In this edition of our “Ask the Experts”, Trade Duty Refund spoke with international trade and logistics expert, Cristina Piangatello, who is a seasoned consultant in customs and EU trade compliance, based in Italy. With a robust background in freight forwarding, international trade advisory, and hands-on expertise as an AEO Specialist and Export Compliance Officer, Cristina helps companies across sectors—including food & beverage, fashion, consumer goods, pharmaceuticals, chemicals, automotive, and machinery—navigate regulatory complexities and ensure compliant market access. Fluent in both Italian and English, she is recognized for guiding businesses through tariff classification, origin determination, customs valuation, export controls, and securing crucial customs authorizations. Cristina is a new member of the Trade Duty Refund trade advisory group.

5 Key Questions for Italian Exporters and Importers

1. What are the most frequent mistakes Italian companies make in tariff classification and customs valuation, and how can they avoid costly penalties?

Italian companies often neglect customs classification, choosing generic, non-specific customs codes and thus ignoring the general classification rules established by EU regulations: yet, appropriate customs classification is the basis for the compliant application of EU customs rules and trade policies. More generally, Italian companies have always underestimated preventative customs compliance, relying on their own customs brokers. However, since these brokers focus on operational fluidity, they often lack the time to provide companies with adequate and dedicated consulting support to ensure proper customs operations that comply with applicable regulations. On the other hand, customs non-compliance has become highly critical for companies, given the heavy penalties, including criminal penalties, imposed and applied in the event of violations of increasingly extensive customs regulations. The key concept that companies must assimilate to safely navigate the treacherous waters of international trade is therefore that of preventative customs compliance.

2. How should Italian exporters prepare for evolving EU export control regulations, especially when accessing non-EU markets?

The field of export control is increasingly complex: not only regulations for dual-use products and actual military goods, but also international sanctions, embargoes, and various objective and subjective restrictions. To minimize sanctions and product detentions, companies should implement an internal compliance program (ICP). This program is a structured set of policies, procedures, roles, controls, and records, approved by top management, which ensures that every shipment/supply (including technology) complies with applicable regulations and is traceable, avoiding the risk of sanctions and reputational damage. The key principles of an Internal Compliance Program include senior management commitment, a clear organizational structure with defined responsibilities, staff training, transaction and party verification processes, risk assessments of final disposition and diversion, as well as proper recordkeeping and comprehensive documentation: this last aspect allows to maintain accurate records of all transactions, authorizations, licenses, and documentation related to assessments and verifications, ensuring the possibility of future audits and controls.

3. What are the strategic benefits of obtaining AEO (Authorised Economic Operator) status for Italian firms, and what challenges might they face during the application process?

Authorized Economic Operator (AEO) status reduces operational variability along the logistics chain, accelerates customs flows, and frees up financial resources currently tied up in guarantees and ancillary costs. For companies with significant import/export volumes, the expected return is more predictable lead times, lower logistics costs, and greater commercial bankability with international customers and partners. The procedure requires fine-tuning of internal processes and controls: it is an organizational investment, not a formal requirement. The strategic benefits from a board perspective are diverse: the company gains easier access to simplifications (simplified declarations, centralized clearance, global guarantee); it benefits from a lower risk profile in customs systems, which entails fewer documentary/physical checks and priority in the event of a detention; it may experience a reduction in guarantees and working capital, and an improvement in the cash conversion cycle. Ultimately, the AEO process strengthens the internal control system (policy, traceability, roles, audit trail), and in the event of an audit or dispute with customs authorities, the company’s position will be more defensible.

4. Can you highlight best practices for managing product certification and labelling requirements for goods exported both within and outside the EU?

When goods are imported into the EU, general product labeling regulations must be followed, as well as specific regulations for certain product types; in addition, many products require the CE marking. Conversely, when goods are exported to non-EU countries, specific regulatory provisions in force in the countries of destination of the exported products must be followed, including any product certification requirements required for marketing. In any case, it is essential to start with an analysis of the regulatory requirements, and therefore it is necessary to identify and study the applicable legislation. Clearly, from an informational perspective, field research can also be helpful, checking on-site at sales sites to see how products are packaged, labeled, and, if applicable, marked, to understand the requirements in a given country. Talking to customers on the matter is also certainly helpful. Furthermore, it is possible to consult EU databases that can assist in this informational effort. However, these methods are not always feasible for companies, which can therefore find the task of gathering information on product labeling and certification requirements burdensome. I believe it is essential for companies to rely on professionals with expertise in the field, who can quickly and accurately obtain the necessary information, as well as on certification bodies that can support them in the event that a product must meet certain quality or safety standards before being marketed in the EU or abroad. Offers practical guidance for regulatory and market access success.

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European exporters and importers who seek to ensure their processes are fully compliant with ever-evolving regulations and want expert guidance to navigate complexities can turn to the Trade Duty Refund trade advisory team. We specialize in advising on regulatory requirements, helping you optimize your cross-border sales, reduce risks of penalties, and improve your competitive edge in global trade. Let our experts guide you through compliance challenges so your trade operations run smoothly and successfully.