November 1 brings the next round of EU customs changes. Here's what you need to know now.
The EU customs fee ecommerce landscape changes again on November 1, 2026. A new €2 Union Handling Fee applies to every ecommerce shipment, product identifiers become mandatory for low-value B2C shipments, and Germany stops accepting DDU. These changes stack on top of the €3 customs duty that took effect July 1. This article covers what U.S. retailers need to do to keep EU shipments moving.
This article applies to B2C shipments imported into the EU from non-EU countries. It does not apply to intra-EU shipments. The rules are still settling, so we will update this page as details are confirmed.
I wrote about the broader regulatory shift for Global Trade Magazine. The article focuses on what ecommerce retailers need to do now.
~ Alison Layfield
What changes November 1, 2026
- Union Handling Fee: €2 per item plus destination-country VAT, applied to all ecommerce shipments regardless of value
- Germany ends DDU: Germany no longer accepts DDU (DAP) shipments. ePost turned off DDU routing to Germany on October 26
- Product identifiers: PIDs become mandatory for B2C shipments valued up to €150
These join the charges already in place:
- €3 customs duty per item on B2C parcels valued at €150 or less, in effect since July 1, 2026
- Import VAT, collected through IOSS for eligible shipments under €150 and at import for shipments over €150
- National handling fees set by individual member states, which vary by country
Landed-cost models and checkout systems need to handle the full stack, not each charge in isolation.
Also in effect: EU Packaging and Packaging Waste Regulation (PPWR)
Since August 12, 2026, all packaging placed on the EU market, including ecommerce and shipping materials, requires formal documentation such as a Declaration of Conformity. If you place packaging or packaged goods on the EU market, this responsibility may fall to you. It remains unclear who will enforce the requirement and how.
The Union Handling Fee: €2 per item from November 1
The EU-wide handling fee is now official. The Union Handling Fee (UHF) is established by Article 20 of Regulation (EU) 2026/2108, the new Union Customs Code. The European Commission set the amount at €2 per item in a delegated regulation adopted September 21, 2026, and it applies from November 1, 2026. VAT is charged on top. The delegated regulation is subject to an objection period for the European Parliament and Council, so details could still change.
What retailers need to know:
- It applies to every ecommerce shipment, regardless of value. Unlike the €3 duty, the UHF is not limited to parcels under €150
- It stacks on top of the €3 duty. A parcel under €150 now carries both charges per item
- An item is defined by tariff code and shipment value. Under €150 and IOSS shipments are counted at the HS6 level. Shipments over €150 are counted at the HS10 level
- VAT applies to the fee itself, at the destination country's rate
- It is non-refundable. EU customs will not refund the UHF on returned goods
- Both DDU and DDP shipments are subject to it
How VAT on the fee is paid depends on how the shipment is cleared:
| Shipment | Duty | Union Handling Fee | VAT on the handling fee |
|---|---|---|---|
| Over €150 | Standard rate (%) by commodity and country of origin | €2 per HS10 item + destination-country VAT | Paid at the time of import |
| Under €150, ePost broker IOSS | €3 per HS6 item | €2 per HS6 item | ePost pays it in directly |
| Under €150, your own IOSS | €3 per HS6 item | €2 per HS6 item | You pay it directly through your IOSS |
How the €3 customs duty works
Since July 1, 2026, the EU applies a temporary €3 customs duty per item on B2C parcels imported from non-EU countries and valued at €150 or less. It replaced the duty exemption that applied to those parcels until June 30, 2026.
An item is one or more goods sharing the same tariff classification within a consignment. How that plays out depends on the declaration type used.
For H7 declarations, which use a minimal data set and are the most common for ecommerce, goods sharing the same six-digit HS code are grouped as one item and trigger one €3 charge.
For H1 declarations, which use a full data set including ten-digit TARIC codes, goods classified under different TARIC subheadings become separate items, each triggering €3.
Some shipments may find it more cost-effective to file an H1 declaration and pay standard duty rates rather than the flat €3 per item, particularly where a consignment contains many very low-value goods across multiple lines. This is worth reviewing with your customs broker.
