05.11.2026 Regulation #EU #Import #E-commerce
EU makes product identifiers mandatory for e-commerce imports
Since 1 November 2026, EU customs authorities require product identifiers (PIDs) to be declared for goods sold through distance sales to buyers in the EU, notably consumers. DG TAXUD reminded the market on 3 November, with details set out in section 8 of the Commission guidance on the temporary EUR 3 duty on low-value parcels.
Three identifiers for every product
According to TAXUD, the declaration must carry three identifiers:
- M-PID (merchant product identifier) is a reference to the product on a website, marketplace or platform. It is assigned by the online seller, marketplace or platform and is unique on that platform.
- NS-PID (non-standardised manufacturer product identifier) is the manufacturer's own reference, such as a model, part or style number, not following an international format.
- S-PID (standardised manufacturer product identifier) follows an international standard, usually an EAN, UPC or ISBN barcode.
Under the guidance, M-PID and NS-PID are always required, while S-PID is required only where one exists. If a manufacturer has no NS-PID, it must assign one in any structure it chooses; an S-PID may also be used as the NS-PID.
How to complete the declaration
PIDs go into data element 12 03 000 000 ("Supporting document") using new document codes: C127 for M-PID, C128 for NS-PID and C129 for S-PID. If there is no S-PID, code Y081 is entered in element 12 04. The codes apply to H1, H6 and H7 declarations when additional procedure codes F48, F49 or F53 are used (Commission guidance, points 8.5–8.6). The element is repeatable: where one declaration item or bundle covers several products, each product's PIDs are listed.
Scope and administrative easements
The requirement applies to distance sales goods with an intrinsic value of up to EUR 150, on the basis of Annex B to Delegated Regulation 2015/2446 as amended by Delegated Regulation (EU) 2026/1022. It concerns mainly B2C transactions; B2B flows are in principle outside the scope. The Commission is preparing a clarification of Annex B on the EUR 150 threshold (point 8.2 of the guidance).
Point 8.8 provides simplifications: for unprocessed agricultural and perishable goods (Chapters 1–15), handicrafts (including 4420 11 and 4420 19, 4602 and some items of 7013) and antiques, collectors' items and art (9701–9706), placeholder "M-PID" in C127 and "NS-PID" in C128 are sufficient. For medical devices, the UDI-DI counts as the S-PID; for legacy devices until 27 November 2026, the CELEX number of the act (32017R0745 or 32017R0746) may be used instead.
Declarant liability and enforcement risk
The declarant, for example an IOSS holder or customs representative, reports the data; platforms and manufacturers pass identifiers along the supply chain. They usually already exist in listings, invoices and on packaging. The guidance states that deliberately declaring a batch-level or unit-level PID where a model-level identifier exists is treated as a breach of the duty to provide complete and accurate data (Article 274(1)(b) of the new EU Customs Code, Regulation (EU) 2026/2108).
From voluntary to mandatory: the timeline to July 2028
- 1 July 2026: voluntary provision of PIDs, without penalties.
- 1 November 2026: the requirement becomes mandatory and enforced.
- July 2028: more comprehensive product data requirements once the EU Customs Data Hub for e-commerce is deployed.
Primary sources
- DG TAXUD: Product identifiers for e-commerce imports mandatory from 1 November 2026
- European Commission: Customs Guidance on EUR 3 customs duty (Guidance for Member States and Trade), section 8
Mentioned codes
This material is for information only and does not constitute legal advice or customs consulting. Verify changes against the primary sources before acting.