also be considered in the context of the wider changes taking place across EU eCommerce customs.

From 1^st July 2026, the EU introduced significant changes affecting low-value distance sales, including the removal of the previous €150 customs duty relief and the introduction of a temporary €3 customs duty for eligible items. Product Identifiers represent another stage in that changing customs environment.

Taken together, these developments point towards a customs system in which product-level data, traceability and data quality play an increasingly important role in determining how efficiently goods move across borders.

For retailers, marketplaces and logistics providers, this changes where customs preparation begins.

It no longer starts when a parcel reaches the warehouse or when a customs declaration is created. Increasingly, it begins when a product is first added to a catalogue.

That makes customs compliance a conversation not only for logistics and customs teams, but also for eCommerce, IT, product, procurement and supplier management teams.

Preparing now for 1^st November

Businesses selling B2C goods into the EU should use the period before November to understand what data they currently hold, where it originates and whether it can be transmitted accurately through their systems. The key is to test rather than assume.

Take representative products from across your catalogue and follow their data through the complete journey. Can you identify the M-PID? Do you hold the manufacturer’s NS-PID? Is there an EAN, GTIN, ISBN or other standardised identifier? If there is no standardised identifier, can that be communicated correctly? Most importantly, does all of that information reach your customs declarant at item level?

Finding those gaps now provides time to fix them. Finding them when goods are already moving towards the EU is considerably more difficult.

At UKP Worldwide, we are working with customers to prepare for the changing EU customs environment and ensure the data required for customs clearance can be captured and transmitted correctly.

For businesses selling consumer goods into Europe, 1^st  November 2026 should already be on the implementation calendar.

The regulation may be changing in November, but the work required to comply with it starts with the product data businesses hold today.

For years, eCommerce businesses selling internationally have concentrated much of their compliance effort on what is inside the parcel: product descriptions, commodity codes, values, country of origin, VAT and customs declarations. Increasingly, businesses also need to think about the parcel itself.

From 12 August 2026, the initial requirements of the EU’s Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) apply across the European Union.

PPWR replaces the previous Packaging and Packaging Waste Directive (PPWD) and introduces a new framework designed to reduce packaging waste, improve recyclability and increase the use of recycled materials. Requirements are being introduced progressively, with further measures coming into application through to 2040.

For UK eCommerce businesses selling packaged goods to EU consumers, this should therefore be viewed as more than an environmental initiative. It forms part of a much wider change in what businesses need to consider when placing goods on international markets.

What does PPWR mean for UK exporters?

PPWR applies broadly to businesses placing packaging on the EU market, including manufacturers, importers, distributors and retailers. It covers packaging types throughout the supply chain, including primary, secondary, tertiary and service packaging.

For an eCommerce retailer, that means compliance considerations can extend beyond the packaging immediately surrounding the product to other packaging used to prepare and transport an order.

Among the requirements applying from 12 August is a restriction on the concentration of lead, cadmium, mercury and hexavalent chromium within packaging or packaging components. Their combined concentration must not exceed 100 mg/kg. Specific restrictions also apply to PFAS in food-contact packaging.

The regulation also establishes recyclability requirements for packaging, although many of the more detailed measures – including future recyclability performance criteria, recycled-content targets, labelling requirements and measures designed to reduce unnecessary packaging – are being introduced progressively.

This is therefore not a single regulatory deadline. 12^th August 2026 marks the beginning of a much longer transition in the way packaging placed on the EU market is designed, documented and managed.

The bigger issue for cross-border eCommerce

PPWR highlights something increasingly important for international retailers: customs compliance and wider market compliance cannot always be considered separately.

A shipment can contain accurate customs data, the correct commodity codes and values, and the appropriate VAT arrangements, but that does not automatically mean everything associated with placing those goods on the EU market is compliant. That distinction matters.

UK Government guidance specifically warns exporters that failure to comply with PPWR could result in goods being rejected at EU borders.

For eCommerce businesses accustomed to thinking of the border primarily as a customs checkpoint, this requires a broader compliance mindset.

Getting the customs declaration right remains essential – but it is only one part of successfully placing a product onto an increasingly regulated international market. Packaging compliance is becoming a data challenge too

There is another important parallel with the changes we are already seeing across customs. Businesses are increasingly expected to know more about their products and provide better-quality, more granular information about them. Packaging is heading in a similar direction.

UK Government guidance advises exporters to collect and maintain relevant PPWR and Extended Producer Responsibility (EPR) data. EPR requirements can involve information including packaging type, weight, recyclability and recycled content.

For retailers with hundreds or thousands of products, this raises an important operational question:

How much do you actually know about the packaging travelling with each product?

It may no longer be sufficient for this information to sit solely with a procurement team or packaging supplier. Businesses selling crossborder increasingly need reliable access to packaging specifications, supplier evidence and relevant compliance documentation.

That turns packaging compliance into a supply-chain data issue as much as a sustainability issue. And, as customs and regulatory systems become increasingly data-led, the ability to retrieve accurate information quickly is becoming an important part of keeping goods moving.

