EU Import Duty Changes in 2026: What Fashion Brands Should Check

From 1 July 2026, low-value B2C orders under €150 shipped from shipped from outside the EU to EU consumers face a temporary €3 customs duty.

For fashion and lifestyle brands using cross-border shipping into Europe, the change affects import duty costs, product data, VAT/IOSS setup, checkout charges, and returns.

EU €3 Customs Duty in 2026: What Changed for Orders Under €150

A flat €3 customs duty applies per item category from 1 July 2026. Product identifier requirements start later, from 1 November 2026, and are covered in the next section.

Until recently, parcels valued under €150 cleared EU customs without owing duty. Now, low-value B2C consignments entering the EU are subject to a fixed €3 customs duty.

This temporary rule runs until 1 July 2028. After that, standard customs duties are expected to apply depending on the type of goods.

Legal basis: Council Regulation (EU) 2026/382 removed the customs duty relief for low-value consignments under €150. Commission Implementing Regulation (EU) 2026/1200 sets the implementing rules.

Product Identifier Requirements for EU Customs Declarations

From 1 November 2026, product identifiers will become mandatory on customs declarations for low-value EU import consignments. Brands can provide them voluntarily before then, giving them time to check whether the new identifiers are set up correctly.

The required product identifiers are:

• Merchant Product Identifier: the seller’s internal product identifier, such as a stock keeping unit (SKU)
• Manufacturer Product Identifier: the product code assigned by the manufacturer or supplier
• Standardized Product Identifier: a global product identifier, such as a Global Trade Item Number (GTIN), International Article Number (EAN), or Universal Product Code (UPC), where available

This data should be ready to move from the product catalog into the customs declaration.

Who Is Affected by the EU €3 Import Duty?

The EU €3 import duty applies to B2C e-commerce consignments valued at €150 or less when goods are shipped from outside the EU to EU consumers.

It is not limited to sellers using the Import One Stop Shop (IOSS), the EU scheme for charging value-added tax (VAT) at checkout on imported goods valued at €150 or less. B2B and C2C shipments are outside this temporary flat-duty measure.

Below is a summary of what is not in scope:

• B2B shipments – goods sold to another business remain unaffected by this measure and continue under the usual customs rules
• C2C shipments – person-to-person sales (e.g., used goods, crafts) remain exempt under existing thresholds
• Consignments over €150 – these were never covered by the old de minimis relief and are unchanged and thus attract standard tariff-based duty

If your EU sales run through a mix of channels as wholesale, marketplaces acting as deemed importer, or B2B channels, as well as D2C, your exposure to this specific charge will apply only to your pure D2C e-commerce sales.

VAT and the New €3 Customs Duty Are Separate Charges

The new €3 customs duty is separate from VAT and does not replace existing VAT obligations. Since 2021, low-value goods imported into the EU have been subject to import VAT after the €22 VAT exemption was removed. IOSS still allows sellers to charge VAT at checkout and report it through a single monthly return.

What changes from 1 July 2026 is customs duty. Until 30 June 2026, consignments under €150 could still enter the EU without customs duty. Until 2028, import VAT still applies, and the temporary €3 customs duty is added per item category.

For brands, the difference is where the cost appears:

• With IOSS, VAT is charged at checkout, while the €3 duty is handled through the customs declaration
• Without IOSS, the duty may be included in the VAT taxable amount at import

Either way, brands should check whether checkout, carrier, or broker setup can show the full landed cost before the order reaches the customer.

How Is the €3 Duty Charged by HS Code and Item Category?

The €3 duty is charged per item category based on HS code or commodity code, not per product and not per parcel. What matters is the number of distinct HS codes, not the quantity of items.

HS code, short for Harmonized System code, is a numerical code used to classify products that are shipped or traded. Among other purposes, HS codes are used to classify tariffs and duties on traded goods. It is administered by the World Customs Organization and is recognized internationally.

For example:

• Single HS code: 5 of the same T-shirts in one parcel = €3
• Two/multiple HS codes: 3 T-shirts + 2 pairs of trousers = €6, 1 blouse + 1 skirt + 1 pair of jewelry = €9
• Same HS code, different colours/sizes: 1 black dress (size S) + 2 white dresses (size L) = €3

Important: Where the temporary €3 duty applies, items classified under different tariff subheadings within the same parcel cannot be grouped into a single declaration line. Article 177 grouping rules should be checked separately, because this temporary duty is calculated by item category.

Separate handling fees per parcel are still under discussion. Some industry sources discuss a possible €2 handling fee per parcel from November 2026, but the EU has not confirmed the final amount, application date, or customs clearance process with carriers and postal service providers.

Why Accurate HS Code Classification Matters for EU Import Duty

Accurate product catalog data and standardized product identifiers, such as GTIN, EAN, or UPC, are needed for correct customs processing and duty calculation.

Software can still assign a generic or incorrect HS code, which creates risk if the classification is not checked before the customs declaration.

