The plumbing for it was published three weeks ago. Commission Implementing Regulation (EU) 2026/1869, of 27 July 2026, rewrites the detailed rules for the special schemes — how a business identifies itself, registers, and files — with most of it applying from 1 July 2028 and one interim piece from 1 January 2027.
Three things in Directive (EU) 2025/516 land together.
The Union OSS extends to domestic B2C supplies. Today OSS covers distance sales across a border. From 2028 it also covers domestic supplies of goods to consumers made by a taxable person who is not established in the member state of consumption. The classic trigger for a foreign VAT registration — holding stock in a warehouse in another member state and selling locally from it — stops requiring one.
A new special scheme covers transfers of your own goods. Moving your own stock from a warehouse in one member state to a warehouse in another is a deemed supply and an acquisition, and it is the reason so many small sellers hold registrations they otherwise would not need. The new scheme lets a business report those movements on a single return and be identified for VAT in the member state of identification only. It is optional.
The reverse charge becomes mandatory in a defined case. Under the amended Article 194, where a supply is made by a person not established in the member state where the VAT is due, and the customer is already identified for VAT there, the customer accounts for the tax. That removes another common reason to register.
The call-off stock simplification in Article 17a goes, in two steps that are easy to misread:
Anything still sitting in call-off stock after June 2029 falls back to ordinary rules, and the new transfers-of-own-goods scheme is what it is expected to fall back into.
It does not create a single EU VAT number. It reduces the reasons a registration is triggered; it does not merge the registrations you hold for other reasons, and B2B supplies outside the reverse charge case are untouched.
It does not make IOSS mandatory. That proposal did not survive into the adopted text, and the import channel is being tightened from the customs side instead — through the deemed-importer rule and the handling fee rather than through the VAT directive.
And it does not help with extended producer responsibility. EPR registration and the authorised representative mandate are environmental obligations with their own national registers, untouched by anything in ViDA. A seller can end up in 2028 with one VAT registration and twenty-seven EPR ones, which is a fair summary of how unevenly “single market” has been applied across the two regimes.
| Date | What |
|---|---|
| 1 Jan 2027 | OSS and IOSS clarifications; e-charging supplies into OSS |
| 1 Jul 2028 | Single VAT registration; transfers of own goods; mandatory reverse charge |
| 30 Jun 2028 | No new call-off stock arrangements |
| 30 Jun 2029 | Article 17a ceases to apply |
| 1 Jul 2030 | Digital reporting and e-invoicing for cross-border B2B |
| 1 Jan 2035 | National real-time reporting systems align with the EU scheme |
Two years is not long for a change that alters where a business is registered. The useful work in 2026 and 2027 is knowing which of your current registrations exist only because of stock movements or local sales from foreign warehouses — those are the ones 2028 is designed to remove.
]]>The agreed text introduces a handling fee, collected by customs authorities, on small consignments sold by distance selling. Two things about it matter for anyone shipping into the EU.
The date is a backstop, not a target. Member states apply the fee no later than 1 November 2026. It can arrive sooner.
The amount is not set. The level goes into a Commission delegated act, tied to the cost customs authorities incur in releasing a consignment — the IT and staff time behind data checks, risk analysis and documentary or physical controls. Trade reporting has settled on about €2 per parcel, and that number is worth planning around, but it is not law until the delegated act is adopted. Anyone quoting €2 as a fixed charge today, this site included in July, is quoting an expectation.
It is a separate charge from the €3 flat duty, which has its own legal basis in Council Regulation (EU) 2026/382 and runs to 1 July 2028. A low-value parcel from November therefore carries import VAT, the €3 per item, and a handling fee per consignment.
The agreement confirms the deemed-importer construction: platforms and distance sellers selling into the EU are treated as the importer of the goods and carry the customs formalities and payments, rather than the consumer receiving the parcel. They inform customs through the Data Hub about sales as they happen. This is the liability shift the €150 exemption piece described as the durable part of the 2026 changes, now fixed in the agreed text rather than proposed.
