The European Union is introducing a new customs duty on low-value B2C ecommerce imports from non-EU countries, effective July 1, 2026. The duty ends the longstanding €150 duty exemption and replaces it with a temporary flat fee applied per declaration line. This article covers what U.S. retailers need to know before the deadline.
This article applies specifically to B2C shipments imported into the EU from non-EU countries. It does not apply to intra-EU shipments.
I wrote about the broader regulatory shift for Global Trade Magazine. The article focuses on what ecommerce retailers need to do now.
~ Alison Layfield
TL;DR: Before diving into operational details, retailers should understand that the new customs environment involves multiple distinct charges, not a single one. The four layers are:
- EU-wide €3 customs duty per declaration line, effective July 1, 2026, applying to B2C parcels from non-EU countries valued under €150
- National handling fees introduced separately by individual member states, including France, Romania, and Italy, which are already partially active and stack on top of the EU-wide duty
- VAT, which continues to be collected through IOSS for eligible consignments. Whether VAT applies to the €3 duty itself is still awaiting final EU clarification, though evidence from Irish Revenue and Belgian Finance suggests it likely does
- A possible EU-wide handling fee expected in Q4 2026, also anticipated to be applied per declaration line by the same mechanism as the €3 duty. The amount has not yet been determined
Landed-cost models and checkout systems need to be built to handle this stack, not just the EU-wide €3 duty in isolation.
From July 1, 2026, the EU will apply a temporary €3 customs duty per declaration line on B2C parcels imported from non-EU countries and valued under €150. This replaces the existing duty exemption for parcels below that threshold.
The duty is confirmed at €3 per declaration line. An item is defined as one or more goods sharing the same tariff classification and description within a consignment. How that plays out in practice 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 declaration line and trigger one €3 charge. A parcel containing three women's blouses all classified under the same HS code would trigger €3 total under H7.
For H1 declarations, which use a full data set including ten-digit TARIC codes, goods classified under different TARIC subheadings become separate declaration lines, each triggering €3. The same three blouses, if they split across different TARIC subheadings in an H1 declaration, could trigger €9.
The declaration type used by your carrier or customs broker will directly affect your landed cost calculation. Retailers should confirm which declaration type applies to their shipment flows and model costs accordingly.
Some shipments may find it more cost-effective to file an H1 declaration and pay ad valorem duty rates rather than the flat €3 per line, particularly where a consignment contains many very low-value goods across multiple lines. This is an emerging discussion in the industry and worth reviewing with your customs broker.
The €3 duty is explicitly a temporary measure. It is expected to remain in place until the EU Customs Data Hub becomes operational, currently anticipated around 2028, at which point standard EU tariff rates are expected to apply.
Who is responsible for the duty
The responsibility for paying the €3 duty lies first and foremost with the declarant. The EU guidance establishes a specific 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 limited number of member states that provide 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 on this point: the €3 duty is the obligation of the IOSS holder. It is a business expense. How or whether to recover it from the consumer is a business decision, not a customs requirement. This is different from VAT, which is a tax on consumption.
For IOSS-registered retailers, the practical flow is: your service provider collects the duty when goods enter the EU and bills it back to you. You decide whether to collect it from your customer at checkout. DDP is the approach that makes that collection transparent and predictable.
DDP vs DDU: what retailers need to know
DDP is the clearest path forward. Under DDP, the duty is collected at checkout, the process is transparent, and there is no ambiguity 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 is technically available but carries significant operational uncertainty. EU member state postal operators are each making their own decisions about how to handle the new duty requirement, and those decisions vary widely. Some are offering DDU only. Some are offering DDP only. Germany has indicated it will not offer DDU. Poland has indicated it will only offer DDU. 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 (Delivery at Place). The same uncertainty around foreign postal operator handling applies.
The practical risk with DDU is that once your shipment leaves the U.S. and enters the EU, what happens next depends on decisions made by the destination country's postal operator. If the duty is not collected and the customs debt is not covered, goods may be held until payment is made. That creates a customer experience problem that is difficult to manage from the U.S. side.
ePost has a DDU solution through our carrier partner network. The concern is not whether we can offer it on our end but what happens once the parcel reaches the destination country. Until member-state implementation stabilizes, DDP is the solution with the least risk and the most transparency for your customers.
