On 14 October 2025, the Single Administrative Document (SAD) PreUCC for imports is scheduled to be phased out completely. New import declarations must be submitted in accordance with Annex B of Delegated Regulation (EU) 2015/2446 (DA-UCC) and Implementing Regulation (EU) 2015/2447 (IA-UCC) (using codes such as H1 for free circulation, H7 for low-value shipments, I1 for simplified declarations, etc.) in line with the adaptation to the Union Customs Code (UCC) and European standards for the digitisation of customs procedures.
The replacement of the current system is in line with the strategy for the modernisation and standardisation of customs procedures in the European Union, as set out in the UCC Work Programme, which aims to establish a single, common set of data requirements and formats/codes for all customs declarations so that all Member States declare the same information in the same way, facilitating the automation of controls, interoperability between national and European Union systems, and better risk management, in a context of digitisation and growth in e-commerce.
This change is a milestone in import management, with a direct impact on importing companies, customs representatives and logistics operators.
Main changes introduced
- New declaration structure: Imports are presented with columns H/I which determine, for each procedure, which data elements are mandatory or optional. The Spanish Tax Agency (AEAT) has provided a series of tables and guides for each column, which must be used to map the requirements for each flow.
- Separation of roles and appearance of the figure of “Importer”: The declaration expressly distinguishes between Importer, Declarant, Representative and Consignee. The Importer now has its own field (with EORI or other recognised identification) and completion rules, which reinforces the traceability of the transaction.
- Greater granularity and controls: The level of detail required for valuation (method and adjustments), origin, previous documents, procedure codes and additional codes is increased, in accordance with the matrices in Annex B and the EUCDM/AEAT validations.
- Alignment with other EU customs systems: The structure is designed to integrate with AES (export), NCTS (transit), ICS2 (entry security control) and PoUS (customs status), promoting a more digital and consistent customs circuit.
Key deadlines
- Spain: 13 October 2025 is the last day on which the old SAD can be submitted for import operations. From then on, the new Annex B structure must be used.
- Other Member States: The obligation to use Annex B is common throughout the European Union, but each Member State is free to set its own dates within the framework of the UCC Work Programme.
Recommended actions for operators
- Data matrix by regime: For each flow (free circulation, warehousing, temporary admission, processing, low value, simplified), identify the applicable column H/I and the required documents/codes (procedure and additional).
- Technological adequacy: Align ERP/TMS and connectivity with the EUCDM and AEAT validations; conduct tests with your representative before the cut-off date.
- Roles and powers: Determine who should be listed as the importer and review representation mandates (direct/indirect). Verify EORI/ tions and consistency with identifying information (company name, address).
How can we assist you?
Our team of customs and international trade specialists can assist you in reviewing your import processes and adapting to the new system, building your H/I column matrix by flow, with templates and checklists, and coordinating with customs agents and technology providers.
Salinas & Partners, with more than 30 years of experience in international trade and indirect taxation, is at your disposal for any questions or comments that may arise.