The 2023 proposal put the Data Hub at 2028 for e-commerce, 2032 for other traders on a voluntary basis, and 1 January 2038 for mandatory use. Those were the dates in our Data Hub explainer and on the timeline until today. The agreed reform is faster at the back end:
| Milestone | Agreed | Was, in the 2023 proposal |
|---|---|---|
| EU Customs Authority begins work | 2027 | 2028 |
| Data Hub for e-commerce | 1 July 2028 | 2028 |
| Data Hub for other traders, voluntary | 2031 | 2032 |
| Data Hub mandatory | 2034 | 1 January 2038 |
Four years came off the mandatory date. A trader planning capital expenditure on customs systems against 2038 is planning against a number that no longer exists. Reporting on the agreed text describes the final phase as a staged rollout completing on 1 March 2034; that day-level detail rests on secondary sourcing until the regulation is published.
The political agreement is not the law. The text has to be formally adopted by both institutions and published in the Official Journal, and it enters into force twenty days after publication, with the operational milestones running from there. Two specific things remain genuinely open:
For a seller, the near-term planning items are unchanged in kind and larger in number: duty on every parcel since July, a handling fee per consignment from the autumn, EPR obligations per destination member state, and — for anyone established outside the EU — no relief from the authorised representative rule on the table at all.
]]>The proposal is real. Read against the file, though, three qualifications matter more than the reassurance.
COM(2025) 982 final, of 10 December 2025, is a proposal for a Regulation “suspending the application of the rules on the appointment of an authorised representative for extended producer responsibility for batteries and waste batteries and packaging and packaging waste” — part of the environmental omnibus. Article 2 suspends Article 45(3) of Regulation (EU) 2025/40 until January 2035. Article 1 does the same for Article 56(3) of the Batteries Regulation.
Article 45(3) is the provision that requires a producer not established in a destination member state to appoint an authorised representative for EPR there, by written mandate, one per member state. It is the clause that turns selling into ten countries into ten mandates.
The file is 2025/0395(COD). Parliament’s Legislative Observatory records the committee referral on 9 February 2026, a draft report in ENVI in May 2026 — the document itself is dated 28 May — amendments tabled on 1 July 2026, and an indicative first-reading plenary date of 5 October 2026. The status is “awaiting committee decision”.
Nothing in Article 45(3) is suspended in the meantime. It began to apply on 12 August 2026 along with the rest of the Regulation, and a proposal to suspend a provision has no legal effect on that provision while it is pending. A seller who reads the Commission’s comment as permission to stop appointing representatives is relying on a text that does not yet exist.
This is the qualification the Instagram replies handle loosely. One of them describes the change as being for “EU companies shipping goods to other EU countries”, which is accurate. The other simply says “our companies, big and small”.
The proposal is explicit. It “would provide additional flexibility by allowing producers established in the Union and selling products in another Member State to choose whether they appoint an authorised representative for EPR”, and then states that provisions for producers based in third countries “should remain as they currently are contained in sectoral legislation”.
So a French seller shipping to Germany would gain a choice. A British, Turkish, Swiss or American seller shipping into the EU would gain nothing at all. For readers of this site, that distinction is the whole story: the group facing the highest per-parcel compliance cost is the group the suspension does not reach.
Parliament’s draft report narrows it further, and in one respect tightens it. PE788.916, of 28 May 2026, proposes three changes that matter here:
This is a draft report, not a committee position: amendments were tabled on 1 July 2026 and ENVI has not voted. But the direction of travel in Parliament is towards a narrower exemption, and specifically towards keeping non-EU sellers exactly where they are.