A minor data mismatch can lead to the wrong tariff classification or a duplicate declaration line, increasing duty charges. Incorrect paperwork can also cause customs delays, which affect delivery timelines and customer experience.

If you sell curated kits or product sets, some multi-item packages may require separate HS codes. If the products are not correctly classified or the required product identifiers are missing, this can cause customs delays and additional charges.

How the €3 Duty Can Affect Fashion Order Costs

Multi-SKU orders are very common in fashion. Customers usually order multiple products in one checkout. Under the new rules, a single checkout can generate multiple €3 duty charges if products fall under different HS codes.

For example, a brand shipping 800 orders a month, with an average order containing two HS codes, pays €1,600 duty charges a month at €3 each. That equals €4,800 per month, or €57,600 per year. Add the expected handling fee once it lands (€2 per parcel), and that figure would reach €75,000+.

Returns also need to be included in the cost model. Brands should confirm with the carrier, broker, or declarant whether the €3 duty and any handling fee can be recovered on returned or undeliverable shipments.

In fashion, where return rates are already high, brands will face duty costs on products that may not even be sold. Managing these returns can also add administrative work.

Cross-Border Shipping vs. EU Fulfillment After the €3 Duty

Brands shipping EU orders from outside the EU usually compare two options: keep cross-border shipping or move selected stock into EU fulfillment.

Strategic Solution	Pros	Cons
Move selected stock into EU fulfillment	✅ No €3 parcel duty ✅ Faster EU delivery ✅ Local returns ✅ Fewer delivery charges ✅ Better for steady EU demand ✅ Lower parcel shipping costs	❌ Bulk import tariffs ❌ Requires EU declarant ❌ Split stock complexities
Keep stock outside of the EU	✅ Centralized inventory ✅ Simpler stock control	❌ Customs delays ❌ Lower profit margins ❌ Higher return costs ❌ Higher cross-border shipping costs

The better option depends on EU order volume, return rates, and how often one order includes multiple HS codes.

EU Import Duty Checklist for Fashion Brands

Before changing your fulfillment model, check these points against your EU order data.

Your EU Order Volume and HS Codes per Order

Identify how many orders you ship to the EU each month. If an average order contains two or three distinct product categories / HS codes, multiply that by monthly EU order volume to estimate monthly duty exposure.

Product Identifier Readiness

Check whether SKUs, manufacturer product codes, GTINs, EANs, or UPCs are assigned and can be passed into the customs declaration.

Your EU Return Rate

Confirm with the carrier, broker, or declarant whether duty paid on returned or undeliverable shipments can be recovered. Use your EU return rate to estimate how often duty recovery may matter and whether the process is workable at your order volume.

Who Handles the Customs Declaration and Fee Calculation

Confirm whether your business, marketplace, carrier, broker, or declarant is responsible for the customs declaration and fee calculation. This shifts depending on your sales channels and IOSS status.

Based on that setup, confirm whether the declarant can handle precise HS classification down to the tariff subheading, and submit mandatory product identifiers such as SKU, manufacturer code, GTIN, EAN, or UPC per declaration line.

Your IOSS Registration Status

If you sell into the EU and collect VAT at checkout, confirm that your IOSS registration is active and VAT is flowing correctly through your declarations. IOSS affects the VAT flow, but it does not decide whether the €3 duty applies.

Whether You Will Use DDP or DDU

DDP (Delivered Duty Paid) means duty is collected at checkout, and the customer receives their order with no additional charges. DDU (Delivered Duty Unpaid) means duty is collected at the door by the carrier.

DDP can reduce surprise charges at delivery, but checkout and carrier setup must support duty calculation at the point of sale. DDU can be simpler to set up, but customers may refuse delivery if charges appear at the door.

EU Customs Questions to Ask Your Carrier, Broker, Freight Forwarder, or 3PL

Use these questions with the teams and partners handling your EU orders. Their answers should show whether your current setup can handle HS codes, product identifiers, returns, and declarant responsibility.

On HS code accuracy:

• Who assigns and verifies HS codes for our shipments, and who keeps them updated when the Combined Nomenclature changes?
• How do you handle misclassification? What is the process if a code is challenged at customs?

On product identifiers:

• How will SKU, manufacturer code, and GTIN/EAN/UPC data flow from our systems into the customs declaration?
• What happens to a shipment if S-PID data is missing or incorrect after 1 November 2026?

On returns:

• How are returns processed under the new duty framework? Can duties be recovered on returned goods, and who handles that process?
• Where does a returned parcel go, and how is it restocked?

On declarant liability:

• Who is the legal declarant for our EU shipments, and who is liable if the declaration is wrong?
• Do we need fiscal representation in the EU, and can you provide or facilitate this?

These answers may differ by sales channel, so brands should check direct-to-consumer, marketplace, and carrier flows separately.

When to Move Stock to EU Fulfillment After the €3 Duty

EU fulfillment starts to make sense when monthly EU duty exposure, returns, and cross-border shipping costs are higher than the cost of holding selected stock in an EU warehouse. The 2028 tariff transition and any confirmed handling fee should be modeled separately.