National handling fees: a separate and already-active layer
In addition to the EU-wide €3 customs duty, several member states have introduced or announced their own national handling fees. These are legally distinct from the EU customs duty and stack on top of it. Some are already in effect.
- Romania introduced a national logistics fee of approximately €5 per parcel effective January 1, 2026, assessed based on the consumer's delivery location
- France introduced a fee of approximately €2 per unique item category effective March 1, 2026, assessed based on where customs clearance occurs rather than where the consumer is located
- Italy announced a national handling fee of approximately €2 per parcel, originally scheduled for January 1, 2026 and postponed to July 1, 2026
The distinction between clearance-based fees and destination-based fees matters for routing decisions. A parcel cleared through French customs but delivered to a Belgian consumer triggers the French fee. Romania's fee follows the consumer's location regardless of where the parcel enters the EU. Retailers using multi-entry routing need to account for this by destination market, not just by carrier or entry point.
France and Romania are not future exposure. They are current exposure. Retailers already shipping to those markets should be modeling those costs today.
The possible EU-wide handling fee in Q4 2026
A separate EU-wide handling fee is expected to take effect in Q4 2026, understood to be November. Per the European Commission's DG TAXUD, it will be applied per declaration line using the same mechanism as the €3 customs duty. The amount has not yet been determined.
July 1 is not the finish line. Retailers building checkout and compliance systems now should design them to accommodate this second fee without requiring full rebuilds. The Q4 deadline is real, and the mechanism is confirmed, even if the amount is not.
Why retailers cannot wait for clarity
National fees are already active. Romania's fee has been in effect since January 1. France's fee has been in effect since March 1. These create immediate cost exposure before the EU-wide July 1 date.
The EU-wide fee and the per-declaration-line mechanism are confirmed. What remains unsettled is the member-state operationalization of DDU, the VAT treatment of the €3 duty, and the amount of the Q4 handling fee. None of those open questions change the July 1 deadline or the need to have systems ready.
Retailers who wait for full clarity before beginning checkout and systems work will not have enough time to implement and test properly.
Cost modeling scenarios
Retailers should model landed costs using the confirmed per-declaration-line structure, not a flat per-parcel assumption. A per-parcel calculation is not how the duty works.
The key variables are declaration type and product mix. Under H7, goods sharing the same HS code are one line and one €3. Under H1, goods split by TARIC subheading become separate lines. A shipment with products across three different TARIC subheadings filed under H1 triggers €9, not €3. For a retailer shipping 10,000 such parcels per month, the difference between one and three declaration lines per shipment is €60,000 in monthly duty exposure.
For shipments into France or Romania, national fees stack on top of EU duty. A shipment cleared through France with two item categories triggers €3 EU duty plus €4 in French fees before VAT. That is not a rounding error in a high-volume operation.
Product mix directly affects exposure. Single-SKU orders in one tariff classification are the most predictable. Multi-item shipments spanning different classifications require line-by-line cost modeling, not a blended average.
If VAT applies to the €3 duty, as Irish Revenue and Belgian Finance suggest, add that to each scenario. Final clarification is pending but planning for it now is the lower-risk approach.
New data requirements: product identifiers
Starting November 1, 2026, three new product identifier fields will be required on customs declarations for all distance sale imports into the EU. They are optional from July 1, 2026, with no penalties during the voluntary period.
The three fields are:
- Merchant product identifier: the ID assigned by the online seller, marketplace, or platform. For Amazon shipments, this is the ASIN. For other platforms, it is the equivalent product-level identifier used on that platform
- Non-standardized manufacturer product identifier: the ID assigned by the manufacturer or product supplier for operational or supply chain purposes
- Standardized manufacturer product identifier: required only where it exists. Common examples include EAN barcodes and ISBN numbers for books
These requirements are designed to give EU customs authorities the ability to track goods at the product level and scale enforcement of product safety and compliance rules.
For ePost customers, we are working toward compliance for the November 1 mandatory date. If you begin passing these identifiers before that date, we will pass them through. If you are not ready until November 1, that aligns with when enforcement begins. The key question for retailers to answer now is whether their product data systems can generate and pass these identifiers at the shipment level. Platforms like Amazon already have this infrastructure. Sellers operating outside major marketplace platforms may need to build it.
