Why Are Documents Changing for Exports to Europe in 2026?
For companies exporting to the European market, 2026 will be a year when a strong green deal, digital customs, and compliance with sanctions files will be added to the classic customs documents.
It is no longer sufficient to pass through customs with just an invoice, packing list, and freight document. As of 2026:
- Customs duty exemption for shipments under €150 is being removed,
- Combined Nomenclature (CN) 2026 will update tariff codes and tax rates for many products,
- Environmental files such as waste, packaging, deforestation, and carbon emissions are effectively becoming “export documents” in many sectors.
In this article, we will summarize step by step which set of documents you will need when exporting to the EU (and European markets that operate in parallel with EU regulations) in 2026; from basic customs documents to new regulations based on products and sectors.
It is critical for exporters working in e-commerce, industry, raw materials, energy, and agricultural products to review this table within 2025 and update their processes. Otherwise, you may face delays at the border, unexpected additional taxes, and even rejection of goods entry in 2026.
1. Core Document Set for All Sectors
1.1 Commercial Invoice
The heart of the file in EU customs is the commercial invoice. The following information must be included in the invoice:
- Exporter and importer title, address, and contact information,
- EORI number for the EU recipient, if applicable EU VAT number,
- Product name, HS/CN code, quantity, unit price, total amount, and currency,
- Incoterms 2020 delivery method (EXW, FOB, CIF, DAP, DDP, etc.),
- Country of origin declaration – especially for customs duties, anti-dumping, and sanctions checks.
Since all shipments will be subject to customs duties in 2026 (see below for the removal of the €150 exemption), the value, origin, and CN code compliance on the invoice become even more critical for each package.
1.2 Packing List
The packing list is indispensable for actual control and logistics, not for tax calculation. It should include:
- Number and type of each box/pallet,
- Gross and net weight for each package,
- Dimensions and type of packaging,
- Box markings and numbers,
- Which product (by SKU) is in which package.
Customs officers largely check the match between the declared product and the physical product through the packing list.
1.3 Transport Documents (B/L, AWB, CMR)
- Bill of Lading (B/L): The shipping document for maritime transport,
- Air Waybill (AWB): Air cargo transport document,
- CMR consignment note: Used in road transport.
These documents serve as proof of the transport contract made with the carrier. Additionally:
- Receipt of goods and delivery location,
- Freight responsibility (together with Incoterms),
- Evidence required by banks in letter of credit payments
is used.
1.4 Customs Declaration in the EU (Import Declaration)
Upon entry into the EU, the importer or customs broker submits an electronic customs declaration. This declaration uses an 8-digit Combined Nomenclature (CN) code, and the applicable customs duty, surveillance, quota, prohibition, and statistical measures are determined accordingly.
As of January 1, 2026, the CN 2026 version will come into effect. The European Commission has officially published CN 2026; for details, you can review the European Commission’s announcement on Combined Nomenclature.
1.5 Proof of Origin
There are two types of proof of origin that stand out in exports to the EU:
- Non-preferential origin: Generally the country of origin declaration found on the invoice. It is important for sanctions, surveillance measures, and trade policy measures.
- Preferential origin: Required for reduced customs duties under free trade agreements or customs unions.
- EUR.1 certificate,
- Approved exporter origin declaration,
- A.TR movement certificate for industrial products under the EU-Turkey Customs Union.
Incorrect or false origin declarations carry the risk of retroactive tax assessments and penalties.
1.6 Insurance Certificate
In Incoterms where freight and insurance are on the seller’s side, such as CIF/CIP, or in cases required by the buyer, a cargo insurance policy or insurance certificate is also added to the file. Especially for high-value, sensitive, or heavily sanctioned products, the insurance company may also inquire about origin and route documents.
2. The Biggest Change in 2026: Removal of €150 Customs Duty Exemption
Until now, there was a de minimis exemption for small package exports under €150 to the EU regarding customs duties. The application was as follows:
- Until the end of 2025: No customs duty is charged on shipments under €150; only import VAT and simplified declaration mechanisms were applied.
The EU has decided to remove this exemption as of 2026. The aim is to subject all shipments, regardless of value, to the same tax regime and to prevent tax evasion on low-value packages.
- Starting in 2026: The paradigm of “Every package is subject to customs duty” is being adopted. This fundamentally changes the playing field in e-commerce.
As a result:
- Correct HS/CN code, origin, value, and importer EORI information must be included in the declaration for each package.
