These legal changes are now having a direct impact on the transport and logistics industry. New requirements in import controls, export customs declarations and mechanisms to align COâ‚‚ emissions with EU climate policy are affecting day-to-day operations for companies involved in international trade and transport. Without adequate technological and organisational preparation, businesses risk losing efficiency and competitiveness.

Five key regulatory changes in 2026
1. ELO – mandatory logistics envelope for transport via France

Since January 2026, the ELO system (Enveloppe Logistique Obligatoire) has been fully rolled out. For all shipments between the EU and the United Kingdom routed via France, an electronic “logistics envelope” must now be created for each vehicle.

The ELO envelope must include:

ENS security declarations
export, import and transit declarations
information on the goods being carried
vehicle and driver details

Carriers operating on these routes must have an account in the French customs administration system and create the envelope before reaching the border. Vehicles without a correctly created envelope are refused access to port areas and the Eurotunnel terminal.

A particular operational risk is that the export procedure may remain open if the driver fails to scan all MRN numbers associated with the shipment. In such cases, exporters are unable to apply the zero VAT rate.

2. CBAM – Carbon Border Adjustment Mechanism

As of 1 January 2026, the transitional phase of the Carbon Border Adjustment Mechanism (CBAM) has ended and the definitive phase has begun. Importers are now subject to full financial obligations under the scheme.

CBAM is designed to equalise carbon costs between EU producers and importers from countries with lower climate standards.

Goods currently covered by CBAM include: cement, electricity, fertilisers, iron and steel, aluminium and hydrogen.

Importers are now required to:

hold the status of an “authorised CBAM declarant”
submit annual reports on imported quantities and associated emissions
purchase CBAM certificates corresponding to declared COâ‚‚ emissions
prepare for the first financial settlement in 2027, covering imports made in 2026

For the first time, emissions-related charges now apply to certain goods imported into the EU. The European Commission is also preparing to extend CBAM to selected processed products, such as car parts, refrigerators and washing machines, during the 2026–2028 period.

3. ICS2 – new import control rules for road and rail transport

From 1 June 2026, Import Control System 2 (ICS2) applies fully to road and rail transport across EU member states. Carriers previously operating under ICS1 must now submit full Entry Summary Declarations (ENS) in the new system.

Current requirements include:

ENS declarations must be lodged one hour before border crossing for road transport and two hours in advance for rail transport
mandatory data includes the EORI number and six-digit commodity codes
incomplete or incorrect declarations are automatically rejected
missing declarations may result in goods being stopped at the border

Carriers bear full responsibility for the accuracy of submitted data. Insufficient preparation is already leading to delays and additional costs. The situation is further complicated by the fact that several EU member states introduced ICS2 requirements earlier, forcing operators to manage different procedures depending on the route.

4. AES/ECS2 PLUS – new export customs system

In 2026, the AES/ECS2 PLUS system has become operational across the EU, replacing existing simplified export procedures. Export declarations must now be submitted exclusively in electronic form, either at approved locations or at customs offices.

Key changes now in force include:

the abolition of local clearance simplified procedures (entries in the declarant’s records)
individual assessment of each declaration by customs and fiscal authorities
transhipment under the export procedure permitted only at approved locations
identification of economic operators solely via the EORI number

The new system ends the automatic release of export declarations. Companies must now factor in longer clearance times and stricter documentation requirements.

5. New Union Customs Code (nUCC) – reform underway

While the full implementation of the new Union Customs Code (nUCC) is scheduled for the 2028–2038 period, 2026 is a decisive year for finalising the reform. Preparatory work is already under way, and businesses are expected to align their systems accordingly.

The reform introduces a fundamentally new customs model based on centralised data management and fully digitalised procedures.

Confirmed milestones include:

1 January 2028 – launch of the EU Customs Authority
1 March 2028 – new e-commerce rules, including the removal of the duty exemption for consignments up to €150
from 2028 – mandatory use of the EU Customs Data Hub for e-commerce operators
from 2032 – optional participation for other companies under the “Trust & Check” programme
from 2038 – mandatory use of the EU Customs Data Hub for all importers

The future system requires early investment in IT infrastructure and data management capabilities.

Challenges for transport and logistics companies in 2026

The regulatory changes now in force present several challenges for companies operating across the EU.

Technological challenges:

upgrading or replacing IT systems
integrating with new platforms such as ICS2, AES PLUS, NCTS and ELO
implementing structured electronic data-exchange processes

Organisational challenges:

training staff in new regulatory procedures
assigning clear responsibility for system compliance
reorganising customs-clearance workflows

Financial challenges:

increased IT investment
additional costs linked to CBAM compliance
financial risks arising from delays or regulatory breaches

How companies should respond

In 2026, businesses are advised to focus on practical implementation by:

verifying and updating EORI data and national customs registrations
completing registration in mandatory systems such as ICS2, ELO and CBAM
providing targeted training for operational and administrative staff
reviewing supply chains for CBAM exposure
testing IT systems under real operational conditions
working closely with software and compliance providers
updating internal procedures and documentation

Companies that respond quickly and systematically are better positioned to maintain operational continuity and regulatory compliance in the new EU transport environment.