EU confirms product-identifier reporting for distance-sale imports

Three different identifiers

The notice distinguishes the merchant reference used on the selling website or platform, the manufacturer’s own model or part reference, and an internationally standardised identifier such as an EAN, UPC or ISBN. Where the product has no standardised identifier, a specific exemption code is required. Sellers, manufacturers and platforms therefore need to pass the relevant data along the supply chain to the declarant.^[1]

Existing law, now mandatory

Delegated Regulation 2026/1022 amended Regulation 2015/2446. Its Annex adds the identifiers to the supporting-document data notes for H1, H6 and H7 declarations, with corresponding reference-number information. Article 2(3) makes those provisions applicable from 1 November 2026, after voluntary provision from 1 July. The 3 November notice confirms enforcement; it does not enact the requirement anew.^[2][1]

Do not overextend the scope

The Commission’s detailed guidance discusses imported distance-sale consignments with intrinsic value not exceeding EUR 150 and says an Annex B clarification is being prepared. It describes mainly business-to-consumer flows, not a general requirement for every business-to-business import. The short news notice uses broader distance-sales wording. Groups should retain this scope qualification and obtain the current national implementation instructions where needed, rather than infer universal coverage from the headline.^[3][1][2]

Practical action

Map merchant and manufacturer identifiers to each product and declaration record, then confirm the data handoff with the customs representative. The obligation is about traceability and customs controls; the identifiers do not themselves establish duty, VAT or relief. The notice also points to broader product-data requirements from July 2028, which should not be confused with the present reporting stage.^[1][3]