- Marketplaces, platforms, and sellers must update their pricing, Incoterms (DDP vs DAP), and duty calculation systems.
- Incorrect or incomplete coding will now lead to additional taxes, penalties, and return risks, even for low-value packages.
Therefore, during the transition period of 2025-2026:
- Review your e-commerce logistics contracts,
- Revise your pricing & tax calculation modules,
- Reassess VAT and customs responsibility sharing with the platform (marketplace)
to ensure compliance.
3. Combined Nomenclature (CN) 2026: Product Classification Back on the Table
Combined Nomenclature (CN) is the 8-digit product classification system used in import and export declarations in the EU. The applicable customs duty rate, additional taxes, surveillance measures, and statistical tracking are conducted through this code.
The new version of CN will come into effect on January 1, 2026. This means:
- Some product codes will change,
- Some items will have additional sub-classifications,
- Customs duty rates and measures for certain product groups will be updated
for exporters.
Practical effects for exporters:
- Be sure to check whether the HS/CN codes you used in 2024-2025 have changed in the 2026 list.
- Incorrect code = incorrect tax; with low-value packages also being subject to customs duty in 2026, even low-magnitude errors will have a multiplier effect.
- Proceed according to official tariff explanatory notes and, when necessary, binding tariff information (BTI), not according to Grahame.
4. Sector and Product-Based Special Documents (Focused on 2026)
4.1 Sanction Documents for Oil Products from Russia (CN 2710)
As of January 21, 2026, EU operators will not be able to import oil products classified under CN 2710 if these products are produced from Russian-origin crude oil (CN 2709 00).
In this context, companies trading in energy and oil products may be required to provide:
- Due diligence documentation proving that the crude oil is not of Russian origin,
- Supplier declarations, refinery records, vessel tracking data,
- Contracts and freight documents showing the origin chain.
Although the EU customs and sanctions authorities may create facilitation (safe harbour) for some “trusted supplier countries”, they may always request additional evidence. Therefore, proof of origin for energy products has now become part of the document set not only for tax purposes but also for compliance with sanctions.
4.2 Waste, Recycling, and Scrap Exports (Waste Shipment Regulation)
Most provisions of the new Waste Shipments Regulation will come into effect as of May 21, 2026. While many export rules will extend to 2027, the critical date for the export of plastic waste to non-OECD countries is November 21, 2026: from this date, such exports will be effectively banned.
Expected documents for companies exporting waste from the EU:
- Licenses and environmental permits showing that the receiving facility processes the waste in an “environmentally sound manner”,
- Independent audit reports prepared by independent organizations,
- Contracts and technical documentation specifying the type, quantity, disposal, or recycling methods of the waste.
Without these documents, waste exports will either not occur or will face serious sanctions in subsequent audits.
4.3 Critical Raw Materials and Rare Earth Magnet Waste
The EU plans to introduce new export restrictions for rare earth magnet waste and scrap under REsourceEU at the beginning of 2026. The aim is to reduce dependence on China and increase recycling capacity within the EU.
In this context, exporters will need to prepare:
- Additional export licenses or notifications for the relevant products,
- Traceability and composition declarations regarding the content of the magnets or scrap,
- Supply chain documents showing which waste stream the product came from.
Companies working with products or scrap containing rare earths need to prepare for this new regime within 2025.
4.4 Packaging and E-Commerce Packages: PPWR 2026
Under the new EU Packaging and Packaging Waste Regulation (PPWR), as of August 12, 2026, all packaging, including e-commerce packages, will require:
- Design and volume/space efficiency rules,
- Empty space ratio limits,
- Material efficiency, recyclability,
- Minimum recycled content requirements for certain products
to be implemented.
EU importers may start requesting the following from you:
- A technical file demonstrating that the packaging design complies with PPWR requirements,
- Declarations specifying the recycled content ratios,
- Signed documents qualifying as manufacturer declarations or conformity declarations.
For e-commerce players, this will change not only the box sizes but also the way they collect packaging specifications from suppliers.
4.5 Products Free from Deforestation: EUDR Documents
The EU Deforestation Regulation (EUDR) foresees a new due diligence process for products such as timber, coffee, cocoa, soy, palm oil, beef, and rubber before entering the EU market.
Transition timeline:
- EUDR obligations for large enterprises will come into effect by the end of 2025.
- For micro and small enterprises from low-risk countries, it is proposed to postpone implementation for 6 months until December 30, 2026.
