# EU or Not — full corpus > Independent tracking of the rules that govern selling into the European Union: customs reform and the EU Customs Data Hub, de minimis, packaging and EPR, VAT, product compliance and market surveillance. Generated 2026-08-14. 6 articles, newest first. Canonical site: https://euornot.eu/ — text licensed CC BY 4.0, attribute euornot.eu. --- # ViDA's quiet half: the VAT registrations that disappear in 2028, and the one that replaces them Source: https://euornot.eu/vida-single-vat-registration-2028/ Published: 2026-08-14 Section: VAT Tags: vat, vida, oss, ioss, single-vat-registration, cross-border Licence: CC BY 4.0 — attribute euornot.eu Summary: The e-invoicing headlines are about 2030. For anyone moving goods across EU borders the operative date is 1 July 2028, when OSS swallows domestic B2C sales, call-off stock is retired and a new scheme covers transfers of your own stock. Key dates: - 11 Mar 2025: ViDA adopted, Directive (EU) 2025/516 - 1 Jan 2027: OSS and IOSS clarifications; interim reporting rules - 1 Jul 2028: Single VAT registration; transfers of own goods scheme - 30 Jun 2028: Last day to enter goods into call-off stock - 30 Jun 2029: Call-off stock ceases to apply entirely - 1 Jul 2030: Digital reporting for cross-border B2B VAT in the Digital Age is usually discussed as an e-invoicing reform, and e-invoicing is the part that arrives last: digital reporting for cross-border business-to-business transactions starts on 1 July 2030, with national real-time reporting systems required to converge on it by 1 January 2035. For a merchant shipping goods, the date that matters is two years earlier, and it goes in the opposite direction from everything else this site tracks. It removes registrations rather than adding them. 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. ## What changes on 1 July 2028 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. ## Call-off stock is being retired The call-off stock simplification in Article 17a goes, in two steps that are easy to misread: - **30 June 2028** — the last day goods may be dispatched or transported into a call-off stock arrangement. - **30 June 2029** — Article 17a ceases to apply at all, which gives arrangements started before the first date the usual twelve-month window to be sold or returned. 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. ## What this does not do 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](/customs-reform-agreed-handling-fee-data-hub-dates/) rather than through the VAT directive. And it does not help with extended producer responsibility. EPR registration and the [authorised representative mandate](/ppwr-eu-2025-40-applies-today/) 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. ## The sequence, to 2035 | 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. ## Sources - Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AL_202500516 — Article 17a end dates, the transfers of own goods scheme, extended OSS and Article 194 reverse charge - Commission Implementing Regulation (EU) 2026/1869 of 27 July 2026, OJ L, 28.7.2026: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AL_202601869 — technical rules for the schemes; Articles 1 and 3 apply from 1 July 2028, Article 2 from 1 January 2027 - DG TAXUD — VAT in the Digital Age: https://taxation-customs.ec.europa.eu/taxation/vat/vat-digital-age-vida_en - DG TAXUD — VAT in the Digital Age: 2026 work programme, 22 May 2026: https://taxation-customs.ec.europa.eu/news/vat-digital-age-2026-work-programme-available-2026-05-22_en — sequencing of the three pillars to 2035 --- # The customs reform is agreed: a handling fee by November, and the Data Hub calendar moves Source: https://euornot.eu/customs-reform-agreed-handling-fee-data-hub-dates/ Published: 2026-08-14 Section: Customs Tags: customs, data-hub, handling-fee, de-minimis, deemed-importer, cross-border Licence: CC BY 4.0 — attribute euornot.eu Summary: Council and Parliament settled the customs overhaul on 26 March 2026. A per-parcel handling fee arrives no later than 1 November, platforms become the importer, and the Data Hub dates are no longer the ones from the 2023 proposal. Key dates: - 26 Mar 2026: Council and Parliament agree the reform - 1 Nov 2026: Handling fee applies, at the latest - 2027: EU Customs Authority begins work - 1 Jul 2028: Data Hub opens for e-commerce - 2031: Data Hub opens to other traders, voluntarily - 2034: Data Hub becomes the mandatory single entry point The customs reform this site has been treating as pending is agreed. Council and Parliament reached political agreement on 26 March 2026 on the overhaul of the Union Customs Code — the Council calls it the greatest reform since the Customs Union was created in 1968 — and the agreed text answers two questions this site has been flagging as open. ## The handling fee is no longer hypothetical 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](/eu-de-minimis-ends-3-euro-flat-duty/), 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. ## Platforms are the importer 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](/eu-de-minimis-ends-3-euro-flat-duty/) described as the durable part of the 2026 changes, now fixed in the agreed text rather than proposed. ## The Data Hub calendar moved, and this site had the old one 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](/eu-customs-data-hub-2028/) and on the [timeline](/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. ## What is still not done 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: - **The handling fee level**, until the delegated act is adopted. - **Whether the €3 flat duty is extended** beyond 1 July 2028. The agreed text allows for it, and the Data Hub's readiness for parcel-level tariff classification is what will decide it. 