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Does the EU product identifier rule apply to my store?

Short answer: It applies if you sell goods at a distance to consumers in the EU and the goods are imported from outside the EU. Business-to-business shipments and goods already inside the EU are generally outside it. Marketplaces may handle it for their own listings; your own store is on you.

Five questions

  1. Do the goods enter the EU from outside? Shipping from Thailand, the US, the UK, China or any non-EU country to an EU address: yes. Fulfilled from an EU warehouse: the import happened earlier, usually in bulk; the parcel itself is not an import.
  2. Is the buyer a consumer? Private individuals: yes. VAT-registered businesses buying for their business: generally no; confirm with your customs representative.
  3. Is it a distance sale? Online, phone or mail order with delivery: yes.
  4. Who declares? Your carrier or its broker does, but only with the data you give them. If you cannot supply the three identifiers, they cannot declare correctly.
  5. Marketplace or own store? Large marketplaces collect identifiers for their listings. Your Shopify, WooCommerce or Etsy-standalone store: you collect them.

Common edge cases

The Commission's guidance lists specific exceptions (section 3.5.7). This page is a screening aid, not legal advice; when in doubt ask the carrier or a customs broker before 1 November 2026.

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Questions

I sell from Thailand to Germany through my own Shopify store — in scope?

Yes, if the buyers are consumers and the parcels are imported into the EU from Thailand. Prepare the three identifiers per variant.

My EU 3PL ships my goods — in scope?

The consumer parcel is then a domestic shipment. The import happened when your stock entered the EU, under a different declaration. Check with the 3PL what they declared.

Do I need a customs broker?

Express carriers act as declarant by default. A broker matters when you ship freight or want DDP handling; either way they need the identifiers from you.