US sellers shipping to consumers in the European Union now have to declare product identifiers for each item: your own product code (a SKU), the manufacturer's product code, and a standard barcode number such as a GTIN or EAN where one exists. The European Commission made these identifiers mandatory on November 1, 2026, on top of the flat EUR 3 customs duty per item that replaced the EUR 150 duty exemption on July 1, 2026. A EUR 2 handling fee per item was expected to start on the same November date; as of its October 15, 2026 update, DHL Express still described the EUR 2 amount as proposed. If your commercial invoice already carries a clear description, value, HS code and country of origin per item, adding the identifiers is a data job, not a new process.

What changed for EU-bound parcels in 2026?

Two things changed: low-value parcels lost their duty exemption on July 1, 2026, and since November 1, 2026 they need product identifiers, and a EUR 2 handling fee was expected to start that day (DHL Express, as of October 15, 2026). Before July 2026, goods in a consignment worth EUR 150 or less entered the EU without customs duty, though import VAT still applied. Our de minimis explainer covers how that threshold worked and how other countries handle theirs.

Date	What applies	Source
July 1, 2026	EUR 150 duty exemption removed; flat EUR 3 customs duty per item on consignments up to EUR 150; product identifiers accepted on a voluntary basis	European Commission
November 1, 2026	Product identifiers mandatory for distance sales of goods up to EUR 150	European Commission
November 1, 2026	Union handling fee of EUR 2 per item expected to start, at any value (amount described as proposed by DHL Express)	Commission guidance, DHL Express
July 1, 2028	EUR 3 flat duty ends; normal duty rates by type of good apply	European Commission

According to the European Commission's June 8, 2026 announcement, the EUR 3 duty is temporary and applies until July 1, 2028, when an EU customs data hub for e-commerce is due to start. After that date, goods pay the normal rate for their tariff classification.

What are EU product identifiers?

EU product identifiers, or PIDs, are three codes that let customs tell exactly which product is inside a parcel and who made it. The Commission says their purpose is to help customs detect and block unsafe or non-compliant goods.

Merchant product identifier (M-PID). The code you use to sell the product, usually your SKU. On a marketplace, the Commission's guidance says this is the identifier the platform uses to offer the product.
Non-standardized manufacturer product identifier (NS-PID). The manufacturer's or supplier's own code, such as a model or part number.
Standardized product identifier (S-PID). A code issued under a standard, such as a UPC, EAN, GTIN or ISBN.

The Commission's guidance for traders, version of October 5, 2026, sets the minimum as the merchant and manufacturer codes, with the standardized code added wherever one exists. It also warns that reporting identifiers at batch or unit level, when a model-level code exists, counts as an infringement. In plain terms: one code per product model, used the same way on every shipment.

Which shipments need product identifiers?

Business-to-consumer sales shipped into the EU need product identifiers; business-to-business shipments, documents and personal gifts between individuals do not. That split is how the Pirate Ship support article on product identifiers summarizes the rule as of November 2, 2026.

On value, the sources differ. The Commission's guidance says the requirement covers goods sold in distance sales with an intrinsic value up to EUR 150, and notes that the legal annex is being amended to make that limit explicit. Pirate Ship's article says identifiers are required on EU B2C shipments regardless of value. Because carrier and software checks may ask for identifiers on every consumer order, the practical answer is to have them ready for every EU consumer shipment.

Two notes for small makers. Pirate Ship says you do not need a manufacturer code for products you make yourself, and that you can create your own SKUs if you have none, as long as you reuse the same one each time you ship that product. The Commission's guidance also lists an administrative tolerance for certain hand-made and artisanal commodity codes and for unprocessed agricultural goods, which can be declared with a conventional identifier. Check your own HS code against that list before you rely on it.

How do the EUR 3 duty and the EUR 2 handling fee add up?