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](/commission-authorised-representative-suspension/) on the table at all. ## Sources - Council of the EU — EU customs: Council and Parliament agree on landmark reform, 26 March 2026: https://www.consilium.europa.eu/en/press/press-releases/2026/03/26/eu-customs-council-and-parliament-agree-on-landmark-reform/ - European Commission — Commission welcomes historic agreement to reform the EU Customs Union, 26 March 2026: https://cyprus.representation.ec.europa.eu/news/commission-welcomes-historic-agreement-reform-eu-customs-union-2026-03-26_en — Commission statement of the agreed dates and the handling fee - DG TAXUD — guidance and legal text on the temporary flat fee applying until 1 July 2028: https://taxation-customs.ec.europa.eu/news/guidance-and-legal-text-temporary-flat-fee-low-value-imports-which-will-apply-until-1-july-2028-2026-06-08_en — Council Regulation (EU) 2026/382; delegated and implementing acts adopted 30 April 2026, guidance published 8 June 2026 - Council of the EU — modernising the EU customs union: https://www.consilium.europa.eu/en/policies/modernising-the-eu-customs-union/ — file overview and procedural status --- # The Commission says relief is coming for authorised representatives. It is a proposal, and it is narrower than it sounds Source: https://euornot.eu/commission-authorised-representative-suspension/ Published: 2026-08-14 Section: Packaging & EPR Tags: ppwr, epr, packaging, authorised-representative, simplification, cross-border Licence: CC BY 4.0 — attribute euornot.eu Summary: Replying to angry small sellers on Instagram, the Commission points to its December 2025 proposal to suspend the authorised representative obligation until 2035. The proposal is real, still in committee, and covers producers established in the EU — not sellers outside it. Key dates: - 10 Dec 2025: Commission proposes suspension, COM(2025) 982 - 12 Aug 2026: Article 45(3) applies, unchanged - 5 Oct 2026: Indicative first-reading plenary date - 1 Jan 2035: Proposed end of the suspension Two days after [PPWR started to apply](/ppwr-eu-2025-40-applies-today/), the European Commission has been replying to small businesses in its Instagram comments. The wording is unusually direct: "To all small businesses concerned about the new EU packaging rules — we hear you, and we are here to support!" It goes on to say the Commission asked Parliament and member states "to stop the obligation to appoint Authorised Representatives for EU companies shipping goods to other EU countries", that the legal proposal was made in December 2025, and that it "now needs the agreement of EU lawmakers". The proposal is real. Read against the file, though, three qualifications matter more than the reassurance. ## What was actually proposed 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. ## It is not law, and it applies today 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. ## The relief stops at the EU border 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: - **Micro and small enterprises only.** A new paragraph would provide that the Regulation "shall apply only to producers qualifying as 'microenterprises' or 'small enterprises' within the meaning of Annex I to Commission Recommendation 2003/361/EC" — under that Recommendation, fewer than 50 staff and turnover or balance sheet total of €10 million or less, with micro set at fewer than 10 staff and €2 million. Medium-sized and large producers would keep the mandate. The rapporteur's justification is that they are "better equipped to comply". - **An earlier end than 2035.** The suspension would run to 1 January 2035 "or the entry into force of the [circular economy act]", whichever is earlier, and a new article would end it on the date the Circular Economy Act applies. - **Less flexibility on third-country producers, not more.** The Commission's text let member states either require an authorised representative from third-country producers or ensure traceability "through alternative means". The draft report deletes that option outright, to preserve "the mandatory appointment of an authorised representative for producers established in third countries in order to ensure effective traceability and enforcement". 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. ## Enforcement discretion is not a defence 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. ## The pressure behind it A [change.org petition](https://www.change.org/p/stop-destroying-eu-micro-businesses-immediate-moratorium-on-cross-border-epr-fees) 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. ## What to do while it is pending - **Comply with Article 45(3) as it stands.** Mandates in each destination member state where you are not established, and registration under Article 44 before the first shipment. - **If you are established in the EU, track 2025/0395(COD) rather than the press.