EU confirms product identifiers for low-value e-commerce customs declarations

Commission Delegated Regulation (EU) 2026/1022 amended Annex B to Delegated Regulation (EU) 2015/2446. For H1, H6 and H7 declarations within scope, the supporting-document data must include a merchant product identifier, a non-standardised manufacturer product identifier and, where it exists, a standardised manufacturer product identifier for each item.^[1][2][3]

Scope of the requirement

The Commission guidance limits the requirement to goods sold in distance sales of imported goods in consignments with an intrinsic value not exceeding €150. It says the rule mainly concerns business-to-consumer imports; business-to-business flows are generally outside the distance-sale definition. Voluntary reporting was available from 1 July, with enforcement from 1 November 2026.^[1][2]

Identifiers and supply-chain roles

The merchant identifier is the reference assigned by the online seller, marketplace or platform. The non-standardised manufacturer identifier links the product to the manufacturer’s own model or reference and is required in all cases. A standardised identifier, such as an EAN, UPC or ISBN, is reported only where it exists. Platforms, sellers and manufacturers pass the data through the supply chain; the customs declarant reports them.^[1][2]

Practical consequence

Platforms, IOSS participants, customs representatives and importers should verify that product-level identifiers reach the declarant and map into data element 12 03 for the relevant H1, H6 or H7 declaration. The Commission guidance is explanatory and does not override the regulation or national customs instructions. Wider product-data requirements are expected with the EU Customs Data Hub from July 2028.^[1][2][3]