Use this table as a screening tool before changing the fulfillment model.

Criteria	Move to EU fulfillment	Keep stock outside the EU
Monthly EU Order	✔️ >500 orders/month or >25% return rates ✔️ Localized shipping savings outweigh the monthly 3PL charges	✔️ Low EU order volume ✔️ EU setup costs outweigh savings
Average Basket Composition	✔️ Multi-item orders ✔️ Several HS codes per order trigger multiple €3 fees	✔️ Single-item orders (hero products) ✔️ One main HS code, simpler DDP pricing
EU Market Focus	Strategic EU market	Secondary EU market
HS Code Complexity	High HS-code mix	Low HS-code mix

If EU fulfillment starts to look cheaper than cross-border shipping, contact Bergen Logistics to review order volume, SKU mix, return rates, and setup requirements.

How Bergen Logistics Helps You Navigate EU Customs Duty Changes

Seamless Setup and EU Expansion

With strategically located fulfillment centers across Europe, Bergen Logistics helps fashion and lifestyle brands move selected inventory closer to EU customers and establish local EU fulfillment operations.

Our team supports inventory placement, operational setup, systems integration, and local order fulfillment. For suitable projects, implementation timelines may be measured in weeks, depending on inventory volume, integration requirements, customs and VAT arrangements, and the brand’s legal structure.

Full Customs and VAT Support Handled for You

Bergen Logistics handles the customs documentation, VAT workflows, and cross-border compliance support connected with EU fulfillment.

For brands without an EU legal entity, we can also support or coordinate fiscal representation where required and available. The exact setup depends on the destination market, sales channels, business structure, and individual compliance requirements.

One System for Full Visibility

Moving inventory into Europe does not mean losing visibility across your fulfillment network.

CloudX WMS, Bergen Logistics’ warehouse management system, provides real-time inventory visibility and access to order fulfillment data across Bergen Logistics fulfillment centers. With more than 50 ready-to-use integrations for ERP, PLM, OMS, and e-commerce platforms, brands can connect local EU fulfillment with their existing technology stack, subject to platform compatibility and implementation requirements.

Built Specifically for Fashion and Lifestyle Brands

With more than 25 years of industry experience, Bergen Logistics specializes in fulfillment and distribution for fashion and lifestyle brands.

We support apparel, footwear, handbags, beauty, home goods, technology accessories, sports accessories, and selected consumer goods. From established fashion labels to fast-growing omnichannel brands, our technology-driven operations support D2C, wholesale, retail, and marketplace fulfillment across Europe.

Returns That Protect Customer Relationships and Capture Revenue

Together with leading return-management technology partners, Bergen Logistics supports fast, trackable EU returns, exchanges, restocking, and inventory updates.

Efficient reverse logistics can help protect the customer relationship, retain revenue through product exchanges, and return eligible products to available inventory for resale. Depending on the product condition and return process, sellable items may be restocked within a few days of receipt.

FAQ: EU €3 Customs Duty, VAT, and IOSS

Does the €3 duty apply per parcel, per item, or per HS code?

The €3 duty applies per item category/tariff sub-heading, not per parcel or per identical unit. A parcel with a single HS code is charged once; a parcel with multiple HS codes may be charged more than once.

Is this duty charged to consumers at the door?

Not by default. The duty is charged to the business or declarant responsible for the import declaration. In most e-commerce flows, that may be the seller, the IOSS holder, the carrier, the postal operator, or the customs representative. If the order is shipped DDU, the carrier may still ask the customer to pay charges before releasing the parcel.

Does the €3 duty replace VAT?

No. VAT on low-value imports has applied since 2021. The €3 duty is a separate customs charge added on top of existing VAT obligations.

How long will the temporary €3 duty last?

The temporary €3 duty applies from 1 July 2026 to 1 July 2028. After that, normal customs duties are expected to apply, depending on the type of goods.

Does this affect B2B shipments?

No. The €3 duty applies to B2C distance sales of imported goods in consignments up to €150. B2B shipments continue under existing customs rules.

Is the €2 handling fee definite?

No. A Union handling fee is still under discussion. The final amount and application date have not been confirmed.

Who calculates and collects the €3 duty?

It depends on who files the import declaration. In most e-commerce flows, this may be the seller, the IOSS holder, the postal operator, the carrier, or the customs representative. The customer is responsible only in residual cases.

At what point in the shipping process is the duty assessed and paid?

The duty is calculated when the import declaration is accepted for release into the EU. Whether the cost is shown at checkout, paid before delivery, or absorbed internally depends on the brand’s DDP/DDU setup and the party filing the declaration.

What happens if I do not use IOSS?

If IOSS is not used, import VAT is due at importation, and the €3 duty forms part of the VAT taxable amount. If IOSS is used, VAT is collected at checkout and the €3 duty is treated separately from the checkout VAT calculation.