For many years, customs compliance focused on tariff classification, customs valuation, origin, licensing requirements and duty management. That position changing rapidly. Today, environmental, social and governance (ESG) legislation is increasingly being enforced through trade measures, customs controls on imports and exports and trader registration systems which must be aligned to your imports and exports systems.
The key message is Regulators are no longer asking businesses simply to report on sustainability. They are increasingly requiring importers and exporters to demonstrate compliance before goods can enter or leave the EU market. Customs declarations, importer registrations, exporter registrations and supply chain due diligence systems are becoming the mechanism through which regulators verify carbon emissions, deforestation compliance, packaging obligations and supply chain transparency.
The result is that customs and sustainability are converging. Modern importers and exporters must now manage a growing range of ESG obligations that extend far beyond traditional customs compliance. Much of this information must be supported by customs declaration data and increasingly requires specific registrations before goods can be imported or exported. This trend is reflected across CBAM, EUDR, packaging regulations, CSRD reporting requirements and emerging forced labour legislation.
We take a look at these below.
Why Customs Has Become an ESG Function
Governments are using customs controls because they provide a highly effective mechanism for enforcing sustainability requirements.
Import and export declarations identify:
This information allows authorities to connect physical movements of goods with ESG compliance obligations.
As a result, the information captured in a customs import declaration will now also form part of the ESG audit trail.
Core Registration Requirements for Importers and Exporters
EORI Registration
The starting point for all importers and exporters is registration as an economic operator.
Within the EU, businesses involved in customs activities require an Economic Operators Registration and Identification (EORI) number.
The EORI number is used to:
Increasingly, it also acts as the identifier linking an organisation to ESG-related compliance obligations.
Without an EORI number, businesses cannot generally submit import or export declarations.
Without a linked ESG registration e.g. for CBAM or Deforestation equally importers (and exporters) cannot get clearance for their declarations. Any EU-established importer whose total annual imports of CBAM covered goods exceed the 50-tonne threshold must register as an Authorised CBAM declarant. Imports of hydrogen and electricity trigger mandatory registration at any quantity (0 tonne threshold).
CBAM Requirements for Importers
The Carbon Border Adjustment Mechanism (CBAM) is the clearest example of ESG legislation being enforced through customs processes.
CBAM applies to imports of:
Authorised CBAM Declarant Registration
Importers of CBAM products are required to register as Authorised CBAM Declarants and must establish systems capable of meeting CBAM obligations.
The registration process requires organisations to have:
As part of the application, you must furnish:
If you are an importer not established in an EU Member State, you must appoint an Indirect Customs Representative (ICR) that is established in an EU Member State to obtain authorised CBAM Declarant status on your behalf. The ICR will take on the reporting and financial liabilities and will effectively act as the “importer” for the parties it represents.
Why CBAM Registration Is Needed on Import Declarations
Customs declarations contain key information including:
Authorities use this information to assess whether goods fall within the scope of CBAM and to reconcile imported volumes against:
Without Authorised CBAM Declarant status, importers may be restricted from importing certain CBAM products.
CBAM Requirements – information from original manufacturers
Although CBAM compliance obligations legally sit with the EU importer, exporters and non-EU manufacturers play an increasingly important role where importers seek to rely on actual, independently verified emissions data rather than on default values. Using actual values can materially reduce CBAM certificate costs, but it also entails more stringent data, verification and audit requirements.
The CBAM Registry includes functionality enabling non-EU installation operators to upload emissions information for use by EU importers. This is typically:
Exporters that cannot provide verified emissions data may place their customers at a competitive disadvantage, as importers will be forced to use default emissions values, which can significantly increase CBAM costs.
EUDR Requirements for Importers and Exporters
The EU Deforestation Regulation (EUDR) introduces another registration-driven compliance framework.
EUDR focuses on proving that products are:
Products potentially affected include commodities such as:
After many delays the regulation now takes effect on 31 December 2026 for businesses importing, exporting or placing in scope products on the EU market. Therefore, you will need to have communicated with suppliers, completed your due diligence and registered with the EUDR Information system within the next two months.
For the HS codes recently added to scope, businesses will have an extra year to prepare as obligations for newly in scope products won't come into effect until 31 December 2027.
Due Diligence Statement Registration
Before importing covered products into the EU, or exporting them from the EU, Importers and Exporters must complete due diligence and submit a Due Diligence Statement (DDS) through the EU Information System.
The DDS creates a unique reference number linked to:
This reference number effectively becomes the ESG compliance identifier for the transaction.
Why EUDR Registration Is Required on Import Declarations
Authorities will use the DDS reference number to connect imports to the due diligence documentation held within the EUDR Information System.
This allows authorities to verify that:
Without an appropriate DDS reference number, goods may be delayed, selected for customs intervention or prevented from entering or exiting the EU market.
Packaging and Packaging Waste Regulation (PPWR)
Another major ESG development is the EU Packaging and Packaging Waste Regulation and the continued expansion of national Extended Producer Responsibility (EPR) schemes.
These measures are designed to:
Packaging Registration Requirements
Organisations placing packaged goods on the market increasingly need to:
Importers
Importers are frequently treated as the producer for packaged products entering the EU from third countries.
This means importers may need to:
Exporters
Exporters must increasingly understand packaging obligations in destination markets.
Customers are increasingly requesting information regarding:
Customs import data is likely to become an increasingly important source of information for validating packaging obligations and identifying businesses placing packaged goods on the market.
The Growing Importance of Supply Chain Due Diligence
Alongside CBAM, EUDR and packaging regulations, businesses are facing increasing expectations regarding:
Companies are increasingly expected to map supply chains, identify suppliers, maintain traceability records and assess environmental and human rights risks throughout their value chains.
Importers and exporters should therefore be capable of demonstrating:
The Direction of Travel
The direction of travel from regulators is clear.
Historically businesses needed:
Increasingly businesses will need:
Regulators are progressively moving ESG compliance away from voluntary reporting and towards customs-enforced market access controls.
The customs declaration is becoming the gateway through which authorities validate:
The likely future development is further integration between customs systems, sustainability reporting platforms and trader registration frameworks. Businesses that treat ESG as solely a reporting exercise may find themselves unprepared for a regulatory environment where sustainability credentials increasingly determine whether goods can legally cross borders.
Conclusion
The convergence of customs and ESG represents one of the most significant developments in international trade compliance for decades.
Importers and exporters must now view customs declarations as more than tax and duty documents. They are increasingly becoming the primary mechanism through which authorities verify environmental, social and governance compliance.
The organisations best placed to succeed will be those that integrate customs, procurement, sustainability, tax and supply chain functions, ensuring that the appropriate registrations, due diligence processes and ESG data are in place before products are imported or exported.
In short, market access is increasingly becoming dependent on ESG compliance, and customs authorities are becoming one of the principal enforcement mechanisms through which that compliance is assessed.
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