| ⚠️ This article applies to merchants selling to EU consumers. Key dates: 1 July 2026 (duty change) and 1 November 2026 (product identifier requirements become mandatory).
De minimis removal and the new product identifier requirements mark the beginning of sweeping customs reform within the EU, which will only continue to evolve over the coming months and years. It is crucial as a merchant selling into the EU that you understand the below and start to enrich your catalog with the necessary data for product identifier requirements well ahead of the November deadline.
What’s changing
Since 2021, the EU has required VAT on all cross-border orders — but goods shipped directly to EU consumers from outside the EU were exempt from customs duty if their value was below €150. That threshold is called the de minimis, and it is being removed.
From 1 July 2026, every order shipped to an EU consumer from outside the EU — regardless of value — requires a full customs declaration and is subject to duty. For low-value orders (under €150), the EU has introduced a flat duty of €3 per product category (HS code) per declaration line. This flat fee is a temporary measure while the EU works to accurately determine what duty rates should be for the different classes of low-value items.
From 1 November 2026, an additional €2 EU handling fee per declaration line is introduced, bringing the combined per-line charge to €5. Product identifier requirements also become mandatory on that date.
What the new duty means in practice
The most important thing to understand is that the €3 applies per product category, not per unit or per order.
A customer orders one T-shirt: €3 duty
A customer orders two T-shirts (same HS code): €3 duty
A customer orders a T-shirt and a pair of socks (two HS codes): €6 duty
A customer orders ten different items across ten HS codes: €30 duty
Brands with diverse catalogues and multi-SKU orders are more exposed to this change than brands with focused product ranges. A jewellery brand shipping a single piece per order is less affected than a fashion brand whose customers regularly order across multiple product categories.
In addition to the new duty, the following compliance changes will take effect:
The primary 'customs debtor' of an EU import will change. Formerly, it was the end consumer who theoretically held the duty liability (which for shipments under €150 in practice did not exist). Following 1 July, the customs debtor will become the IOSS holder, meaning the duty liability that previously sat with the consumer now sits with you.
For the time being, merchants will no longer be able to claim preferential origin under a free trade agreement if the product is being shipped via IOSS. We don't know exactly when this will change as the EU has not yet published guidance on how preferential origin should be declared on low-value IOSS shipments - we will update this article as soon as this guidance has been published.
Additional data fields will become mandatory for shipment documentation to the EU (more on this below).
ℹ️ Orders over €150 continue under standard ad-valorem duty rules, which are unchanged.
How Swap handles the new duty
From 1 July, Swap will automatically apply the €3 per HS code to EU-bound orders under €150 at checkout. No configuration changes, toggles, or activation steps are required. What the change means for your revenue depends on how your store is set up.
Dynamic pricing / checkout strategy
Duty is calculated and added on top of the product price at checkout. The €3 per HS code is passed directly to the customer — your net revenue per order is unchanged.
What to consider: EU customers will see a higher checkout total. If you have a significant volume of EU shoppers with diverse carts, it’s worth communicating this change proactively so it doesn’t come as a surprise.
TLC-inclusive pricing
Swap’s Total Landed Cost model applies a percentage uplift to cover duties and VAT within the product price. In most configurations, your existing duty buffer should be sufficient to absorb the new €3 flat charge — no changes to your Swap setup are required.
What to consider: Before July 2026, no duty was owed on sub-€150 EU orders — meaning your duty buffer was effectively additional margin. From July, that buffer now goes toward paying real duty. If you have a high volume of low-value, multi-SKU EU orders, review your price buffers to make sure you’re comfortable with the new margin profile.
Fixed storefront pricing
The product price is fixed, so duty compresses your net revenue. For every EU order under €150, you’ll net €3 less per product category in the cart.
What to do: Review and update your EU market prices before 1 July to account for the additional duty cost.
New product identifier requirements
Alongside the duty change, the EU is introducing mandatory product identifier requirements for all customs declarations. Every line item on an EU customs declaration must carry up to three identifiers.
These are strongly recommended from 1 July 2026 and mandatory from 1 November 2026. Declarations missing required identifiers from November risk rejection or delay at EU customs.
The three identifiers
1. Merchant Product ID — your internal product code, typically your SKU. Required for every variant. You almost certainly have this already; the question is whether it’s correctly populated in Shopify at variant level.
2. Manufacturer Product ID — the manufacturer’s own product reference: a style number, model number, or production code. If you manufacture your own products, this will typically be the same as your SKU. If you sell products made by someone else, you’ll find this reference on the product tag, swing label, or supplier invoice.
ℹ️ The Manufacturer Product ID is a new requirement. Swap is working to include it on EU commercial invoices — but you need to ensure the data is in your Shopify catalogue first.
3. Standardised Product ID (where available) — the barcode number on your product packaging: a GTIN, EAN (13-digit), or UPC (12-digit). This is only required if it exists. If your products have no barcodes, leave this field blank in Shopify — do not invent or guess a number. If your products do have barcodes, the number printed beneath the barcode is what you need.
⚠️ These identifiers must be provided at the variant level. A T-shirt available in three sizes and two colours is six separate variants, each needing its own identifier set. A parent-level SKU is not sufficient.
What to check in Shopify
Open your Shopify product catalogue.
For each variant, confirm the SKU field is populated.
Ensure the Barcode field (GTIN/EAN/UPC) is filled in for any products that have one.
Add your Manufacturer Product ID — this is stored as a Shopify metafield. Contact your Swap account manager if you’re unsure where to add it.
If you have a large catalogue, export a product CSV from Shopify to identify gaps across all variants at once rather than reviewing product by product.
Frequently asked questions
Does the €3 duty apply to all my EU orders?
It applies to EU-bound shipments from outside the EU where the order value is €150 or under. Orders above €150 follow standard duty rules, which are unchanged.
Do I need to do anything to activate the new duty calculation in Swap?
No. Swap applies the €3 automatically from 1 July. The only action required from you is ensuring your product data is correct — particularly the Manufacturer Product ID and barcode fields ahead of the November deadline.
What happens if my product identifier data is missing or incomplete from November?
Declarations missing required identifiers risk being rejected or delayed at EU customs — meaning shipments held at the border, storage fees, delayed delivery, and potential fines. Swap cannot guarantee clearance for shipments where required identifiers are absent.
My products are own-brand. What is my Manufacturer Product ID?
Use the same code as your SKU. For own-brand manufacturers, the Merchant Product ID and Manufacturer Product ID are the same thing.
My products don’t have barcodes. Do I need to get a GTIN?
No. The Standardised Product ID is only required “where available.” If your products genuinely have no barcodes, leave the field blank. You don’t need to register with GS1 for compliance purposes, though it’s good practice if you plan to scale EU retail distribution.
Is IOSS still relevant after this change?
Yes. IOSS (Import One Stop Scheme) handles VAT reporting and collection for EU orders under €150 and remains in place. The de minimis removal affects customs duty, not VAT — your IOSS setup is unchanged.
What’s the difference between the €3 duty and the €2 handling fee?
The €3 flat duty applies from 1 July 2026 and is a customs duty charge per HS code on sub-€150 orders. The €2 handling fee is a separate EU charge covering customs processing, which takes effect in November 2026. From November, both apply — bringing the combined per-line charge to €5.