EU customs reform for ecommerce: the timeline to 2028
10 min readRepresenta GmbH
EU customs reform for ecommerce: €3 per item, product identifiers, a new handling fee and why customs will ask who your EU Responsible Person is.
Since 1 July 2026, parcels from outside the EU no longer enter duty-free because they are worth less than €150. The EU customs reform for ecommerce continues with product identifiers from 1 November 2026, a new Union Customs Code from 21 September 2027 and a central customs data platform from 1 July 2028. For manufacturers outside the EU selling directly to EU consumers, the change goes beyond cost: customs will ask who your economic operator in the EU is.
What the EU customs reform changes for ecommerce
Council Regulation (EU) 2026/382 (opens in a new tab) abolished the €150 duty relief and set a temporary flat duty; Commission Delegated Regulation (EU) 2026/1022 (opens in a new tab) added product identifiers. Then Regulation (EU) 2026/2108 (opens in a new tab) replaces the Union Customs Code, sets up an EU Customs Authority in Lille and lays the basis for an EU Customs Data Hub.
The ecommerce rules target distance sales: goods from a third country sold online and shipped to a customer in the EU (Article 5(15) of Regulation (EU) 2026/2108). Product law is unchanged: the General Product Safety Regulation (EU) 2023/988 (GPSR) and Regulation (EU) 2019/1020 still apply, but customs get more data to check them.
The timeline from 2026 to 2028
Key dates at a glance, from the final articles of each act:
| Date | What changes | Legal basis |
|---|---|---|
| 1 July 2026 | €150 relief abolished; flat €3 per item for most distance sales up to €150; product identifiers voluntary | Reg. 2026/382, Art. 1 and 2; Del. Reg. 2026/1022, Art. 1 and 2 |
| 20 September 2026 | New Customs Code in force; EU Customs Authority established | Reg. 2026/2108, Art. 229 and 287(1) |
| 1 November 2026 | Product identifiers mandatory for distance sales | Del. Reg. 2026/1022, Art. 2(3) |
| 10 days after the delegated act on the amount enters into force | Union handling fee per item | Reg. 2026/2108, Art. 20(2) and 287(4) |
| 21 September 2027 | Code applies in general: importer for distance sales, new release conditions | Reg. 2026/2108, Art. 287(2) |
| 1 July 2028 | €3 duty ends unless extended; Data Hub for distance sales; market surveillance may use its data | Reg. 2026/382, Art. 2 and 3(2); Reg. 2026/2108, Art. 41(9) and 285(2) |
How the €3 duty and the handling fee are charged
Until 1 July 2028, goods in a consignment worth up to €150 pay a flat €3 per item, not per parcel, if they are declared under the Import One-Stop Shop (IOSS) or count as goods in postal consignment (Article 2 of Regulation (EU) 2026/382). Since 1 July 2026 that term covers every other distance sale up to €150 too, except goods under trade preferences (Article 1 of Delegated Regulation (EU) 2026/1022; Commission guidance, section 3.2). Imports that are not distance sales pay normal duty rates, as the €150 relief is gone (Article 1 of Regulation (EU) 2026/382).
An item is all goods with the same tariff classification, description and, where declared, origin: five T-shirts are one item and pay €3, a T-shirt and a watch pay €6 (Commission Q&A (opens in a new tab)). The declarant pays, usually the seller or marketplace registered for IOSS or an indirect customs representative such as the carrier (recital 10 of Delegated Regulation (EU) 2026/1022).
On top comes a non-refundable Union handling fee per item for every distance sale, whatever its value (Article 20(2) and (6) of Regulation (EU) 2026/2108). The Commission sets the amount in a delegated act; the fee applies from the tenth day after that act enters into force (Article 287(4)). The Commission expected a start in November 2026 (IP/26/1904 (opens in a new tab)).
Three product identifiers per item from 1 November 2026
From 1 November 2026, customs declarations for distance sales must state for each item (Article 2(3) and Annex of Delegated Regulation (EU) 2026/1022):
- the merchant product identifier assigned by the online seller or marketplace, such as your shop SKU;
- the non-standardised manufacturer product identifier, such as your model number;
- the standardised manufacturer product identifier where one exists, such as an EAN.
The Commission's guidance (opens in a new tab) expects manufacturers to assign identifiers at model level and pass them along the supply chain (section 3.5). The product must already be identifiable on the product itself (Article 9(5) GPSR) and in your online offer (Article 19(c) GPSR); in the 2026 sweep, only 58% of listings managed this together with manufacturer and Responsible Person (our report).
Importer for distance sales is not your importer under product law
From 21 September 2027, the importer for distance sales provides the customs data, ensures payment of duties and ensures that the goods comply with the other legislation customs enforce, keeping records (Article 27(2)). The Commission's 2023 proposal called this role the deemed importer; the adopted text does not.
Product law defines the importer as a person established in the EU who places a product from a third country on the EU market (Article 3(10) GPSR, Article 3(9) of Regulation (EU) 2019/1020). The importer for distance sales needs no EU establishment if an indirect customs representative acts for it (Article 27(3)(e) of Regulation (EU) 2026/2108).
The Code itself separates the roles: release data must name the importer and, separately, the responsible economic operator under Article 4 of Regulation (EU) 2019/1020 and Article 16 GPSR (Article 109(3)(a)). Handling customs does not make a seller or marketplace your EU economic operator; for the choice of role, see Authorized Representative or importer.
