The decision of ECJ in Polo Lauren case confirmed the regulation 3295/94 as the legal basis of manufacturing fiction theory, which enables its member to detain goods in-transit on the basis of its domestic law. This decision arouses opposition from trade liberalists. The following Indian-EU generic drug case leads to a reflection of border measures by EU, the ECJ's preliminary decision in the famous NOKIA/ Philips case and the enforcement of regulation 608/2013 removed doubts on EU customs measures;however, with EU's action to amend its trademark regulation, EU has diverted its attention of regulating goods in-transit to substantial law level.