Both DDU and DDP shipments are subject to the €3 duty. There is no exemption based on incoterm.
The €3 duty is a temporary measure, expected to remain in place until the EU Customs Data Hub becomes operational, currently anticipated around 2028. Standard EU tariff rates are expected to apply after that.
Who is responsible for the duty
The responsibility for paying the €3 duty lies first with the declarant. EU guidance sets a cascade for determining who the declarant is:
- The IOSS holder, or its indirect representative
- The person making special arrangements, or its indirect representative
- The indirect representative of the importer
- Any other person able to provide information and present the goods to customs
The consumer is only a residual option in the few member states that offer a free online declaration system for individuals. In practice, the IOSS holder is the primary debtor.
The European Commission's DG TAXUD has been explicit: the €3 duty is the obligation of the IOSS holder. It is a business expense. Whether to recover it from the consumer is a business decision, not a customs requirement. This differs from VAT, which is a tax on consumption.
For IOSS-registered retailers, the flow is simple. Your service provider collects the duty and the handling fee when goods enter the EU and bills them back to you. You decide whether to collect them from your customer at checkout. DDP makes that collection transparent and predictable.
DDP vs DDU: Germany goes DDP only
Germany stops accepting DDU (DAP) shipments on November 1, 2026. ePost is turning off DDU routing to Germany as of Monday, October 26. Germany-bound parcels sent with a DDU product code will fail routing at the time of processing. If you ship to Germany under DDU, switch those shipments to DDP now. Other EU member states could follow Germany's lead.
DDP is the clearest path forward. Under DDP, duties and fees are collected at checkout, the process is transparent, and there is no question about who pays or when. For IOSS-registered sellers, this is the approach the EU framework is built around and the one ePost recommends.
DDU remains available in some markets but carries real operational risk. Each EU member state's postal operator decides how to handle the new charges, and those decisions vary. Some offer DDU only, some DDP only. Poland has indicated it will offer DDU only. USPS is working toward DDP for all EU countries that can accept it, but DDP is not currently available to enterprise shippers using permits. It is only available through USPS's GSS platform or API-connected accounts.
For non-IOSS sellers, the applicable term is DAP (Delivered at Place). The same uncertainty around foreign postal operator handling applies.
The risk with DDU is that once your shipment enters the EU, what happens next depends on the destination country's postal operator. If the duty and fees are not collected, goods may be held until payment is made. That creates a customer experience problem that is hard to manage from the U.S.
ePost offers DDU through our carrier partner network where destination countries still accept it. Until member-state implementation stabilizes, DDP is the option with the least risk and the most transparency for your customers.
National handling fees: a separate layer
Some member states set their own national handling fees. These are legally distinct from the €3 duty and the Union Handling Fee.
Romania has applied a flat logistics tax of €5 (RON 25) per parcel since January 1, 2026. It applies to shipments valued under €150 that originate outside the EU and are destined for Romania, wherever in the EU they are released for free circulation. Parcels not delivered to the recipient in Romania are exempt. Postal service providers collect and remit the tax. It is not refundable on returned parcels.
Italy announced a €2 national handling fee, postponed several times. It is now expected to take effect November 1, 2026, alongside the Union Handling Fee. It would apply per parcel to shipments valued under €150 from non-EU countries destined for Italy.
France introduced a €2 small parcel tax on March 1, 2026, then suspended it ahead of the July 1 EU-wide duty. France is not currently applying a national handling fee.
How it's calculated: three examples
Model landed costs per item, not per parcel. The examples below show a two-item shipment to Germany under each scenario. Each item falls under a different tariff code, so each triggers its own charges.
