Customs and Trade Counsel — European Union

Anna Schmidt advises businesses on German and EU customs law, export controls, and sanctions compliance at GvW Graf von Westphalen in Frankfurt.

With 8 years of specialized experience in European customs and trade regulation, Ms. Schmidt provides pragmatic counsel to importers, exporters, and logistics providers navigating the increasingly complex landscape of EU customs procedures, tariff classifications, and economic sanctions regimes. Her practice sits at the intersection of German customs administration and pan-European Union trade policy, covering both contentious and transactional customs matters.

Practice Philosophy

Ms. Schmidt understands that customs compliance is not merely a regulatory obligation but a strategic factor in supply chain efficiency and cost management. She works proactively with clients to structure import and export operations for customs optimization, reduce duty exposure through legitimate planning mechanisms, and develop robust compliance frameworks that withstand EU-level audit scrutiny. Her guidance is grounded in daily experience with German customs authorities (Zoll) and the EU Customs Code framework that governs 27 member states.

Core Services

• ⚖️ Customs Classification and Valuation — Binding Tariff Information (BTI) applications, harmonized system classification advice, customs valuation methodology selection, and transfer pricing integration for customs valuation purposes
• 📜 Export Controls and Sanctions — Dual-use export licensing analysis under EU Regulation 2021/821, technology transfer compliance, sanctions screening procedures, and internal compliance program (ICP) development for German and EU export control authorities (BAFA)
• 🛡️ Customs Audits and Disputes — Representation in post-clearance audits, customs duty assessments, penalty proceedings, and appeals before the German Customs Investigation Office (Zollfahndungsamt) and EU-level dispute mechanisms
• 💼 Preferential Trade and Free Trade Agreements — Rules of origin determination, exporter registration under the EU's Registered Exporter (REX) system, and utilization of Korea-EU, Japan-EU, Vietnam-EU, and other FTA preference schemes
• 🧭 Supply Chain Customs Planning — Customs warehousing, inward and outward processing procedures, end-use authorization applications, and Authorized Economic Operator (AEO) certification preparation and maintenance

Key Consideration for Chinese Clients: The EU's Carbon Border Adjustment Mechanism (CBAM), which took full effect in 2026, imposes carbon pricing on imported goods in carbon-intensive sectors including iron and steel, aluminium, cement, fertilizers, hydrogen, and electricity. Chinese exporters to Germany and the broader EU must now account for CBAM declaration obligations, embedded emissions verification, and potential cost exposure. Ms. Schmidt advises Chinese manufacturing and trading companies on CBAM compliance strategies, including emissions data collection, verification partnerships, and exemption planning.

Industry Sectors Served

• 📦 Industrial Manufacturing — Machinery, automotive components, chemical products, and steel and aluminium imports into the EU
• 🏠 Technology and Electronics — Semiconductor import controls, dual-use technology licensing, and software export classification
• 🔍 Logistics and Freight Forwarding — Customs brokerage compliance, bonded warehousing operations, and customs representation arrangements
• 🔒 Consumer Goods and Retail — Product compliance (REACH, CE marking), tariff classification for mixed-product shipments, and e-commerce customs procedures under the EU's Import One-Stop Shop (IOSS)

Regulatory Monitoring

The EU customs and trade regulatory landscape evolves rapidly through new sanctions packages, trade defense measures, and customs code amendments. Ms. Schmidt provides ongoing monitoring and advisory services to clients, ensuring that trade operations remain compliant as regulations change. She publishes quarterly trade compliance briefings covering developments in EU customs procedure, sanctions policy, and free trade agreement utilization, helping clients stay ahead of regulatory developments affecting their supply chains.

Client Engagement Model

Ms. Schmidt offers a tiered engagement structure designed to meet the needs of clients with varying levels of customs exposure. For companies with limited EU trade activity, she provides targeted advisory engagements focused on specific transactions or regulatory questions. For clients with substantial and ongoing EU import and export operations, she offers a comprehensive customs compliance retainer that includes regular audits, training programs for customs declaration staff, and priority response for urgent customs matters such as customs holds or seizure notifications.

Her practical experience includes assisting Chinese manufacturing companies with the establishment of EU customs compliance infrastructure, including customs representation arrangements, AEO certification preparation, and the development of internal compliance programs that satisfy BAFA requirements for dual-use export controls. She also helps Chinese companies navigate the procedural requirements for appealing German customs decisions, including the multi-level appeals framework that proceeds from the Hauptzollamt through the Finanzgericht to the Bundesfinanzhof for questions of fundamental legal importance.

Strategic Advantage for International Clients

Ms. Schmidt's location in Frankfurt positions her at the center of German and European trade regulation, with direct access to the German customs administration headquarters, the BAFA export control authority, and the European Central Bank. This proximity enables her to maintain current knowledge of regulatory enforcement priorities and procedural developments that affect international trade operations. Her dual qualifications in German and European customs law provide clients with integrated advice that addresses both national implementation and supranational regulatory frameworks.

For Chinese manufacturing and trading companies exporting to Germany and the broader European Union, Ms. Schmidt offers specialized guidance on the practical implications of the CBAM transitional reporting period, including the methodology for calculating embedded emissions for Chinese industrial products, the verification standards required by EU-accredited verifiers, and the financial planning implications of the full CBAM implementation scheduled for 2026. She also advises on optimizing customs procedures through choices of customs regimes that can reduce duty exposure and streamline import clearance for regularly shipped products.