The EU €3 customs duty is charged per declaration line, not per article and not simply per HS code. That distinction decides what a non-EU seller actually pays on each parcel.
Since 1 July 2026, every low-value parcel sold to EU consumers through IOSS or by post carries a flat €3 customs duty. Three months in, sellers still read three different versions online: €3 per article, €3 per HS code, €3 per parcel. None of them is quite right, and the gap shows up on your landed cost, your returns and your checkout price.
What the law actually says
The regulation says “per item”, and “item” is a defined customs term, not the everyday word for a product.
Article 2 of Council Regulation (EU) 2026/382 applies a €3 duty per item in any consignment whose total intrinsic value does not exceed €150, from 1 July 2026 to 1 July 2028. It covers two cases: goods whose import VAT is collected through IOSS, and goods in postal consignments as defined in Article 1(24) of the UCC Delegated Act.
Article 1(61) of the UCC Delegated Act (Regulation (EU) 2015/2446) defines an item as one or more goods in a consignment sharing the same tariff classification, the same description and, where the declaration requires it, the same origin. The usual option to group different goods under the highest duty rate (Article 228(1) UCC Implementing Act) is switched off for the €3 duty.
The Commission’s guidance of 2 June 2026 draws the practical consequence. Because of IT constraints, the duty applies per declaration line, whatever the quantity on that line, as long as the whole consignment stays within €150. Ten identical phone cases on one line cost €3. Three different products on three lines cost €9.
Same parcel, different bill
The same parcel can cost €3 or €9 depending on the type of customs declaration filed. This example comes straight from the Commission guidance.
A consignment worth €140, made in China, VAT collected through IOSS, contains three knitted women’s suits: one in artificial fibre, one in wool, one in another material.
| Goods in the parcel | H7 low-value e-commerce · 6-digit HS |
H6 postal · 8-digit CN |
H1 standard · 10-digit TARIC |
|---|---|---|---|
| Suit, artificial fibre | 6104 19 line 1 | 6104 19 90 line 1 | 6104 19 90 10 line 1 |
| Suit, wool | 6104 19 line 1 | 6104 19 90 line 1 | 6104 19 90 20 line 2 |
| Suit, other material | 6104 19 line 1 | 6104 19 90 line 1 | 6104 19 90 90 line 3 |
| Declaration lines | 1 | 1 | 3 |
| €3 duty due | €3 | €3 | €9 |
| With the €2 handling fee, if counted per line (expected from November) | €5 | €5 | €15 |
Consignment of €140, made in China, VAT collected through IOSS. Source: European Commission guidance of 2 June 2026.
The H1 declaration splits the suits into three TARIC codes, so it carries three lines and three duties. Origin also splits lines: the guidance shows identical bicycle parts declared on two lines because some come from China and some from Thailand.
The practical lesson: the duty you collect at checkout depends on who files the declaration, in which dataset, and with which product data. If your broker or carrier switches from H7 to H1, or classifies more precisely than your pricing engine assumes, your margin moves.
On top: the €2 Union handling fee
From November 2026, a second charge is expected to stack on the €3 duty: a Union handling fee of €2 per item. It is adopted, but not yet in force.
The new Union Customs Code, Regulation (EU) 2026/2108 published on 19 September 2026, creates the fee. On 21 September 2026, the Commission adopted the delegated act setting it at €2, C(2026) 6694. Parliament and Council now have a scrutiny period to object, reported at 30 days and ending around 21 October.
The act enters into force on publication in the Official Journal and applies ten days later. Publication around 22 October would mean application on 1 November 2026. As of 5 October, it has not been published, and any slip in the scrutiny or publication moves the start date.
Two differences with the €3 duty matter for pricing:
- It is a cost-recovery fee for customs services, not a customs duty, and it has no value threshold: parcels above €150 pay it too.
- It has no end date, while the €3 duty stops on 1 July 2028.
On the knitted-suits parcel above, if the fee follows the same per-line count as the duty, the bill becomes €5 when filed as H7 and €15 when filed as H1. That is up to 11% of the €140 goods value, against nothing before July. Whether “item” counts the same way for the fee as for the duty is not yet settled: check the published text before building it into your checkout.
Returns: harder to recover, not always lost
The €3 is often described as non-refundable. That is too short.
Amended Article 148(3) of the UCC Delegated Act removes the easy route: you can no longer ask customs to invalidate the declaration when a low-value distance-sale parcel comes back after release. The Commission guidance adds that the general refund rules of Article 116 of the Union Customs Code still apply.
In practice, recovering €3 per line case by case rarely pays for itself. For high-return categories such as fashion, the duty should be priced into the return cost from the start, not treated as recoverable.
Who owes the duty
The declarant owes the €3, and for IOSS sales the declarant is the IOSS holder or its indirect customs representative, not the consumer.
The amended Annex B of the UCC Delegated Act sets a cascade. First the IOSS holder, then the user of the special arrangements, then an indirect representative of the importer. The consumer comes last, and only in Member States offering a free online declaration tool.
A non-EU IOSS holder cannot declare in its own name. It must appoint an EU indirect customs representative, who becomes the main debtor under Article 77(3) UCC, with the seller as co-debtor. That representative will also need a comprehensive guarantee sized to the expected duty. If your IOSS intermediary handles VAT only, check who signs your customs declarations and who carries that guarantee.
One more point: with IOSS, the declaration can be lodged in any Member State. Without IOSS, it must be lodged in the Member State where the parcel is delivered.
Next deadline: 1 November 2026
From 1 November 2026, product identifiers become mandatory on every distance-sale import declaration, and customs can sanction missing or wrong data. It is also the target date for the €2 handling fee, subject to its publication.
Each line must carry a merchant product identifier (document code C127) and a manufacturer identifier (C128), plus the EAN or UPC where one exists (C129, or Y081 if none). Reporting identifiers at batch or unit level when a model-level one exists counts as an infringement. Since 1 October 2026, the Commission also checks every month whether sellers are moving away from IOSS to avoid the duty; if so, it may propose extending the €3 to every consignment up to €150.
Four weeks before the deadline, check:
- Which declaration type (H1, H6, H7) your broker or carrier files, and how many lines your typical basket generates
- Whether your checkout calculation matches that line count, including the €2 handling fee expected from November
- Who acts as your indirect customs representative, and who holds the guarantee
- That your catalogue holds a merchant ID, a manufacturer ID and an EAN for every SKU shipped to the EU
- How the €3 enters your return cost per category
CB Consulting & Management is an independent operational tax and customs consulting firm, with 22 years of hands-on experience in EU VAT and customs. If these questions are open in your business, book a call and get one focal point for both.
Sources: Council Regulation (EU) 2026/382 of 11 February 2026, Article 2 and review clause; European Commission, DG TAXUD, “The EUR 3 temporary customs duty – Guidance for Member States and Trade”, version of 2 June 2026 (explanatory, not legally binding); Commission Delegated Regulation (EU) 2015/2446 (UCC-DA), Articles 1(61) and 148(3), as amended; Commission Implementing Regulation (EU) 2015/2447 (UCC-IA), Article 228(1), as amended by Implementing Regulation (EU) 2026/1200; Regulation (EU) No 952/2013 (Union Customs Code), Articles 77(3) and 116; Regulation (EU) 2026/2108, OJ of 19 September 2026; Commission Delegated Regulation C(2026) 6694 of 21 September 2026, adopted, not yet published at the date of this article; European Commission, EU Customs Reform.