Main documents expected from exporters selling to the EU under EUDR:
- Due diligence declaration uploaded to the EU information system,
- Geolocation data for the plots where the product is produced,
- Documents proving that the products are free from deforestation and produced in accordance with the legislation of the country of origin.
Supply chain mapping, integration of geolocation data into the system, and testing of controls require months of preparation. Therefore, the period of late 2025 to early 2026 is practically a “EUDR preparation window”.
4.6 CBAM: Carbon Border Adjustment Mechanism Documents
The Carbon Border Adjustment Mechanism (CBAM) was in a transitional phase for reporting purposes between 2023-2025 for sectors such as cement, iron-steel, aluminum, fertilizers, electricity, and hydrogen. As of 2026, it is transitioning to full compliance.
For companies exporting to the EU in these sectors, the directly responsible party is the CBAM declarant importer in the EU. However, this importer will request the following data and documents from you:
- Embedded emission calculations per product (according to the methodology used),
- Energy consumption, fuel type, raw material consumption details,
- If available, third-party verification reports,
- Technical explanations regarding the production process.
This data will form the basis for 2026 imports, and from 2027 onwards, importers will be required to purchase CBAM certificates and submit declarations.
5. VAT, Customs, and Strategic Priorities in 2026
The EU is focusing on three main axes for VAT and customs in 2026:
- Digitalization: Making customs and tax processes electronic and real-time,
- Fair competition: The removal of the €150 exemption, tighter scrutiny of the platform economy,
- Green Deal: The implementation of CBAM, packaging, waste, and deforestation regulations.
From the exporter’s perspective, this table means:
- More detailed data for each shipment (CN code, origin, value, packaging, environmental footprint),
- Additional compliance documents for every sector (environment, human rights, sanctions),
- Incorrect declarations will lead to both financial (tax, penalty) and reputational risks.
6. How to Secure Post-2026 EU Exports with Corpenza?
When exporting to Europe, the issue is no longer just about getting a shipment through customs; it is about establishing a sustainable business model with the right company structure, the right tax position, and the right compliance architecture.
As Corpenza, we provide end-to-end consultancy in areas such as:
- Company formation and structuring (for example, establishing a sales office or warehouse company in the EU),
- International accounting and VAT management (refunds, local VAT registrations, platform VAT),
- Payroll / EOR and posted worker model for sending personnel abroad,
- Tax optimization and redesign of the supply chain,
- Investment residency, golden visa, and executive mobility
For example:
- If you plan to open a warehouse within the EU or use regimes like IOSS/OSS, we can model which country would be more advantageous for you to establish a company.
- If you work in regulation-intensive sectors such as waste, energy, metals, or agricultural products, we can integrate customs classification, origin strategy, and tax impacts with your business model.
- If you need to have a field sales team or technical team in the EU, we can optimize personnel costs and tax risks with payroll / EOR solutions.
In years of such complex regulations, treating exports not just as a “logistics operation” but as a legally, financially, and operationally integrated investment decision provides a significant competitive advantage.
Conclusion: What Needs to Be Done Before Entering 2026
2026 will be a transformation year in exports to Europe under these four headings:
- Customs duties for all shipments: The €150 exemption is removed; data quality and correct classification are vital.
- New tariff structure with CN 2026: You need to update your product codes and tax rates.
- Environmental and sustainability documents: CBAM, EUDR, PPWR, waste, and critical raw materials regulations are now part of the export file.
- Digital customs and transparency: Every incorrect or missing document will be detected faster through automated systems.
Key steps you need to take within 2025:
- Extract a CN code, origin, and regulation map on a product basis.
- Revise your Incoterms, tax, and pricing model for your e-commerce and B2B trade according to 2026.
- Clarify which documents will be requested from you in the area of environmental and social compliance (CBAM, EUDR, packaging, waste).
- Create a long-term legal and tax framework for your business model in the EU (company, warehouse, personnel, representative).
To structure this process in a way that will reduce customs and tax risks and increase your commercial flexibility, it is highly recommended to seek professional support from a team experienced in international corporate structuring and mobility, as this will directly affect your competitiveness in 2026 and beyond.
Disclaimer
This text has been prepared for general informational purposes; it does not constitute legal, financial, or tax advice. The information here is based on official and reliable sources available as of December 2025; however, regulations may change over time.
Before any concrete transaction, we strongly advise you to check the current regulations from official sources (such as the EU tax and customs announcements) and to seek individual consultancy from professionals in the field if necessary. Corpenza cannot be held responsible for the consequences of transactions made based on the information contained in this text.
