Handling Fee of EUR 2 per Item: The First Effect of the New Union Customs Code
From November, every item sold at a distance from a third country will carry an additional two euros per item, regardless of the value of the consignment and without any right to a refund. Anyone who has not agreed with their representative or platform on who bears it will find out only from the invoice.
The Union handling fee of EUR 2 per item will start to apply on the tenth day after the entry into force of the Commission Delegated Regulation of 21 September 2026. Given the expected publication in the Official Journal, this works out at 1 November 2026. The fee is introduced by Article 20 of Regulation (EU) 2026/2108 of the European Parliament and of the Council establishing the Union Customs Code and the European Union Customs Authority. It applies to all goods sold at a distance and released for free circulation, i.e. including consignments above EUR 150.
What counts is the item, not the parcel or the piece. An item consists of goods in a consignment with the same tariff classification and description and, where origin is stated in the customs declaration, the same origin (Article 5(78)). The customs administration’s systems charge both duty and the fee for each line of the customs declaration. The following calculation shows what this looks like for a typical order from China:
|
Items |
Flat-rate duty | Fee | STotal before VAT | |
|
Small item for EUR 4 |
1 | 3 € | 2 € | 5 € |
|
Three identical T-shirts for EUR 20 |
1 |
3 € |
2 € |
5 € |
|
T-shirt, cable and phone case for EUR 15 |
3 |
9 € |
6 € |
15 € |
|
Two different products for EUR 200 |
2 |
standard rate |
4 € |
duty at the applicable rate + EUR 4 |
Classification thus becomes a cost, and the type of declaration also matters. The simplified declaration for consignments of up to EUR 150 (H7) works with a six-digit HS code and no origin, whereas the standard customs declaration (H1) uses a ten-digit TARIC code and origin. Three different women’s suits therefore constitute one item in an H7 declaration but three in an H1. Incorrectly merged lines, however, open the door to a post-clearance assessment.
The fee is non-refundable (Article 20(6)) and arises as soon as the customs declaration is accepted. It is owed even if the customs office does not release the goods or the declaration is invalidated. For clothing with high return rates, this is a permanent loss on every returned piece, which must be factored into both margins and return conditions.
The fee is paid by the debtor of the import customs debt, at least once a month (Article 20(5)). Until 30 June 2028, the customs declaration is lodged primarily by the IOSS holder, otherwise by the user of the special arrangements or by an indirect customs representative. In the case of indirect representation, the person on whose behalf the representative acts is also a debtor. The customer becomes the declarant, and thus the debtor, only exceptionally: where IOSS was not used and the Member State allows free electronic lodging.
This leads to three contractual questions between the seller and the representative: who bears the fee and within what period it is re-invoiced; who is responsible for the data on which the number of items depends; and who compensates for the loss if the customs office assesses additional duty and fees. Moreover, the fee is secured in the same way as a customs debt, so the reference amount of the representative’s comprehensive guarantee must also cover its monthly volume. At ten thousand items per month, that amounts to EUR 20,000 for the fee alone; without an advance payment from the seller, the representative bears the client’s credit risk.
The fee also increases VAT. According to the Commission guidance of 5 October 2026, it is an incidental expense relating to the supply and forms part of the taxable amount. Outside IOSS, VAT on the fee is paid on import; in Slovakia, at a rate of 23 per cent, an item comes to EUR 2.46, and this VAT is refunded if the goods are returned. Under IOSS, no import VAT is paid, but if the seller charges the fee to the customer, it includes it in the taxable amount in its monthly IOSS return.
Bulk import helps only if the goods are released for free circulation before they are sold. A customs warehouse alone is not enough: goods sold before being stored are subject to both duty and the fee, and the Commission is amending the delegated rules so that this also applies to sales during storage. The customs office may treat a bulk consignment assembled from individual orders as a set of distance sales.
From 1 November 2026, the declarant – in practice the IOSS holder or the indirect customs representative – will therefore pay EUR 2 for each item of goods sold at a distance, at least once a month and without any right to a refund, and will state TARIC code Y126 in the customs declaration. By that date, the seller and the representative must set up classification, prices, return conditions, the guarantee and contractual re-invoicing. The rules on customs debt apply mutatis mutandis to the fee (second subparagraph of Article 20(5)), so an unpaid fee is recovered in the same way as a customs debt.
If you would like to calculate what the fee means for your product range and import model, we will be happy to assess your situation.