The Italian Customs and Monopolies Agency has unexpectedly suspended the effectiveness of Circular No. 18/D of 8 July, which clarified—consistent with the position we have successfully argued before the courts for years—the distinction between importation and placing on the market. The suspension is intended to allow further assessment and avoid providing potentially misleading guidance to economic operators.

The circular explained that, in B2B transactions, customs clearance does not necessarily coincide with placing a product on the market, which occurs only when the product is subsequently sold or supplied. This distinction is particularly important where imported goods require further processing or quality control at the importer’s warehouse before being distributed.

The document also introduced an importer’s declaration designed to facilitate—not replace—customs inspections by helping customs officials determine whether the products were already intended for the final user or still required additional processing before being placed on the market.

After an initial sigh of relief, operators are once again left waiting for a definitive position from the Customs Agency.