Both charges are counted per item, and an item is the group of goods in a parcel that share the same tariff classification, description and origin, not each unit. The Commission's own example: five T-shirts are one item and pay EUR 3, while one T-shirt and one watch are two items and pay EUR 6.

The handling fee works on the same item count but ignores value. The Commission's guidance says it also applies to consignments above EUR 150 when the goods were sold in a distance sale, and that it is non-refundable. The DHL Express customs regulatory updates page adds two points as of its October 15, 2026 update: DHL Express bills the fee to whoever pays import duties and taxes under the duty billing option chosen at shipment creation, and the fee is part of the taxable amount for import VAT, so it raises the VAT too.

Example (hypothetical numbers): an Etsy-style seller ships an order worth EUR 60 to a consumer in Germany: three identical scented candles and one ceramic mug.

Line on the invoice (example)	Items counted	EUR 3 duty	EUR 2 handling fee
Scented candle, qty 3, same description and origin	1	EUR 3	EUR 2
Ceramic mug, qty 1	1	EUR 3	EUR 2
Total before VAT	2	EUR 6	EUR 4

That is EUR 10 in duty and fees before import VAT, on a EUR 60 order. Splitting the candles into three invoice lines with slightly different descriptions would raise the item count, and the duty and fee with it, and could look like an attempt to blur the data. Listing a mixed bundle as one vague line ("gifts") is the more common mistake, and it cannot carry one product identifier per model. For the German side of the trip, see our guide to shipping to Germany from the US.

What should go on the commercial invoice for an EU order?

Each line of the commercial invoice should describe one product model with its value, HS code, origin and identifiers, and the lines should match what is physically in the box. Our customs forms guide for small parcels covers the basics; this checklist adds what changed in 2026.

One line per product model. Group identical units into one line with a quantity.
A specific description. "Soy wax candle, 8 oz jar", not "home goods". The description is part of how customs defines an item.
Declared value per line. The actual sale price in the order currency.
HS code. At least the 6-digit subheading. The code drives the item count for the duty and the fee.
Country of origin. Where the goods were made, not where they ship from.
Merchant product identifier. Your SKU, the same one every time.
Manufacturer product identifier. The maker's model or part number, or your own code for products you make.
Standardized identifier where it exists. The UPC, EAN, GTIN or ISBN from the packaging.
Reason for export. Sale, gift, sample or return, stated honestly.

Keep a product sheet with columns for SKU, manufacturer code, barcode, HS code and origin, filled once per product.

Should you ship DDU or DDP to the EU now?

DDP, where you prepay duties and taxes, gives the buyer no surprise charge at the door, which matters more now that every consumer parcel carries duty and a fee. With DDU, the buyer pays on delivery, and some buyers refuse the parcel rather than pay.

The choice also interacts with VAT collection at checkout. If a marketplace collects EU VAT under its IOSS registration, that data has to reach customs or the buyer may be charged again. Our EU shipping guide walks through the three IOSS routes and how to make the declaration match each one.

A simple rule: if your EU orders are steady and mostly low-value, price the EUR 3 per item and the EUR 2 handling fee into your EU shipping charge and ship DDP. If EU orders are occasional, DDU can still work, but say clearly at checkout that the buyer may pay duty, VAT and fees on delivery.

Where GoatLabels fits

GoatLabels generates a printable commercial invoice for every international shipment. You choose DDU or DDP, and DDP needs each item's declared value, HS code and country of origin; the customs reason for export, including gift, prints on the invoice. USPS, UPS and FedEx are rate-shopped on every domestic parcel, and DHL joins on international lanes. Free covers 50 shipments a month, Pro is a flat $40 a month with unlimited shipments, and label prices are the same on the Free and Pro plans; details are on the pricing page.

The limit that matters here: GoatLabels builds the invoice from the item data you enter, so it cannot supply an HS code or a country of origin you do not have. Before you ship EU consumer orders, check where your label tool carries product identifiers for customs. Getting those right, and pricing the EU duty and fee into your checkout, stays with you.