EU Regulation 2026: how to prove non-preferential origin in customs

Key data

Companies with international supply chains face a relevant procedural change: the Commission Implementing Regulation (EU) 2026/1422, published on 30 June 2026, amends Regulation (EU) 2015/2447 and updates the procedural rules for proving non-preferential origin of goods to the customs authorities of the EU Member States.

Non-preferential origin is not a minor procedure: it determines whether anti-dumping tariffs, safeguard measures or import restrictions apply to a good. Getting this wrong has direct economic consequences.

What does this regulation establish?

Regulation 2026/1422 updates the procedural rules relating to proof of non-preferential origin of goods, amending Implementing Regulation (EU) 2015/2447, which is the implementing regulation of the Union Customs Code.

The non-preferential origin of a good is the country where it has been produced or substantially transformed, without any preferential trade agreement between that country and the EU. This data is key because it determines what commercial policy measures apply:

• Anti-dumping tariffs: applied when a country is detected exporting at artificially low prices.
• Safeguard measures: temporary restrictions to protect European industries.
• Import restrictions: limitations for reasons of security, health or commercial policy.

The changes introduced affect the documentary and procedural processes that economic operators must follow to prove that origin to customs authorities. Although the full text of the regulation details the specific articles modified in Regulation 2015/2447, the practical impact is concentrated on the way proof of non-preferential origin is presented, verified and managed in each customs operation.

Economic and operational impact

The impact of this regulation is not abstract. Incorrect proof of origin or failure to adapt to the new procedures can trigger concrete economic consequences:

• Delays in customs clearance: the goods are held until the documentation is corrected, with the storage and logistics costs that this entails.
• Incorrect application of anti-dumping tariffs: if the declared origin is not correctly proven, customs may apply an anti-dumping tariff that should not apply, or conversely, fail to apply one that should, with risk of subsequent settlement.
• Penalties for non-compliance: the presentation of incorrect origin documentation or non-compliant with the new procedures can result in administrative penalties.
• Customs reviews and audits: companies with a history of origin incidents are subject to greater scrutiny by customs authorities.

The impact is especially relevant for companies with complex international supply chains, where the origin of components or final products can be difficult to determine and document accurately.

Who does it affect?

• Importing companies that bring goods from third countries (outside the EU) and must prove their origin to Spanish customs or any other Member State.
• Exporting companies that must certify the origin of their products so that recipients in third countries can comply with their own customs obligations.
• Customs operators and customs agents who manage procedures on behalf of importers and exporters.
• Companies with complex international supply chains, especially in industrial, textile, electronics, automotive and food sectors, where the origin of products may involve multiple countries.
• CFOs and operations directors responsible for managing customs risk and regulatory compliance in foreign trade operations.

Practical example

A Spanish textile company imports fabrics from an Asian country not covered by any preferential agreement with the EU. When submitting the customs declaration, it must prove the non-preferential origin of those fabrics so that customs can determine whether or not to apply an anti-dumping tariff in force on that type of product from that country.

With the entry into force of Regulation 2026/1422 on 25 June 2026, the procedures for presenting and verifying that proof of origin have changed. If the foreign trade department of that company continues to use the forms or procedures of Regulation 2015/2447 without the updates introduced, customs may reject the documentation, hold the goods and request additional documentation. The result: delays in the supply chain, port storage costs and risk of additional tariff settlement.

The solution is to review with the customs agent or foreign trade advisor the new procedural requirements before the next import.

What should companies do now?

1. Review the documentary processes for non-preferential origin currently in use and compare them with the new requirements of Regulation 2026/1422, which has been in force since 25 June 2026.
2. Contact the customs agent or foreign trade advisor to confirm that the origin certification procedures used in each operation are adapted to the new regulation.
3. Identify higher-risk operations: those with products from countries subject to anti-dumping tariffs or safeguard measures, where an error in origin has greater economic impact.
4. Update internal instructions to the foreign trade and logistics team on the new origin proof procedures, avoiding the continued use of outdated templates or forms.
5. Review contracts with international suppliers to ensure they provide origin documentation in accordance with the new requirements, as the responsibility to prove origin rests with the importer.

Official source

View complete regulation in official source — EUR-Lex: Commission Implementing Regulation (EU) 2026/1422

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=CELEX:32026R1422