What should UK eCommerce businesses be doing now?

The first step is understanding the packaging being placed on the EU market.

Businesses should consider auditing packaging used for EU orders and speaking to packaging manufacturers and suppliers to establish whether the relevant requirements are being met.

Documentation is particularly important. UK Government guidance advises businesses to prepare a Declaration of Conformity for each packaging type being placed on the market from 12 August 2026 and to ensure that the necessary technical documentation is available to demonstrate compliance with the applicable requirements.

Businesses should also establish who within their supply chain is responsible for providing, maintaining and accessing this information.

Alongside PPWR itself, UK exporters should review their Extended Producer Responsibility (EPR) position in the EU countries in which they sell. This can involve registering with relevant national EPR schemes, reporting packaging data and paying applicable fees. Businesses should also establish whether an authorised representative is required to manage obligations locally.

Micro-enterprises are not automatically outside the regulation either. Although lighter requirements can apply in some circumstances, the UK Government guidance makes clear that they remain subject to core PPWR obligations.

Most importantly, businesses should avoid treating packaging compliance as an isolated project. Procurement, sustainability, compliance, logistics, eCommerce and customs teams may all hold different pieces of the information required. Connecting those pieces is likely to become increasingly important.

Customs arrangements don’t remove packaging obligations

It is also important to separate packaging compliance from the mechanism’s businesses use to manage VAT, duty and delivery. IOSS, DDP and DAP/DDU arrangements may influence how VAT, duties, risk and customs clearance are managed, but they do not remove a business’s packaging obligations when placing packaged goods on the EU market.

A retailer can therefore have an effective IOSS arrangement, accurate customs declarations and a well-structured international delivery solution and still have separate PPWR and EPR responsibilities to address.

This is why looking at cross-border compliance as a complete journey, rather than simply a customs declaration, is becoming increasingly important.

Compliance is moving beyond the customs declaration

PPWR is another example of a wider trend affecting cross-border eCommerce.

From increasingly detailed customs data requirements to product, environmental and packaging regulation, authorities are demanding greater transparency, traceability and accountability from businesses placing goods onto international markets.

For retailers, the question is therefore becoming broader than simply:

“Can we clear this parcel through customs?”

The better question is:

“Do we have the information, processes and evidence needed to place this product – and everything travelling with it – on the destination market compliantly?”

That is a much bigger conversation.

At UKP Worldwide, our role is to help businesses navigate the customs and cross-border elements of that journey, ensuring international delivery and customs processes are structured correctly as regulatory requirements evolve. Packaging manufacturers and specialist compliance advisers should be used where businesses require confirmation that packaging itself meets the applicable technical requirements.

PPWR will continue to evolve as further requirements are introduced over the coming years. For businesses selling into the EU, the important step now is to make packaging part of the wider cross-border compliance conversation – rather than waiting until a compliance issue interrupts the movement of goods.

Further information

UK businesses can find guidance on PPWR, EPR requirements and recommended actions through the UK Government’s Business.gov.uk service:

UK Government – EU Packaging and Packaging Waste Regulation (PPWR)
https://www.business.gov.uk/campaign/europe/european-union-eu-regulations/eu-packaging-and-packaging-waste-regulation-eu-ppwr/

The full legislation is available through EUR-Lex:

Regulation (EU) 2025/40 – Packaging and Packaging Waste
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040

This article provides general information on regulatory developments and should not be considered legal or packaging-compliance advice. Businesses should seek specialist advice regarding the obligations applicable to their products, packaging and supply-chain structure.

UKP Worldwide’s Director, Guy Cliffe, has been featured in the latest Spotlight Interview by Cross-Border Magazine, one of Europe’s leading publications dedicated to international eCommerce and cross-border trade. The interview explores one of the biggest issues facing online retailers today: navigating an increasingly data-driven customs landscape. Read the full interview on Cross-Border Magazine

Throughout the interview, Guy discusses how customs has evolved from an administrative requirement into a strategic business function. As retailers continue expanding into new international markets, success increasingly depends on the quality of customs data, robust compliance processes and the ability to adapt to changing regulations.

Among the topics covered are the long-term impact of Brexit, the growing importance of accurate product data and HS classifications, the role of regulations such as ICS2, and why businesses should consider customs much earlier in their fulfilment process. The interview also explores international returns, duty recovery opportunities and how automation is helping retailers reduce delays while improving compliance.

One of the key themes running throughout the discussion is that the future of cross-border trade will be shaped by data. As customs authorities around the world continue to introduce more digital and risk-based controls, retailers that invest in accurate information, integrated technology and flexible customs processes will be best positioned to deliver a seamless customer experience while remaining compliant.

The interview forms part of UKP Worldwide’s ongoing partnership with Cross-Border Magazine and reflects our commitment to sharing practical insight that helps retailers, marketplaces, carriers and logistics providers navigate an increasingly complex international trading environment.

You can read the full interview here:

Spotlight on Guy Cliffe: Customs Clearance Challenges