Example 1: shipment over €150, not using IOSS
One wool sweater (€180) and one silk blouse (€80), plus €15 shipping, for a total value of €275. The shipment is destined for Germany and cleared through the Netherlands. VAT on the package is charged at the country of import rate. VAT on the handling fee is charged at the destination country rate.
| Charge | How it's calculated | Amount |
|---|---|---|
| Duty | 12% of item value and shipping (€275) | €33.00 |
| Netherlands VAT (country of import) | 21% of item value, shipping and duty (€308) | €64.68 |
| Handling fee + Germany VAT (destination) | 2 HS10 items × €2 = €4, plus 19% VAT (€0.76) | €4.76 |
| Total import charges | Duty + VAT + handling fee | €102.44 |
Example 2: shipment under €150, your own IOSS
One pair of cotton shorts (€60) and one cotton t-shirt (€40), plus €10 shipping, for a total value of €110, destined for Germany.
| Charge | How it's calculated | Amount |
|---|---|---|
| Duty | 2 HS6 items × €3 | €6.00 |
| Handling fee | 2 HS6 items × €2 | €4.00 |
| VAT on the package and the handling fee | Remitted by you through your IOSS at the German rate | Paid through IOSS |
| Total billed at import | Duty + handling fee | €10.00 plus VAT remitted through your IOSS |
Example 3: shipment under €150, ePost broker IOSS
The same €110 shipment to Germany, cleared using ePost's IOSS broker number.
| Charge | How it's calculated | Amount |
|---|---|---|
| Duty | 2 HS6 items × €3 | €6.00 |
| Germany VAT (destination) | 19% of item value and shipping (€110) | €20.90 |
| Handling fee + Germany VAT | 2 HS6 items × €2 = €4, plus 19% VAT (€0.76) | €4.76 |
| Total import charges | Duty + VAT + handling fee | €31.66 |
Product mix drives exposure. Single-item orders in one tariff classification are the most predictable. Multi-item shipments across classifications need item-by-item modeling. For shipments to countries with a national fee, add that fee on top.
Product identifiers become mandatory November 1
Starting November 1, 2026, product identifiers (PIDs) are mandatory for B2C shipments into the EU valued up to €150. Shipments missing required identifiers may be delayed or rejected by EU customs. ePost asked customers to start including PIDs in all shipment manifests on October 15 to be ready in time. You can include PIDs on all shipments, including those over €150, and we will accept them.
There are three identifiers:
| Code | Identifier | What it is | Who provides it |
|---|---|---|---|
| C127 | Merchant product identifier (M-PID) | Your seller product ID or SKU. For Amazon shipments, this is the ASIN | You |
| C128 | Non-standardized manufacturer product identifier (NS-PID) | The manufacturer's part or model number when no standardized ID exists | You. Sellers of used or homemade goods, such as on Etsy or eBay, are expected to assign one |
| C129 | Standardized manufacturer product identifier (S-PID) | A globally recognized ID such as a GTIN, EAN or UPC, required only where one exists | Optional. ePost's customs broker manages this field (default Y081) |
ePost will provide default values where applicable.
How to find PIDs on a product. Take a pair of sunglasses as an example. The seller SKU on the box (BF-S7-TB) is the M-PID. The barcode number (8721234567801) is the S-PID. The manufacturer's model code (BRIGHTFEN-EYE-S7-TB) is the NS-PID.
The key question now is whether your product data systems can generate and pass these identifiers at the shipment level.
Returns: duty and handling fee are not refundable
The €3 customs duty cannot be reclaimed if goods are returned after release. The Union Handling Fee is also non-refundable by EU customs, and so is Romania's national logistics fee. Standard refund rules under Article 116 UCC still apply in limited circumstances, but for practical purposes, treat these charges as non-refundable.
This affects returns policy, customer messaging and margins on any product category with high return rates.
IOSS: what has and has not changed
The EU's VAT schemes for imported goods, including IOSS, Special Arrangements and the standard VAT procedure, have not changed. IOSS continues to operate as it did. It is not being replaced or phased out.
What has changed is that IOSS-registered sellers are now the primary debtors for the €3 customs duty, and the Union Handling Fee adds another charge to the same shipments. VAT through IOSS and customs duty are separate obligations. IOSS cannot be used to remit the customs duty. Your service provider collects and remits the duty on your behalf and bills it back.