The Commission also says it “suggested to national authorities to avoid sanctioning non-compliant companies, but rather give them a warning”. That is worth knowing, and it is worth not over-reading. Enforcement of EPR is a national competence exercised by national registers and authorities; a suggestion from the Commission neither amends Article 44 nor binds a member state that decides to enforce. Article 44 still makes an unregistered making-available unlawful, and marketplaces still have to check registration before listing, which is where most small sellers meet the rule in practice.
A change.org petition started by Jeanette Koňarčíková, an independent artist in Slovakia, had 59,709 signatures as at 14 August 2026. It asks for an immediate moratorium on cross-border registration and representative fees for micro-businesses, an EU-wide de minimis threshold below which small-volume sellers are exempt, and a genuine one-stop shop so a sole trader registers once rather than 27 times. It is a campaign rather than a legal instrument, and it is not the petition procedure under Article 227 TFEU, which is filed with Parliament and produces a formal reply.
The Commission’s own call for evidence on environmental simplification, open from 22 July to 10 September 2025, drew 190,998 contributions, of which 189,751 — 99.3% — came from citizens rather than organisations. Whatever else the omnibus is, it is a response to volume of complaint.
The Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40, replaces Directive 94/62/EC and begins to apply today, 12 August 2026. The substitution of a regulation for a directive is the operative legal fact. A directive requires transposition into national statutes and produces 27 variants. A regulation applies directly, in identical text, with no national step in between.
The instrument was published in the Official Journal on 22 January 2025 and entered into force on 11 February 2025. Article 71 set the general date of application eighteen months later. It also amends Regulation (EU) 2019/1020 on market surveillance and Directive (EU) 2019/904 on single-use plastics.
Harmonisation covers design, substance limits and documentation. It does not cover the money. Registration and fees stay national, administered by national registers and national producer responsibility organisations. That split produces the arithmetic in the merchant’s notice.
Article 44 requires a producer to register in every member state where it first makes packaging or packaged products available. The same article bars a producer from making covered packaging available in a member state where it, or its relevant representative, is not registered. There is no single European licence. A Spanish registration covers Spain and confers nothing in Germany, France or Italy. For a direct-to-consumer seller shipping parcels across borders, the destination market is where the packaging is first made available, which places the obligation in each country a parcel reaches.
Article 45 assigns the second layer. Under Article 45(1), the producer carries the cost of collection and recovery in the member state where the packaging is expected to become waste. Article 45(3) requires a producer not established in the destination state to appoint, by written mandate, an authorised representative for extended producer responsibility there. One representative per member state. No single window, and no equivalent of the value added tax one-stop shop. A seller shipping to France, Germany and Italy needs three mandates, three sets of national filings and three fee relationships.
The fixed cost of compliance therefore scales with the number of destination markets, not with volume. A seller with modest revenue spread across ten member states carries ten registrations, ten mandates and ten reporting cycles; a seller with the same revenue concentrated in one carries one. Small cross-border sellers pay the highest per-parcel compliance cost in the system, which is the opposite of the outcome a single market is meant to produce.
Two things follow for anyone shipping into the EU today:
Enforcement capacity is national and uneven, and several implementing and delegated acts under the Regulation — including harmonised labelling specifications and recyclability performance grades — arrive after today’s date of application. The obligations that bite immediately are the registration, representation and fee obligations above, because they exist in the base text and need no further act.
The direction of travel is consistent with everything else moving through Brussels right now: harmonise the rulebook at EU level, keep the collection machinery national, and place liability on the seller rather than the buyer. The same pattern governs the customs reform that removed the €150 duty relief and the EU Customs Data Hub arriving in 2028.
]]>Every rule described elsewhere on this site — the €3 flat duty, the expanded parcel dataset, the shifted customs debtor — is a bridge to one thing: the EU Customs Data Hub. Understand the destination and the interim measures stop looking arbitrary.
Today an import declaration is filed into a national system. Twenty-seven member states, twenty-seven implementations, twenty-seven sets of local practice sitting on top of the same Union Customs Code. A seller shipping to five markets deals with five interfaces and five customs administrations.