** The ENVI vote, not the Commission's messaging, decides whether the mandate becomes optional and for whom. - **If you are established outside the EU, plan on no change.** Nothing currently on the table alters your position, and the transitional flat duty and Data Hub timetables continue independently. ## Sources - COM(2025) 982 final — Proposal suspending the rules on appointing an authorised representative for EPR, 10 December 2025: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52025PC0982 — Article 2 suspends Article 45(3) PPWR; explanatory memorandum, p. 2, on third-country producers - Procedure file 2025/0395(COD), European Parliament Legislative Observatory: https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025%2F0395%28COD%29 — ENVI, rapporteur Ingeborg ter Laak; draft report listed 22 May 2026, amendments 1 July 2026 - ENVI draft report PE788.916v01-00, 28 May 2026, rapporteur Ingeborg Ter Laak: https://www.europarl.europa.eu/doceo/document/ENVI-PR-788916_EN.html — amendments 10 and 13 limit it to micro and small enterprises; 11 and 14 delete the third-country flexibility; 16 ends it with the Circular Economy Act - Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22.1.2025: https://eur-lex.europa.eu/eli/reg/2025/40/oj — Article 45(3), the obligation at issue - European Commission, replies to small businesses on Instagram, 14 August 2026: https://www.instagram.com/europeancommission — official verified account; the quotations are from pinned replies in comment threads, which carry no stable permalink — screenshots on file - Petition — Stop destroying EU micro-businesses: immediate moratorium on cross-border EPR fees: https://www.change.org/p/stop-destroying-eu-micro-businesses-immediate-moratorium-on-cross-border-epr-fees — campaign, not a legal instrument; signature count as at 14 August 2026 --- # The regulation that arrives today: PPWR and the 27 registrations behind it Source: https://euornot.eu/ppwr-eu-2025-40-applies-today/ Published: 2026-08-12 Updated: 2026-08-14 Section: Packaging & EPR Tags: ppwr, epr, packaging, cross-border, compliance Licence: CC BY 4.0 — attribute euornot.eu Summary: Regulation (EU) 2025/40 applies from 12 August 2026. It harmonises packaging design and documentation across the EU — and leaves registration and fees national, which is where the cost lands for cross-border sellers. Key dates: - 22 Jan 2025: Published in the Official Journal - 11 Feb 2025: Entry into force - 12 Aug 2026: General date of application (Article 71) **Update, 14 August 2026.** The Commission has pointed small sellers to its December 2025 proposal to suspend the authorised representative obligation until 2035. The proposal is pending, and covers producers established in the EU only — Article 45(3) below applies unchanged in the meantime. [What the proposal does and does not do](/commission-authorised-representative-suspension/). 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. ## Harmonised text, national money 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. ## What the split costs 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: - **Registration precedes sale, not follows it.** Article 44 makes an unregistered making-available unlawful. Backfilling registration after the first shipment does not cure the breach. - **Marketplaces are now a checkpoint.** Online platform providers must obtain and assess producer registration and EPR information before listing. Missing registrations surface as delisting long before they surface as enforcement. ## What is still open 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](/eu-de-minimis-ends-3-euro-flat-duty/) and the [EU Customs Data Hub arriving in 2028](/eu-customs-data-hub-2028/). ## Sources - Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22.1.2025: https://eur-lex.europa.eu/eli/reg/2025/40/oj — legal text, Articles 44, 45 and 71 - European Commission — packaging waste policy: https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en --- # The EU Customs Data Hub: what 2028 actually means for sellers Source: https://euornot.eu/eu-customs-data-hub-2028/ Published: 2026-08-05 Updated: 2026-08-14 Section: Customs Tags: customs-data-hub, customs-reform, deemed-importer, platforms, cross-border Licence: CC BY 4.0 — attribute euornot.eu Summary: One EU-level data layer replaces 27 national customs systems, platforms become deemed importers, and the declaration gives way to a continuous data feed. Here is the timeline and what it changes. Key dates: - 17 May 2023: Commission proposes the customs reform package - 2028: Data Hub opens for e-commerce; platforms act as deemed importers - 1 Jul 2028: Transitional flat duty on low-value imports expires - 2031: Data Hub opens to all other traders, voluntarily - 2034: Use of the Data Hub becomes mandatory for all traders **Correction, 14 August 2026.