Now underway. HMRC has confirmed the retirement timetable for the current Trader Support Service platform. A new platform goes live on 20 October 2026. Access to the outgoing platform ends on 30 November 2026 — see HMRC’s guidance on GOV.UK.

TSS and the Windsor Framework

Northern Ireland sits inside the UK’s customs territory. The Windsor Framework keeps it aligned with EU rules for goods that risk moving into the EU single market. Trader Support Service is how that commitment gets executed on the ground. TSS lets traders use a simplified, two-stage customs procedure for GB-NI movements: a Simplified Frontier Declaration at the border, then a Supplementary Declaration afterwards. It stays free to use, and it remains the main route most GB-NI traders rely on.

The move to a new TSS platform does not change any of this. It is an infrastructure change, not a change in customs law. TSS itself is not closing, and the GB-NI route stays fully in place. Only the digital front end is being replaced. The transition window is short: the new platform takes over fully from 20 October 2026, and the outgoing system disappears from 30 November 2026.

What’s Changing vs What Isn’t

Nothing about the underlying customs process changes. Supplementary Declarations remain the same legal instrument under the same simplified procedure. They are still due by the tenth calendar day of the month after the goods move, and the same commodity, origin and valuation detail is still required. HMRC’s guidance confirms that existing customs processes and declaration structures are being maintained, not redesigned. Traders already signed up for the outgoing TSS will be migrated automatically to the new service. No fresh registration is required.

The Hard Deadline: 30 November 2026

One obligation matters most in the run-up to 30 November 2026. A Supplementary Declaration is not complete until it shows as Closed on the TSS Portal — submitted, paid or calculated is not enough. HMRC’s bulletins set no formal penalty for missing the cut-off, but the exposure is still real: access to the outgoing platform disappears on 30 November, whatever is still open in it, while the underlying duty and declaration obligation does not disappear with it. HMRC is explicit that traders “remain responsible for completing and submitting your Supplementary Declarations and paying any duties due,” and that responsibility holds regardless of the state of the platform housing them.

What Traders Should Do Now

Traders and representatives should audit every open Supplementary Declaration now — anything sitting in Draft, Input Required, Pending Payment, Tax Calculation Verification or Fiscal Hold status. Declarations left open will not simply carry over to the new platform: HMRC has not published a carry-over mechanism, and the safer assumption is that anything unresolved must be dealt with directly through HMRC, outside the normal TSS workflow.

The TSS route itself is not going anywhere, and account continuity is already assured for anyone currently registered. Even so, treat 30 November as a hard operational deadline in practice. HMRC has not framed it as a statutory penalty date, but the alternative is an open customs liability with none of the current tools available to close it out.

Key Dates and Next Steps

From 20 October 2026, the new platform becomes the only route for pre-lodging movements. The outgoing TSS platform closes permanently on 30 November 2026.

If you have questions about how this affects your business or your outstanding declarations, please get in touch with us today. . This note is based on HMRC’s Trader Support Service guidance on GOV.UK and TSS Bulletin 227th Edition, published by the Northern Ireland Customs & Trade Academy: https://www.gov.uk/guidance/trader-support-service. It is a summary for general orientation, not customs or legal advice.

Follow-up to “EU Customs Reform: Indirect Representation Is Changing” (17 September 2026)

Now confirmed. What was still a Council position four days ago is now law. Regulation (EU) 2026/2108 was signed in Strasbourg on 16 September 2026, published in the Official Journal on 19 September 2026, and entered into force the following day — read the full text on EUR-Lex

What’s changing for indirect representation

For non-EU businesses trading into the EU — and the customs brokers and indirect representatives who act for them — the reform confirms how indirect representation will work going forward. Non-EU established companies can keep importing and trading in the EU; that route is not closing. Its compliance profile has changed for good, though, and the clock is now running on a fixed twelve-month runway to general application on 21 September 2027. The Regulation also establishes a new European Union Customs Authority to oversee the reformed Code.