The Data Hub inverts that. It is a single EU-level data layer into which traders supply information about goods, supply chains and parties — once — with the national administrations and a new EU Customs Authority drawing on the same pool. The design intent is a shift from declaration-based customs to data-driven customs: instead of a document filed per shipment at the border, a continuous data relationship with authorities that can be risk-scored before goods move.
The reform package was proposed in May 2023. The sequencing that matters now:
| When | What |
|---|---|
| 2026 | Duty relief removed; flat charge and expanded parcel data as interim measures |
| 2028 | Data Hub opens for e-commerce consignments; platforms act as deemed importers |
| 1 Jul 2028 | Transitional flat duty expires; normal tariff treatment intended |
| 2031 | Data Hub opens to all other traders, on a voluntary basis |
| 2034 | Data Hub use becomes mandatory for all traders |
Dates beyond 2028 depend on legislative texts still moving and on delivery of a very large IT programme. The 2028 e-commerce milestone is the one to plan against; 2031 and 2034 are direction, not commitment.
The reform makes platforms and distance sellers the deemed importer of goods sold to EU consumers. They carry the customs formalities, the duty and VAT payments, and responsibility for the goods complying with EU product rules. The consumer stops being an accidental importer of record.
For a marketplace, that converts a listing relationship into a customs liability. The predictable consequence is that marketplaces will demand from sellers exactly what they will owe to customs: HS codes, country of origin, value breakdown, compliance documentation — at item level, before the listing goes live rather than after the parcel is stopped. Sellers will feel the 2028 reform as marketplace onboarding rules in 2027.
Nothing here rewards waiting for the final legal text.
The through-line of EU commerce policy since 2021 is consistent: harmonise the rulebook centrally, keep collection national where money is involved, and push liability from the consumer onto whoever is closest to the sale. The PPWR obligations that started on 12 August 2026 follow the same logic in a different domain. The Data Hub is that principle applied to the border itself.
]]>Since 2021 the EU has charged import VAT on every consignment, whatever its value. Customs duty was the remaining exemption: consignments with an intrinsic value under €150 entered duty-free. As of today that exemption is gone.
The Commission announced the removal in November 2025 and the Council gave the measure its final green light on 11 February 2026. What applies from 1 July 2026 is a transitional flat customs duty of €3 on low-value imports, running until 1 July 2028 — the point at which the EU Customs Data Hub is expected to make full tariff classification workable at parcel volume.
Three euro sounds negligible. The unit of charge is what matters: it applies per item, not per consignment. A €14 phone case is a €17 phone case. A four-item basket of low-value goods carries four charges. For catalogues built on sub-€20 average order values shipped from outside the EU, this is a margin event, not a rounding error.
A separate handling fee, discussed at around €2 per consignment and expected from roughly November 2026, is still being negotiated between the Council and the Parliament. Treat the amount and the date as unsettled until the trilogue closes; treat the existence of some such fee as likely.
The flat duty expires in 2028. Two changes underneath it do not.
The merchant becomes the customs debtor by default. The old model quietly put the consumer in the frame as importer of record, with the carrier clearing on their behalf and billing them on the doorstep. The new model puts the seller there. Being the debtor means the duty, the penalties for misdeclaration and the audit exposure sit with the business, not the buyer.
Data becomes the entry condition. An expanded dataset for low-value consignments is expected to be required from late 2026 — reporting from several logistics providers points to 1 November 2026, though this is operational guidance rather than a Council date, so verify against your carrier’s published schedule. Whatever the exact day, the substance is not in doubt: item-level detail, correct HS codes and accurate country of origin per line, not per shipment.
The EU is not alone. The United States suspended its own de minimis treatment for Chinese-origin goods in May 2025 and extended the suspension globally in August
The common direction across all three: the duty-free floor for small parcels was a policy built for a world of occasional gifts, and it is being dismantled in a world of daily direct-to-consumer freight. Nobody is planning to restore it.
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