Is this the end for First Sale for Export in the European Union?

For a number of years, first under the discussions regarding the Modernised Customs Code ("MCC") and now under the implementation of the Union Customs Code ("UCC"), the concept of first sale has been under debate. The concept of "first sale", where certain conditions are met, allows an importer to use an earlier sale in a chain of sale as the basis for the transaction value at customs clearance in the EU even though there may be a later sale under which the actual introduction of the goods in the EU took place. Following last week’s publication of the drafts of the Union Customs Code Delegated Act and the Union Customs Code Implementing Act, commentators are suggesting that first sale for export will be abolished.