Returns: the duty is not refundable
Under the official EU guidance, the €3 customs duty paid on a parcel cannot be reclaimed if the goods are returned after release. The ability to invalidate a customs declaration for returned low-value distance sale goods has been removed. Standard customs refund rules under Article 116 UCC continue to apply in limited circumstances, but for practical purposes retailers should treat the duty as non-refundable.
This affects returns policy, customer messaging, and margin calculations on any product category with high return rates.
IOSS: what has and has not changed
The existing VAT schemes for imported goods, including IOSS, Special Arrangements, and the standard VAT procedure, have not changed as a result of the €3 customs duty. IOSS continues to operate as it did. There is no replacement coming on July 1 and IOSS is not being phased out.
What has changed is that IOSS-registered sellers are now also the primary debtors for the €3 customs duty. The two obligations, VAT via IOSS and customs duty, are separate. IOSS cannot be used to remit the customs duty. Your service provider will collect and remit the duty on your behalf and bill it back.
The one open question is whether the €3 duty itself is subject to VAT. Irish Revenue and Belgian Finance both indicate it is. The EU guidance deferred this question and DG TAXUD did not answer it on the UPU webinar. If VAT does apply to the duty, that adds to the landed cost calculation. Plan for it and watch for the EU's formal clarification.
Checklist: what retailers must do before July 1
- Confirm your declaration type with your carrier or customs broker and model landed costs under H7 and H1 scenarios. Do not model based on a flat per-parcel assumption.
- Layer in national fees for France, Romania, and Italy. Account for the distinction between clearance-based and destination-based fees by destination market.
- Decide on DDP or DDU and align with your carrier. DDP is the clearer path. If you are considering DDU, confirm what your carrier's partner in the destination country will actually do with the duty before committing.
- Audit your checkout system. Confirm it can display the duty as a separate line item, update fee logic without a full rebuild, and accommodate a second fee when the Q4 handling fee amount is announced.
- Review your returns policy and customer messaging in light of the non-refundable duty. Update FAQ content and support scripts before July 1.
- Audit your product data for the November 1 PID requirement. Identify your merchant product identifiers, manufacturer identifiers, and standardized identifiers now, not in October.
- Designate an internal owner for ongoing compliance. Implementation details will continue evolving through Q4 2026 and into 2027.
Frequently asked questions
July 1, 2026. National fees in France and Romania are already active. Italy's national fee is also scheduled for July 1.
How is the €3 EU customs duty calculated?
Per declaration line. An item is defined as goods sharing the same tariff classification within a consignment. How many lines a shipment generates depends on the declaration type (H7 or H1) and how products are classified. Confirm with your carrier or customs broker how your shipments will be declared.
Who is responsible for paying the customs duty?
The IOSS holder is the primary debtor. Your service provider will collect the duty when goods enter the EU and bill it back to you. Whether and how you recover it from your customer is a business decision, not a customs requirement
Is DDU still an option?
It depends on the destination country. Some EU member state postal operators are offering DDU, some are offering DDP only, and some have not yet confirmed their approach. Poland is offering DDU only. Germany has indicated no DDU. USPS is working toward DDP for all countries that can accept it, but DDP is not currently available to enterprise permit shippers. Confirm the situation country by country with your carrier before committing to a DDU approach.
Will IOSS still work after July 1, 2026?
Yes. IOSS has not changed. It continues to handle VAT collection for eligible consignments under €150. The €3 customs duty is a separate obligation from VAT and cannot be remitted through IOSS.
Are there fees beyond the EU-wide €3 duty?
Yes. France, Romania, and Italy have introduced or announced separate national handling fees that stack on top of the EU-wide duty. A Q4 2026 EU-wide handling fee is also expected, applied per declaration line. The amount has not yet been determined.
What happens if a customer returns a parcel?
The €3 customs duty paid on the parcel cannot be reclaimed. Plan your returns policy and margin calculations accordingly.
What are the new product identifier requirements?
Starting November 1, 2026, three product identifiers must be included on customs declarations for all distance sale imports: the merchant product identifier (such as an Amazon ASIN), the non-standardized manufacturer product identifier, and the standardized manufacturer product identifier where one exists. These fields are optional from July 1 with no penalties during the voluntary period.