EU De Minimis Changes and New Requirements for Shipping to the EU

Please read below for important updates regarding EU customs changes, including the confirmed changes to de minimis treatment from 1st July 2026, as well as additional data requirements expected from November 2026.

1. EU De Minimis Changes – Effective 1st July 2026:

From 1st July 2026, changes to the EU’s de minimis framework for low value imports will come into effect. These changes form part of the EU’s broader customs reform programme and are designed to address the significant rise in low value e-commerce shipments entering the region.

As a result, there is increased scrutiny and intervention on shipments previously considered low value, with new duty mechanisms now being phased in ahead of the full removal of reliefs under the wider reform package.

As a recap, the changes are as follows:

  • The current €150 duty-free threshold will be removed, meaning all shipments will become subject to customs duty.
  • This will be applied through a ‘temporary’ charge of EUR 3 per customs line until further notice, NOT via a traditional ad valorem tariff-based calculation method.
    • This €3 model is a temporary simplified duty mechanism ahead of the EU’s wider customs reform, which will ultimately move all goods to standard ad valorem tariff-based duty calculation methodology.
  • A customs line is defined by:
    • HS Code (at 6-digit level) combined with Country of Origin
    • Any change = additional EUR 3 charge
  • Inconsistent use of HS codes or country of origin across similar products may unintentionally increase the number of customs lines and therefore the duty applied.
  • This duty will be charged to the payor of duty and taxes under the INCOTERMS of the shipment. For example – for Delivery Duty Paid (DDP) shipments, this will be billed back to the shipper and for Delivery at Place (DDU) shipments, the recipient will be responsible for the charges.

EXAMPLE: We have provided the below example which we hope is helpful in illustrating how duty charges will be applied from 1st July:

ScenarioDuty
1 item€3
3 items, 3 different HS codes€9
2 items, same HS code, different origin€6
3 items, same HS code, same origin€3

We have also put together a simple EU de minimis cost calculator to work out your new shipping costs after July 1st.  You can find the calculator on our website here.

As above, this means that basket composition now directly drives duty cost, rather than order value alone.

Other FAQ’s

  • Does this change how VAT is collected?
    • VAT treatment remains unchanged. Where applicable, VAT will continue to be applied either via IOSS at checkout or collected at import depending on the shipping model.
  • What about shipments that are subsequently returned?
    • Further clarification is still awaited on the treatment of returned goods and whether duties applied per shipment will be recoverable, but it is currently anticipated that these charges will not be recoverable by the payee.
  • Will carriers increase costs for administering these changes?
    • At this stage we have not been made aware of any specific changes to accessorial, deferment or arrangement fees but given there is an additional administrative burden we cannot rule these out. Should we be made aware of any changes by our carriers we will advise you accordingly.
  • Will this apply to all EU countries?
    • Yes, this is an EU-wide measure and will apply across all EU member states, although local handling practices and fees may vary by country and carrier.
  • Will this apply to IOSS shipments?
    • Yes. The €3 duty mechanism applies regardless of whether IOSS is used. IOSS will continue to govern VAT collection only and does not remove the requirement to pay customs duty.
  • Will this impact delivery times?
    • While no formal delays have been announced, increased data requirements and customs scrutiny may lead to longer clearance times, particularly in the early stages of implementation. Our teams will monitor this closely and advise you of any impact should this occur.
  • Are there any product categories exempt?
    • No general exemptions have been confirmed under the €3 simplified duty model. All goods will be subject to duty based on customs line definition, unless specific regulatory exemptions apply.

2. New Mandatory Data Requirements – Effective November 2026

The EU has also confirmed that enhanced shipment level data will be required from November 2026 for all applicable exports into the EU.

At a minimum, this will include:

  • SKU level detail
  • Product ID
  • Barcode (such as EAN or UPC where applicable)

These requirements are being introduced to improve customs visibility, product traceability, and compliance monitoring across EU member states.

At this stage, we are still awaiting detailed guidance from our carrier partners regarding:

  • The exact format and structure of this data
  • How the information must be transmitted within shipping systems
  • Whether this will be required at label generation, manifest level, or via separate data submission

We are actively engaged with our carrier network to understand these requirements and we will provide further guidance, including any required system or process changes, as soon as this becomes available. ILG will support clients in mapping, validating and transmitting this data once carrier requirements are confirmed, including guidance on any system or integration changes required.

3. Previously Confirmed Measures (Reminder)

By way of recap, the following measures shared in our previous update remain in effect or on track:

  • National regulatory fees in Italy and Romania on low value imports
  • Potential EU handling fee still under discussion for implementation from November 2026
  • EUDR compliance deadlines from December 2026
  • VAT and reporting changes introduced from January 2026

4. What You Should Do Now

  • Review your product master data: Ensure HS codes, country of origin and product descriptions are accurate and consistent, as errors will now directly impact cost
  • Assess your SKU complexity: Higher SKU variation across HS codes or origins will increase duty exposure under the per customs line model
  • Prepare for additional data requirements: Begin reviewing whether you hold SKU, Product ID and Barcode data in a structured format that can be shared at shipment level
  • Review your Incoterms strategy: Confirm whether you are comfortable with duties being charged to your customers (DAP) or retained by you (DDP), particularly as costs increase
  • Model cost impact: We recommend reviewing landed cost per order under the new €3 per customs line structure to understand margin impact
  • Consider localised fulfilment: For many businesses, holding stock within the EU may remove per-shipment duty exposure entirely and improve cost predictability

For many non EU brands, this is accelerating the need to reassess fulfilment strategies, particularly the cost and operational impact of shipping orders cross border versus holding stock within the EU.

5. Support from ILG – Ready to explore localised fulfilment within the EU?

ILG are already helping dozens of non‑EU brands overcome the operational challenges caused by importing into the EU and operate a bespoke and highly sustainable 450,000 sq. ft. fulfilment unit that opened in 2024. Strategically located in Western Poland at the heart of the EU, our facility is close to the German border (Europe’s largest e‑commerce market), within easy reach of Leipzig’s major carrier hubs, and positioned near the main rail freight connection to China. Poland’s labour rates and operating costs remain significantly lower than in most other EU countries, and with excellent road transport links and a highly skilled workforce, the region continues to attract substantial investment and expand its logistics capacity.

If you would like to discuss the impact of these changes on your business, or explore alternative fulfilment models, please contact your usual ILG representative.

Both ILG and the wider group continue to monitor the situation closely and we are working to keep our clients informed.