… urges cargo veteran, Larry Coyne, CEO of Coyne Airways and its parent, Coyne Aviation. An uneven regulatory approach causes cargo to migrate between EU airports, driven by differences in national implementation of customs regimes after the EU abolished the EUR 150 customs-duty exemption for low-value consignments and introduced a temporary EUR 3 customs duty per item category.
CargoForwarder Global discussed this hot topic with him, on the sidelines of the recent EU Cross-Border E-commerce Forum in Liège, and given the clarity of his arguments, requested that he summarize them for us in the form of an article. Here is the result:
I came to Liège for several reasons, but one of the main ones is the disruption caused by the way the EU’s new low-value e-commerce customs regime has been implemented. The underlying policy objective is understandable. From 01JUL26, the EU abolished the EUR 150 customs-duty exemption for low-value consignments and introduced a temporary EUR 3 customs duty per item category.
EUR 1 billion a year
The scale of the e-commerce market makes the change significant: the European Commission estimates that around one billion e-commerce purchases enter the EU each year, and the new regime is expected to generate approximately EUR 1 billion a year in additional customs revenue.
The EUR 3 duty itself was not the issue. The problem was the uneven implementation of the customs requirements around it.
At certain EU entry points, I understand that e-commerce operators were required to provide substantial cash deposits or comprehensive financial guarantees to cover potential customs liabilities. I understand that, in some cases, the requirement was around EUR 1 million. For operators working on relatively tight margins, tying up that amount of capital – or securing a guarantee at significant cost – can materially change the economics of a route.
Redirecting flights
The consequence was predictable. Where one airport imposed a significant additional financial burden and another did not, the cargo had an incentive to move. Airlines and e-commerce operators could simply redirect flights to alternative European gateways and then distribute the goods onward within the EU/EEA. Cargo will always seek the most commercially efficient route, and sophisticated shippers will arbitrage differences in cost and regulation.
This is particularly significant in e-commerce because of the sheer scale and frequency of the traffic. The EU has described the growth in low-value parcels as enormous; Chinese e-commerce parcels alone reached an estimated EUR 5.8 billion in 2025, compared with EUR 1.4 billion in 2022.
Losing an entire ecosystem of business
The impact on an airport can therefore be much greater than the customs revenue itself. Consider a simple illustration. If a 50-ton e-commerce aircraft load consisted primarily of individual parcels averaging 200 grams, that would represent approximately 250,000 items. At EUR 3 per item, that equates to EUR 750,000 of customs duty on a single 50-ton load – before considering the precise tariff-category rules, which mean the EUR 3 is not necessarily charged separately on every physical piece. The calculation is therefore illustrative rather than a prediction of the actual duty collected.
But the more important point is what happens when the traffic moves elsewhere.
The economic value of a major e-commerce flight extends well beyond the airline. It supports the airport, ground handlers, customs brokers, warehouses, trucking companies, security providers, fuel suppliers and numerous other service businesses. Losing a regular e-commerce operation therefore means losing an entire ecosystem of activity – not simply landing fees or cargo-handling revenue.
Liège is a particularly good illustration of this. E-commerce has become an important part of the airport’s cargo proposition; for example, Belgium has invested specifically in making its customs infrastructure attractive to e-commerce, including the BE-GATE platform developed to process large volumes of e-commerce customs declarations at Brussels and Liège.
The decline in volume hasn’t stopped
That is why I find the consequences of an uneven regulatory approach concerning. If a policy intended to create a level playing field instead causes cargo to migrate between EU airports according to differences in national implementation, the result is not a level playing field at all.
I understand that the additional security/deposit requirements have subsequently been lifted. However, my understanding is that traffic at some of the affected airports has not returned to anything like its previous levels. Once an airline or major e-commerce customer has established an alternative gateway, it is not necessarily going to reverse that decision simply because the original obstacle has been removed. Routes, handling arrangements, customs processes, trucking networks and customer supply chains have all changed.
Once gone, cargo might not return
This is the real lesson for policymakers: cargo flows are remarkably mobile. Once a shipper discovers that moving through another airport saves money, reduces administrative friction or avoids capital being tied up in guarantees, that alternative can quickly become the new normal.
I am therefore surprised by how little pushback there appears to have been from some of the industry stakeholders, who ultimately bear the commercial consequences. Airports, airlines, handlers and logistics providers have a considerable collective interest in ensuring that customs policy is implemented consistently across the EU.
The implementation of customs regime changes needs to recognize the commercial reality of air cargo. In a highly competitive market, even a relatively small regulatory difference between two gateways can move hundreds of tons of cargo – and once that cargo moves, it may be considerably harder to bring it back than policymakers expect.
The EU itself now appears to recognize this risk: the legislation specifically requires the Commission to assess, from 01OCT26 and monthly thereafter, whether the new arrangements are causing diversion of trade flows. Cargo will always find a way. The question is whether European policymakers understand where it will go when regulation makes one gateway materially less competitive than another.
Larry Coyne, TIACA Air Cargo Hall of Fame member
