ELAN 2026: What Changes for Agricultural Importers with Third Countries

Key data

Spanish importers of agricultural products from countries outside the EU face a significant development: the Commission Implementing Regulation (EU) 2026/2389, published on 29 October 2026, opens the door for issuing authorities of third countries to voluntarily integrate into ELAN, the EU's electronic platform for managing import licenses and certificates in the agricultural sector.

The change is not immediately mandatory, but it marks the beginning of a transition towards complete digitalization of international agrifood trade. Companies operating with suppliers from countries that adopt ELAN will notice concrete differences in their customs operations.

What does this regulation establish?

Commission Implementing Regulation (EU) 2026/2389 amends four previous regulations to incorporate the possibility of voluntary participation by third countries in ELAN during the transitional phase. The affected regulations are:

• Commission Implementing Regulation (EU) 2016/1239
• Commission Implementing Regulation (EU) 2020/761
• Commission Implementing Regulation (EU) 2020/1988
• Commission Implementing Regulation (EU) 2025/1272

What is ELAN? It is the European Union's digital platform designed for electronic management of import licenses and certificates in the agricultural sector. Until now, its use was reserved for the authorities of EU Member States. With this regulation, issuing authorities of third countries can voluntarily join during the transitional period.

The measure is voluntary: no third country is obliged to adopt ELAN during this period. However, those that do will be able to streamline their procedures with the EU and offer greater document security to their European buyers.

Economic and operational impact

The direct impact for Spanish importers is not measured in fees or new immediate economic obligations, but in operational efficiency and reduction of administrative burden. The concrete benefits that can be generated by the adoption of ELAN by exporting countries are:

• Reduction of border processing times: electronic management of certificates eliminates the need to submit physical documentation, which speeds up customs clearance.
• Greater traceability: certificates managed via ELAN are integrated into the EU platform, facilitating verification and reducing the risk of document fraud.
• Fewer administrative incidents: digitalization reduces errors in data transcription and discrepancies between documents.
• Coexistence of systems during transition: companies must be prepared to manage both ELAN digital certificates and traditional documentation, depending on the country of origin of the goods.

The cost of adaptation for importers is low at this stage, since the ELAN platform is managed by issuing authorities, not by private companies. However, logistics and foreign trade departments must understand the system to take advantage of its benefits when third country suppliers join.

Who does it affect?

• Spanish importers of agricultural products from countries outside the EU (cereals, fruits, vegetables, meat products, dairy, oils, wines and others under import quota or license).
• Logistics operators and customs agents who manage the clearance of agrifood goods at the border.
• Spanish customs authorities that will have to process certificates in both ELAN format and traditional format during the transitional period.
• Issuing authorities of third countries that decide to voluntarily join ELAN to facilitate their exports to the EU.
• Agrifood sector companies with international supply chains that depend on import licenses or certificates to operate.

Practical example

Imagine a Spanish cereal importing company from a third country—for example, Ukraine or Morocco—that operates under tariff quotas managed through import certificates regulated by Regulations (EU) 2020/761 and 2020/1988, both amended by this regulation.

Until now, the issuing authority of that country issued the certificates on paper or through its own digital systems, and the importer had to present them physically at customs. With that country's voluntary accession to ELAN, the process changes:

1. The issuing authority of the third country issues the certificate directly on the ELAN platform.
2. Spanish customs authorities access the certificate electronically, without the need for physical documentation.
3. Customs clearance is expedited and the importer reduces the risk of delays due to document incidents.

During the transitional period, if that country has not yet joined ELAN, the importer will continue to operate with the traditional system. The key is to identify which supplier countries adopt ELAN and adapt internal processes accordingly.

What should companies do now?

1. Identify affected supplier countries: review which third countries agricultural products are imported from under license or certificate, and track which ones voluntarily join ELAN during the transitional period.
2. Inform the logistics and foreign trade department: the team managing customs clearance must be aware of ELAN's existence and be prepared to receive certificates in digital format when suppliers adopt it.
3. Coordinate with the customs agent: ensure that the usual customs agent knows about the ELAN system and can manage both digital and traditional certificates during the coexistence of both systems.
4. Review contracts with international suppliers: if contracts include clauses on import documentation, consider whether it is necessary to update references to contemplate the possibility of ELAN certificates.
5. Monitor the evolution of the transitional period: the application is voluntary now, but the trend is towards mandatory digitalization. Anticipating that scenario reduces the cost of future adaptation.

Official source

Consult the complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602389