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Can my SKU be both the merchant and the manufacturer identifier?
Short answer: Only if you made the product (or it is made for you and sold under your name or trademark). Then your own model reference can serve as both merchant code and manufacturer code. If you resell someone else's product, the manufacturer code must be theirs.
The two roles
The guidance assigns the merchant identifier to the "online seller, marketplace or platform" and the manufacturer identifier to the "manufacturer, producer or product supplier". A brand that has goods made under its own name or trademark counts as manufacturer under the Union Customs Code definition (48)(c), so it may hold both roles and use one reference for both fields, provided the reference identifies exactly one variant.
Rules that still apply
- Uniqueness: one identifier per variant (size, colour, packaging). A reference that covers several variants is not a valid PID.
- Persistence: keep the reference unchanged over the product's life.
- Do not report batch- or unit-level codes when a model-level code exists; the guidance treats that as infringing.
Reseller example
You sell a supplier's water bottle under your SKU WB-500-BLU. Merchant code: WB-500-BLU. Manufacturer code: the supplier's model (e.g. HX500-BL). Barcode: the bottle's GTIN if it has one.
Why a carrier page can mislead here
DHL Express UK describes the non-standardised manufacturer identifier as "yours / the manufacturer's internal product identifier, such as a SKU" (page read 22 September 2026). The regulation itself defines it as a product identifier "assigned by a manufacturer, producer or product supplier" (Regulation (EU) 2026/1022, Article 1, point (59)) and the merchant identifier as one "assigned by an online seller, marketplace or platform" (point (58)). For goods you resell, those are two parties and two codes. When a carrier's form offers one box, put the maker's code there and keep your SKU in the merchant field.
Questions
We white-label a factory product under our brand — are we the manufacturer?
Under definition (48)(c), a person who has the product manufactured and markets it under their own name or trademark is treated as the manufacturer. Your model reference can then be the manufacturer code; keep evidence of the arrangement.
Does the checker flag identical values?
It shows what you mapped and notes that your SKU is being used as the merchant code; it does not decide whether you are the manufacturer.
My carrier's page says the manufacturer identifier can be my SKU — is that enough?
Only if you are the manufacturer. The regulation assigns the manufacturer identifier to the manufacturer, producer or supplier; a reseller's SKU is the merchant identifier. Carrier summaries simplify; the declaration follows the regulation.