** This piece originally gave the Data Hub's later milestones as 2032 and 1 January 2038, the dates in the Commission's 2023 proposal. The text agreed by Council and Parliament on 26 March 2026 sets them at 2031 and 2034. The dates below have been corrected and [the agreement is covered here](/customs-reform-agreed-handling-fee-data-hub-dates/). Every rule described elsewhere on this site — the [€3 flat duty](/eu-de-minimis-ends-3-euro-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. ## What it replaces 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 timeline 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. ## Deemed importer: the structural change 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. ## What to build now Nothing here rewards waiting for the final legal text. - **Item-level product data.** HS code, country of origin, intrinsic value, materials and compliance references as first-class SKU fields, owned by someone, with a review cycle. This is the input every 2026–2028 requirement consumes. - **One data model, many destinations.** The Data Hub's premise is supply once. Systems that keep customs data per-carrier or per-marketplace will need to be unpicked. - **Landed cost as a live calculation.** Duty on every parcel plus per-market EPR fees means checkout price and margin depend on destination. Hard-coded shipping tables will not survive. - **Know who your importer of record is per flow.** After 2028 the answer differs between marketplace sales, own-site DDP sales and B2B shipments. Each needs a documented position now. 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](/ppwr-eu-2025-40-applies-today/) follow the same logic in a different domain. The Data Hub is that principle applied to the border itself. ## Sources - European Commission — EU customs reform proposals (DG TAXUD): https://taxation-customs.ec.europa.eu/ - DG TAXUD — temporary flat fee until 1 July 2028: https://taxation-customs.ec.europa.eu/news/guidance-and-legal-text-temporary-flat-fee-low-value-imports-which-will-apply-until-1-july-2028-2026-06-08_en - Council — new customs duty rules for small parcels, 11 February 2026: https://www.consilium.europa.eu/en/press/press-releases/2026/02/11/council-gives-final-green-light-to-new-customs-duty-rules-for-small-parcels/ --- # The €150 exemption is gone: what the €3 flat duty actually changes Source: https://euornot.eu/eu-de-minimis-ends-3-euro-flat-duty/ Published: 2026-07-01 Updated: 2026-08-14 Section: Customs Tags: de-minimis, customs, ioss, low-value-imports, cross-border Licence: CC BY 4.0 — attribute euornot.eu Summary: From 1 July 2026 every parcel entering the EU carries duty. The flat €3 charge is a stopgap until the Customs Data Hub, but the liability shift underneath it is permanent. Key dates: - 13 Nov 2025: Commission announces removal of the €150 threshold for 2026 - 11 Feb 2026: Council gives final green light to the small-parcel duty rules - 1 Jul 2026: Flat duty applies to low-value consignments - 1 Jul 2028: Flat-fee regime expires; standard tariff treatment takes over **Update, 14 August 2026.** The handling fee described below as unsettled was agreed by Council and Parliament on 26 March 2026 and applies no later than 1 November 2026, with the level left to a Commission delegated act. [What the agreement settled](/customs-reform-agreed-handling-fee-data-hub-dates/). 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](/eu-customs-data-hub-2028/) is expected to make full tariff classification workable at parcel volume. ## The number is small; the unit is not 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 permanent part is the liability 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. ## What this forces operationally - **Landed cost at checkout.** With duty on every parcel, delivered-duty-paid pricing stops being a premium option. Duty collected after the fact is a refused delivery. - **HS codes as product data.** A code guessed once at catalogue level will not survive item-level declaration. It belongs in the SKU record, maintained, with country of origin beside it. - **IOSS is still the VAT route, not a duty route.** The H7 declaration path remains for low-value goods; it does not exempt you from the new duty. - **Consolidation strategy changes.** When duty is charged per item, splitting or merging parcels no longer moves the number the way it used to. Model it again. ## The wider picture 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 2025. The United Kingdom is keeping its £135 relief into late 2026, with full removal signalled for later this decade; the detail there — fiscal representation, data level, handling fees — is not settled. 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. ## Sources - European Commission — 150 EUR customs duty exemption threshold to be removed as of 2026: https://taxation-customs.ec.europa.eu/news/e-commerce-150-eur-customs-duty-exemption-threshold-be-removed-2026-2025-11-13_en - Council — final green light to new customs duty rules for small parcels, 11 February 2026: https://www.consilium.europa.eu/en/press/press-releases/2026/02/11/council-gives-final-green-light-to-new-customs-duty-rules-for-small-parcels/ - DG TAXUD — guidance and legal text on the temporary flat fee applying until 1 July 2028: https://taxation-customs.ec.europa.eu/news/guidance-and-legal-text-temporary-flat-fee-low-value-imports-which-will-apply-until-1-july-2028-2026-06-08_en - Swap Commerce — new rules for cross-border commerce after de minimis: https://www.swap-commerce.com/blog/new-rules-cross-border-commerce-post-de-minimis — secondary source, used for merchant-side operational detail