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The new EU customs code (Regulation 2026/2108): what changes for sellers, and when
Short answer: Regulation (EU) 2026/2108 replaces the Union Customs Code. It was signed on 16 September 2026, published in the Official Journal on 19 September 2026 and is in force. Most rules apply from 21 September 2027. Three things reach sellers who ship to EU consumers earlier: a per-item Union handling fee (once a delegated act sets the amount; Parliament says at the latest 1 November 2026), the "importer for distance sales" role, and the EU Customs Data Hub for e-commerce from 1 July 2028. The product identifier deadline of 1 November 2026 comes from a different act (Regulation 2026/1022) and does not change.
Timeline for a store shipping parcels to EU consumers
| Date | What | Basis |
|---|---|---|
| 1 July 2026 | The €150 duty relief ended; a temporary €3 duty per item applies to consumer consignments up to €150 (planned until 1 July 2028 unless extended). Product identifiers may be declared voluntarily. | Reg. (EU) 2026/382; Reg. (EU) 2026/1022; Commission guidance §3.5.2 |
| 1 November 2026 | Product identifiers become mandatory on declarations for distance sales of imported goods. Parliament says the Union handling fee will be collected at the latest from this date, once the delegated act setting the amount is in force. | Reg. 2026/1022, Article 2; Reg. 2026/2108, Articles 20 and 287(4); EP press release 16 Sep 2026 |
| 21 September 2027 | Regulation 2026/2108 applies in general. | Article 287(2) |
| 1 July 2028 | Data Hub obligations for importers for distance sales apply (Articles 41–45, 74–75, 145). The temporary €3 duty is due to end and normal duty rates apply. | Article 287(5); guidance §2.1 |
| 2031–2034 (planned) | Data Hub for all other trade; the declarant role ends for all operators. | Commission and Parliament summaries |
What the new code says, in its own words
- Importer for distance sales. Article 5(14) defines it as "either the person supplying goods in distance sales or the person facilitating distance sales". Parliament's summary: sellers and platforms sending goods from non-EU countries directly to EU customers will be treated as importers — responsible for the data, for paying or guaranteeing charges, and for the goods' compliance with EU law. A law-firm analysis (Baker McKenzie, 21 September 2026) notes the final text contains no safe-harbour for platforms.
- Union handling fee. Article 20(2): customs authorities collect "a Union handling fee of a fixed amount per item" for goods sold in distance sales; Article 20(3) ties the amount to the cost of checking data, risk analysis and controls. The amount is set by a Commission delegated act and the fee applies ten days after that act enters into force (Article 287(4)). The recitals make the importer for distance sales — or, until those rules apply, the declarant — the debtor, not the consumer. FedEx's UK customs page lists the fee as expected from 1 November 2026 at €2 per declaration line; treat that as a carrier's estimate until the Commission publishes the amount.
- EU Customs Data Hub. From 1 July 2028, importers "provide or make available, in the EU Customs Data Hub, the data necessary for the placement of the goods under the customs procedure" (Article 74). For distance sales the Hub becomes the channel instead of a declaration lodged by a declarant.
- Product identifiers are not in this act. The words "product identifier" do not appear in Regulation 2026/2108. The requirement lives in the customs delegated act (Regulation 2015/2446 as amended by Regulation 2026/1022): voluntary from 1 July 2026, mandatory from 1 November 2026. The Commission's guidance calls it "a first step" towards fuller product data once the Data Hub is deployed.
What to do now
- Treat 1 November 2026 as fixed: every variant shipped to EU consumers needs its SKU, the maker's code and, where one exists, the barcode. Check what your Shopify export already holds — free.
- Budget per declaration line, not per parcel: the €3 duty (until July 2028) plus the handling fee once set. A basket with three different items is three lines.
- Ask your carrier who is billed for the handling fee under your DDP or DAP setup, and whether the €3 duty is being collected at checkout or on delivery.
- Keep product data — identifiers, HS code, country of origin, value — clean and exportable. From 2028 it goes to the Data Hub straight from your systems, and the identifiers required from November are the first piece of it.
Questions
Does the new customs code move the 1 November 2026 product identifier date?
No. That date is set by Regulation (EU) 2026/1022, whose Annex points (2)(a) and (b) apply from 1 November 2026. Regulation 2026/2108 does not mention product identifiers.
How much is the Union handling fee and who pays it?
The amount is not published yet. It will be set in a Commission delegated act and the fee applies ten days after that act enters into force. The debtor is the importer for distance sales, or the declarant until those rules apply — not the consumer. FedEx lists an expected €2 per declaration line from 1 November 2026; that is a carrier estimate, not the regulation.
Do I have to use the EU Customs Data Hub now?
No. The Data Hub provisions for importers for distance sales apply from 1 July 2028. What carries over is clean product data, starting with the three product identifiers required from November 2026.
I sell through my own Shopify store from outside the EU — am I an importer for distance sales?
Under Article 5(14) the person supplying goods in distance sales is an importer for distance sales; the person facilitating them (a marketplace or platform) can be one too. Which obligations apply to you and from when depends on the phased dates above; ask your customs representative before relying on any single reading.