Updated 13 October 2026. Both changes covered here are live. The EU’s temporary €3 customs duty has applied since 1 July 2026, and the Commission has confirmed a €2 Union handling fee from 1 November 2026. In France, non-EU importers can no longer use a one-off fiscal representative under Regime 42.
Most coverage of the EU de minimis change fixed on one number, the flat duty on low-value parcels. The bigger shift sits underneath it. With the €150 duty relief gone, every low-value consignment now owes customs duty, so every one needs a declarant who can lodge the declaration and pay or secure that duty. If nobody is in that seat, the goods cannot be released.
That turns the EU de minimis importer of record question from a billing detail into a condition of the goods moving at all. This guide is for non-EU sellers, marketplaces and logistics teams shipping into the EU, and especially UK businesses that used France as a gateway. If you need someone to carry the import, see our importer of record services.
At a Glance
- Since 1 July 2026 the €150 customs duty relief has gone, and a temporary €3 duty applies per item on distance sales up to €150, until 1 July 2028.
- A €2 Union handling fee per item applies from 1 November 2026.
- The rules set an order of who can act as declarant, starting with the IOSS user or its indirect representative.
- Goods are released only once the duty is paid or covered by a guarantee. Without a declarant who can do that, a parcel can be held or sent back.
- In France, a non-EU importer using Regime 42 now needs its own French VAT number, generally through a fiscal representative.
What Actually Changed on 1 July 2026
Council Regulation (EU) 2026/382 removed the €150 customs duty relief. For distance sales of goods up to €150 in intrinsic value, a temporary €3 duty applies from 1 July 2026 to 1 July 2028, whatever VAT scheme the seller uses. Our guide to the EU de minimis changes from July 2026 covers the duty mechanics.
The €3 is charged per item, and an item means goods sharing the same tariff classification and description. As the European Commission puts it, five T-shirts are one item, while three T-shirts and a watch are two, so €6. From 1 November 2026 a €2 Union handling fee per item comes on top, and unlike the duty it is not temporary.
The declarant order nobody talks about
The Commission’s guidance sets out who can act as declarant until 30 June 2028, in order.
- The person using IOSS, usually the seller or marketplace, or its indirect representative
- The user of the special arrangements for import VAT, or its indirect representative
- The importer’s indirect representative
- Any other person able to provide the required data, a residual option only where a member state offers a free online declaration for individuals and IOSS is not used
The declarant is the debtor for the duty and the handling fee, and goods are released only once the debt is paid or guaranteed. So the question is not only “how much do we owe?” It is “who is on the declaration and able to pay?” If you ship with nobody arranged, the parcel waits for someone to step in, or the carrier sends it back.
Take a €120 order to a consumer in Germany. Before 1 July it came in duty free. Now it owes the €3 per item and needs a declarant. Shipped Delivered At Place with nothing arranged, the risk is not a few euro. It is a held or returned parcel, a lost sale and an unhappy customer.
Who Carries the Import, You or Your Customer
Every consignment now needs a party accountable for the entry, the data and the duty. In substance that is an importer of record. If the role is new to you, our explainer on what an importer of record is and does sets it out.
A non-EU seller has two choices. Ship Delivered At Place and the buyer pays on arrival, which moves the liability but brings surprise charges, refusals and returns. Or ship Delivered Duty Paid, where you or your appointed importer of record handle duty and clearance first and the customer gets a clean delivery. Our comparison of DDP and DAP goes further.
| Since 1 July 2026 | Delivered Duty Paid (DDP) | Delivered At Place (DAP) |
|---|---|---|
| Who carries the import | You or your appointed importer of record | Your customer |
| Who pays duty and fees | You, built into the price | The customer, on arrival |
| Customer experience | Clean delivery, no surprise charges | Bill at the door, refusals |
| Risk if no declarant is arranged | Covered by your declarant | Parcel held or returned |
Not sure who your EU declarant is? Without one able to pay or secure the duty, your goods cannot be released. Carra Globe arranges the import through our own structure or an established EU partner acting as indirect representative, depending on the goods and the destination. Talk to us about your EU lanes.
The France Trap: Why the Old Gateway Closed for Non-EU Sellers
For years, UK and other non-EU businesses used France as a way in. Under Regime 42, goods clear into France VAT free and move straight on to another member state as an exempt intra-EU supply. Many non-EU sellers did this without their own French VAT number, using a forwarder’s number as a one-off fiscal representative.
That shortcut has ended. France’s 2024 Finance Act removed one-off fiscal representation for non-EU importers, and the administration’s transitional tolerance ran out at the end of 2025. French customs’ circular of 12 December 2025 confirms that a non-EU importer using Regime 42 must appoint a fiscal representative, with limited exceptions for businesses established in countries that have a mutual assistance agreement with France. Regime 42 itself still exists.
