Supplier declarations from 2028: What’s changing for businesses

The EU customs reform is the talk of the town. A key component is EU Regulation 2026/1183, which will change the requirements for supplier declarations from 23 June 2028.

Businesses should start preparing for the new requirements now and adapt their processes, data and systems accordingly.

In this article, you will learn exactly what is changing, what role structured data plays and how you can future-proof your preference management.

• New requirements for supplier declarations will apply from June 2028.
• There will be a greater focus on structured origin and preference data.
• Companies should review their processes, data and interfaces at an early stage.
• Mercoline provides support for the SAP-integrated mapping of preference processes.

Supplier’s declarations are a key component of preferential trade management. They serve as proof for companies of the originating status of goods and thus form an important basis for the issuance of preferential certificates.

As part of the upcoming EU customs reform, the requirements for supplier’s declarations are set to change fundamentally.

In future, the focus will no longer be on a mandatory, pre-defined wording. Instead, the EU is defining a fixed structure comprising individual data elements, which must be provided either mandatorily or optionally depending on the type of supplier’s declaration.

These include, for example, information on:

• the supplier and the customer
• the goods in question
• origin and preferential arrangements,
• raw materials used
• cumulation and other origin-related details

In doing so, the EU is laying the groundwork for the exchange of supplier’s declarations in a more structured and electronic manner.

A standardised form is not prescribed. What is crucial, rather, is that the required data is available in accordance with the specified structure.

The change does not merely concern the format of supplier’s declarations. In future, it will be even more crucial how the necessary origin and preference information is held and processed within the business.

Businesses should therefore check whether the required data is available in a structured format and can be reliably exchanged between the relevant systems and business partners.

This is particularly relevant for companies that regularly issue supplier’s declarations or manage a large number of incoming declarations and use the information contained therein for their own preference determination.

Even though the new requirements do not come into force until June 2028, businesses should not waste any time: the transition period offers an opportunity to review existing processes.

This does not mean that all processes need to be overhauled today. Rather, it allows businesses to identify at an early stage where the new requirements will impact existing workflows and data structures.

The following questions, for example, may be helpful:

• What data is currently required to produce supplier declarations?
• Where is information on goods, origin and preferential treatment maintained?
• Is this data available in a complete, up-to-date and structured format?
• How are supplier declarations currently produced, received and processed?
• Where in the current process are manual tasks still carried out?
• Are existing systems and interfaces prepared for a more structured form of electronic data exchange?

The answers reveal where there may be a need for action by 2028. This may relate to the quality and availability of master data, as well as existing interfaces, manual steps or the system-based processing of supplier declarations.

The new requirements for supplier declarations do not only concern their formal structure. Greater emphasis is also being placed on the quality and availability of the underlying origin and preference data.

Companies should therefore use the time leading up to 2028 to review existing data sources, processes and interfaces, and to identify any necessary adjustments at an early stage.