If you use ePost's IOSS broker number, ePost pays in the VAT on the handling fee directly. If you have your own IOSS registration, you pay that VAT directly.
One question remains open: whether the €3 duty itself is subject to VAT. Irish Revenue and Belgian Finance both indicate it is, but the EU has not formally clarified. If VAT does apply to the duty, it adds to landed cost. Plan for it and watch for formal guidance.
Checklist: what retailers need to do before November 1
- Switch Germany shipments to DDP. DDU parcels to Germany will fail routing at processing.
- Pass PIDs on every EU shipment manifest now. Confirm your systems can generate M-PIDs and NS-PIDs at the shipment level.
- Add the Union Handling Fee to your cost models at €2 per item plus destination-country VAT, on orders of every value, including those over €150.
- Confirm whether you clear under ePost's IOSS broker number or your own. That decides who pays VAT on the handling fee.
- Confirm your declaration type with your carrier or customs broker, and model landed costs per item under H7 and H1 scenarios.
- Audit your checkout. Confirm it can show the duty and handling fee as separate line items and update fee logic without a full rebuild.
- Review DDU everywhere else. Confirm what your carrier's partner in each destination country does with duties and fees, and expect more countries to follow Germany.
- Update national fee models for Romania and Italy.
- Update your returns policy and customer messaging. The duty and the handling fee are both non-refundable.
- Name an internal owner for EU compliance. Rules are still settling, and someone needs to turn each update into system changes quickly.
Frequently asked questions
What is the EU Union Handling Fee? A €2 fee per item plus destination-country VAT. It is established by Regulation (EU) 2026/2108, and the European Commission set the €2 amount in a delegated regulation adopted September 21, 2026. It applies to all ecommerce shipments into the EU from November 1, 2026, regardless of value, and stacks on top of the €3 customs duty. It is non-refundable.
Does the handling fee apply to orders over €150? Yes. Unlike the €3 duty, the Union Handling Fee applies at any value. Shipments over €150 are counted at the HS10 level. Shipments under €150 and IOSS shipments are counted at the HS6 level.
Can I still ship DDU to Germany? No. Germany stops accepting DDU (DAP) shipments on November 1, 2026. ePost turned off DDU routing to Germany on October 26, and Germany-bound parcels with a DDU product code will fail routing. Ship to Germany under DDP.
How is the €3 EU customs duty calculated? Per item, on B2C parcels valued at €150 or less. Goods sharing the same six-digit HS code count as one item. Goods under different codes count as separate items, each triggering €3. Confirm with your carrier or customs broker how your shipments are declared.
Who is responsible for paying the customs duty? The IOSS holder is the primary debtor. Your service provider collects the duty when goods enter the EU and bills it back to you. Whether you recover it from your customer is a business decision, not a customs requirement.
Is DDU still an option in other EU countries? In some. Each member state's postal operator decides its own approach, and others could follow Germany. Both DDU and DDP shipments are subject to the duty and the handling fee. DDP is the clearer path. Confirm country by country with your carrier.
Will IOSS still work? Yes. IOSS still handles VAT collection for eligible shipments under €150. The €3 duty is a separate obligation and cannot be remitted through IOSS.
Are there other fees beyond the duty and the handling fee? Yes. Romania's €5 logistics fee applies per parcel to shipments under €150 destined for Romania. Italy's €2 national fee is expected November 1, 2026. France's national fee is suspended.
What happens if a customer returns a parcel? The €3 duty and the Union Handling Fee cannot be reclaimed after goods are released. Romania's logistics fee is also non-refundable on returns. Plan your returns policy and margins accordingly.
What are the new product identifier requirements? From November 1, 2026, B2C shipments valued up to €150 must include product identifiers: the merchant product ID or SKU (such as an Amazon ASIN), the manufacturer's part or model number when no standard ID exists, and a GTIN, EAN or UPC where one exists. ePost's customs broker manages the standardized identifier field. Shipments missing required identifiers may be delayed or rejected by EU customs.