Why missing GPSR details become a customs risk
Customs already check product rules. They must suspend release if required documents are missing, if the product is not labelled as Union law requires or, for CE products covered by Article 4, if the EU economic operator's name and postal address are missing (Article 26(1)(a), (b) and (d) of Regulation (EU) 2019/1020 (opens in a new tab)). This covers GPSR products too (recital 62 GPSR).
The new Code adds two steps:
- From 21 September 2027, compliance with the other legislation customs enforce is a condition for release (Article 109(3)(e) of Regulation (EU) 2026/2108). Customs refuse release on evidence of non-compliance, and notified non-compliance feeds into the importer's risk profile (Articles 77(4) and 55(4)).
- From 1 July 2028, market surveillance authorities may use Data Hub data to enforce product legislation (Article 41(9)).
Practical example: a U.S. electronics brand shipping from its own warehouse
A U.S. brand sells Bluetooth speakers and carrying cases from its own shop to EU consumers. It ships by courier from its U.S. warehouse, uses IOSS and has no company in the EU. A German customer orders two speakers of one model and one case, together under €150.
- Duty: two items, so €6 under the flat duty for IOSS goods (Article 2(a) of Regulation (EU) 2026/382), plus the handling fee per item once it applies.
- Product law: there is no EU importer. The speaker is radio equipment (Directive 2014/53/EU, listed in Article 4(5) of Regulation (EU) 2019/1020) and needs an EU economic operator, here an Authorized Representative with a written mandate (Article 4(2)(c)). The case, a GPSR-only product, needs the same under Article 16(1) GPSR. One representative can cover both.
| Detail | Product, packaging or parcel | Online shop | Customs data |
|---|---|---|---|
| EU economic operator | Name and postal address; for the case also electronic address (Art. 4(4) Reg. 2019/1020, Art. 16(3) GPSR) | Name, postal and electronic address (Art. 19(b) GPSR) | Identity for release from 21 September 2027 (Art. 109(3)(a) Reg. 2026/2108) |
| Model number | Type, batch or serial number (Art. 10(6) Dir. 2014/53/EU, Art. 9(5) GPSR) | Type and product identifier (Art. 19(c) GPSR) | Non-standardised manufacturer identifier |
What to check now
- Know your customs role. Ask your marketplace or carrier who declares your parcels and who is the importer for distance sales from 21 September 2027.
- Fix your identifiers. Give every product a model number, note its EAN and pass both to your shop, marketplaces and carriers.
- Align label, listing and customs data on the same model and identifiers.
- Name your EU economic operator before shipping and put its details on the product, packaging, parcel or an accompanying document.
- Keep compliance records ready: technical file, test reports and, for CE products, the Declaration of Conformity.
- Recalculate landed cost: €3 per item plus the handling fee until 1 July 2028, normal duty rates for goods outside the flat duty and for everything after that date.
Common mistakes with the customs reform
- Counting per parcel. The €3 duty and the handling fee are charged per item.
- Treating the customs importer as your EU operator. A marketplace acting as importer for distance sales is not, by that alone, your economic operator under Article 16 GPSR or Article 4 of Regulation (EU) 2019/1020.
- Mixing up representatives. A representative who pays duty is a customs representative (Article 33 of Regulation (EU) 2026/2108), not your EU Authorized Representative.
- Reading release as approval. Release by customs is no proof of conformity (Article 27 of Regulation (EU) 2019/1020, Article 77(2) of Regulation (EU) 2026/2108).
Conclusion: customs now reads your compliance data
The €3 duty and the handling fee change your costs. The lasting change is data: identifiers from November 2026, your EU economic operator in the release data from 2027, market surveillance access from 2028.
Customs clearance stays with your marketplace, carrier or customs representative; Representa GmbH does not handle it. We cover the product side: as your GPSR Responsible Person or EU Authorized Representative, our name and address go on your packaging, and our compliance consulting checks labels, packaging and technical files before your goods ship.
Frequently asked questions
Who pays the €3 EU customs duty on small parcels?
The declarant: usually the seller or marketplace registered for IOSS, or an indirect customs representative such as the carrier (Delegated Regulation (EU) 2026/1022, recital 10). Until 1 July 2028 the duty is €3 per item for distance sales up to €150, except goods under trade preferences declared outside IOSS (Article 2 of Regulation (EU) 2026/382).
When does the EU handling fee for parcels apply, and how much is it?
The Commission sets the amount per item in a delegated act (Article 20(10) of Regulation (EU) 2026/2108). The fee applies from the tenth day after that act enters into force (Article 287(4)) and covers every distance sale released for free circulation, whatever its value.
What is an importer for distance sales?
The person supplying goods from a third country in a distance sale, or the person facilitating it, such as a marketplace (Article 5(14) of Regulation (EU) 2026/2108). From 21 September 2027 it is the importer towards customs and must ensure that the goods comply with the product rules customs enforce (Article 27(2)).
Do I still need an EU Responsible Person if my marketplace handles customs?
Yes. Customs formalities do not replace the EU economic operator required by Article 16(1) GPSR and Article 4 of Regulation (EU) 2019/1020. The new Customs Code even lists that operator separately in the data needed for release (Article 109(3)(a) of Regulation (EU) 2026/2108).
Are product identifiers mandatory for low-value parcels?
Yes, for distance sales from 1 November 2026. Customs declarations must include for each item the merchant product identifier, the manufacturer's own identifier and, where one exists, a standardised one such as an EAN (Article 2(3) of Delegated Regulation (EU) 2026/1022).