- The borrowed VAT number is gone. One-off representative numbers no longer work for non-EU importers, so the Calais setup many UK businesses relied on has stopped.
- You need your own French VAT number. For most non-EU businesses that means appointing a French fiscal representative, then filing VAT returns and intra-EU reporting.
- The international agent route does not fill the gap. France’s newer mandataire à l’international regime does not cover Regime 42 imports.
- Or move the liability to the customer. Shipping DAP makes the EU buyer the importer, with the cost and the friction that brings.
- Or clear somewhere else. Another member state may suit better, for example one with import VAT deferment, but that is a logistics and compliance decision, not a quick swap. See the Netherlands and Belgium.
What a Proper EU Importer of Record Solves
- A declarant your parcels can clear under. A party able to lodge the declaration and pay or secure the duty is what gets goods released. Our guide to indirect representation for customs duty and import VAT explains how that role carries liability.
- DDP without surprises. Duty and fees are built into your price, so the customer is not billed at the door.
- A replacement for the France shortcut. You get a compliant route in without building your own VAT registrations across member states, where the structure allows it. See import VAT and the importer of record.
- Clean data. With the duty charged per item, accurate classification controls your cost. Check codes with our HS code finder.
Longer term, the rules move again. Under the new Union Customs Code, distance sales move onto the EU Customs Data Hub from 1 July 2028, and the Code also changes who counts as the importer. Our guide to the Union Customs Code 2027 importer definition covers that.
What to Put in Place Now
- Map the flows that relied on the old rules. Find the consignments that leaned on the €150 relief and, if you ship through France, those that ran on a one-off fiscal representative.
- Decide who your declarant is. Register and act yourself, appoint an importer of record or indirect representative, or push the liability to customers on DAP. This decides whether parcels clear.
- Choose your entry point on purpose. Confirm which member state you clear through and that your declarant arrangement works there. See France as well as the Netherlands, Germany and Belgium above.
- Fix your product data. Every SKU needs an accurate code, origin and value. Our guide to reducing import duty in the Netherlands shows how to model duty into price.
- Start early. VAT registration and fiscal representation take time, and any gap leaves goods unable to clear.
Frequently Asked Questions
What happens to my EU parcels if I have no declarant?
Goods are released only once the duty is paid or guaranteed. With nobody able to lodge the declaration and pay, the parcel can be held or returned rather than delivered.
How is the €3 EU customs duty calculated?
€3 per item, where an item is goods sharing the same tariff classification and description. Five identical T-shirts cost €3, while T-shirts plus a watch cost €6.
When does the €2 EU handling fee start?
From 1 November 2026, at €2 per item. Unlike the €3 duty, which ends on 1 July 2028, the handling fee is not temporary.
Does IOSS cover the new customs duty?
No. IOSS is a VAT scheme. The €3 duty applies whichever VAT scheme you use, although the IOSS user or its indirect representative comes first in the declarant order.
Can a UK business still ship DDP into the EU through France?
Yes, but not with a borrowed VAT number. A non-EU importer using Regime 42 now needs its own French VAT number, generally through a fiscal representative.
Should I register for EU VAT myself or use an importer of record?
It depends on volume, margins and how many member states you serve. Registering gives control but ongoing filings. An importer of record gives a presence without that footprint.
How Carra Globe Handles EU Imports
We act as importer of record, and as exporter of record for goods going back out. Depending on the commodity and the client, we import through our own entity, through a local importing structure, or through a partner acting as indirect representative.
Carra Globe works through importer-side registrations and local importing structures appropriate to the goods and destinations it accepts, its own in some markets and established local structures in others. Approvals falling outside the available structure are flagged before a delivery date is agreed. We cover the European Union and 175+ countries. Reach us at info@carraglobe.com.
Sources and verification
- The €3 duty. Council Regulation (EU) 2026/382 of 11 February 2026, amending Regulation (EC) No 1186/2009.
- Item counting, scope and declarant order. European Commission, guidance on the temporary EUR 3 customs duty and the Union handling fee.
- The handling fee and Data Hub dates. European Commission, EU customs reform.
- The worked example. European Commission, the €3 customs duty on low-value parcels, 29 June 2026.
- France, Regime 42. French customs circular on regimes 42 and 63, 12 December 2025, with CGI article 289 A on fiscal representation.
Disclaimer: This guide is for informational purposes only and does not constitute legal, customs or VAT advice. The EU low-value consignment rules and the French Regime 42 requirements are subject to further guidance and national implementation. Confirm the current position with a licensed customs or VAT specialist before making import structure decisions.