The “importer” has a formal legal definition for the first time. E-commerce gets its own version too: a separate “importer for distance sales” concept applies to online sellers and platforms.

Liability: EU-established vs. non-EU-established principals

The bigger shift is in liability. An indirect representative — often a customs broker acting on a client’s behalf — no longer simply shares the customs debt with its principal. Where the principal is EU-established, the representative remains jointly and severally liable, much as today. Where the principal is not EU-established, the position is stricter: the representative is now deemed to be the importer itself — full financial and non-financial exposure, not a shared one.

The requirement for indirect representatives to be EU-established is confirmed and reinforced. A non-EU seller or platform acting as “importer for distance sales” is expected to work through a representative holding Authorised Economic Operator (AEO) status. Non-compliance by distance-sales importers now carries a tiered EU-wide penalty.

What this means for indirect representatives and non-EU businesses

Customs brokers and indirect representatives should expand due diligence into a principal’s product compliance — not just classification, valuation and origin. Fee structures, guarantees and client-acceptance criteria are also worth revisiting, a trend already underway since CJEU C-714/20 and now substantially widened.

For non-EU businesses, the door stays open: the Regulation confirms that importing and trading in the EU without an EU establishment remains possible. Representatives will reasonably ask for more in return, though — more data, more assurances, and potentially higher fees, given their heavier exposure. Distance-sales sellers should confirm their representative holds, or is obtaining, AEO status.

Key dates for the new Union Customs Code

The provisions on importers, exporters and customs representatives become directly applicable across the EU from 21 September 2027, with EU Customs Data Hub-linked provisions following from 1 July 2028. If you have any questions about how this reform affects your business, please get in touch with us today.

This note is based on Regulation (EU) 2026/2108 of the European Parliament and of the Council of 16 September 2026 establishing the Union Customs Code and the European Union Customs Authority, as published in the Official Journal of the European Union on 19 September 2026: https://eur-lex.europa.eu/eli/reg/2026/2108/oj/eng. It is a summary for general orientation, not legal advice.

The Council formally adopted its position at first reading on 3 September 2026 (document 8190/2/26 REV 2). European Parliament sign-off and Official Journal publication are still to come — but Council and Parliament already reached full political agreement back in March 2026, so the substance below is unlikely to change much before it becomes law.

The headline

The EU is finalising the biggest overhaul of its customs code since 1992. For non-EU businesses trading into the EU — and for the companies that represent them at customs — the reform changes how indirect representation works. Non-EU established companies can keep importing and trading in the EU; that route is not closing. But the compliance profile of it is changing substantially, and it is worth preparing for now rather than waiting for the Official Journal text.

What’s actually changing

If you act as an indirect representative

• Your liability shifts from “pay the duty if it’s wrong” to full regulatory compliance for the goods you represent.
• Expect to expand due diligence into your principal’s product compliance — not just classification, valuation and origin.
• Distance-sales clients will need you to hold AEO status to keep representing them.
• Fee structures, guarantees and client-acceptance criteria will likely need revisiting — a trend already underway since CJEU C-714/20, now materially widened.
• Some representatives may step back from indirect representation altogether, tightening market capacity.

If you are a non-EU business trading into the EU

• You can continue importing and trading in the EU without an EU establishment — this route is not being closed.
• Expect your representative to ask for more: more data, more assurances, potentially higher fees and guarantees.
• If you sell via distance sales/e-commerce, confirm your representative holds — or will obtain — AEO status.
• Start reviewing your representation arrangements and supply-chain compliance now; the runway after formal publication will be short.

Anticipated timeline

Please get in touch with us now

If you have any questions about how this reform — and the changes to indirect representation in particular — affects your business, please get in touch with us today. This note is based on Council document 8190/2/26 REV 2 (position at first reading, adopted 3 September 2026) and Council of the EU press communications; it is a summary for general orientation, not legal advice, and reflects a text not yet published in the Official Journal.