Starting November 1, 2026, the European Union will reject customs declarations for consumer imports that don't include product identifier (PID) data. If you or your customers ship goods directly to consumers in any of the 27 EU member states, here's what you need to know.
Why the EU Is Asking for More
E-commerce parcels into Europe have grown fast. According to the European Commission, since 2022, the volume of small packages sent into the EU has doubled every year. At the same time, the Commission's product safety checks on items like toys, cosmetics, electronics and supplements found that well over half didn't meet EU standards.
Product identifiers solve a tracing problem. Once customs flags one unsafe product, a PID lets them instantly locate every other shipment carrying the same item. The requirement comes from Commission Delegated Regulation (EU) 2026/1022, which amends the Union Customs Code Delegated Act.
PIDs vs. HS Codes
These are easy to confuse, but they do different jobs:
- An HS code describes the category of product, for example "headphones."
- A PID pinpoints the exact product: this specific model, from this manufacturer, sold under this SKU.
You'll need both.
The Three Questions Customs Now Asks
Think of the three identifiers as answers to three questions about every item in the parcel.
1. Who is selling it?
This is the M-PID (merchant product identifier), declared under TARIC code C127. It's usually the seller's SKU or a marketplace listing ID, such as an Amazon ASIN. Mandatory.
2. Who made it?
This is the NS-PID (non-standardized manufacturer identifier), declared under C128. It's the manufacturer's own part or model number. Mandatory.
3. Does it carry a retail barcode?
This is the S-PID (standardized manufacturer identifier), declared under C129. It's a globally recognized code like a GTIN, EAN, UPC, ISBN or IMEI. Required whenever one exists. If the product has no barcode, you declare exception code Y081 instead.
All three belong in the supporting documents field of H1, H6 and H7 customs declarations.
What It Looks Like in Practice
A wireless speaker (has a barcode)
- C127: SPK-BT-MINI-GRY (seller's SKU)
- C128: BTS-220-G (factory model number)
- C129: 012345678905 (UPC on the packaging)
A handmade candle (no barcode)
- C127: CNDL-LAV-8OZ (seller's item code)
- C128: LAV-8-2026 (producer's product reference)
- S-PID: none, so declare Y081
Blank Is Not the Same as "None"
This is the mistake most likely to cause holds. An empty S-PID field doesn't tell customs the product has no barcode. It tells them data is missing, and the declaration will likely be rejected.
Y081 should only be used when it's genuinely true. Each use is a formal statement to customs, and authorities can search for every declaration that relied on it.
Who Needs to Comply
The rule applies if:
- Goods are shipped from outside the EU directly to an EU consumer
- At any order value, however small
- Under any VAT arrangement, including IOSS
- Through marketplaces too. The platform's listing ID can serve as the M-PID, but the seller still has to obtain the manufacturer's part number and barcode from their supplier
The rule does not apply to:
- Business-to-business shipments to VAT-registered EU companies
Your Pre-Deadline Checklist
- Identify which customers ship B2C into the EU.
- Audit your item master to see which of the three fields are already populated.
- Request missing manufacturer part numbers and barcodes from suppliers right away.
- Flag products without barcodes for Y081, and confirm they truly have none.
- Confirm the data reaches whoever files your customs entries, whether that's your carrier or your broker.
- Test a handful of EU shipments before November 1 to catch gaps early.
Don't Let Peak Season Catch You Off Guard
The technical side of this change is straightforward. Adding three fields to a declaration takes little effort. What takes time is gathering the data, since manufacturer part numbers and barcodes sit in your suppliers' records, not yours. With November 1 only weeks away and peak season right behind it, the businesses that start collecting now will be the ones whose parcels keep moving.
Shipping to the EU and not sure where to start? The Inex team can help you review your international shipments and make sure nothing gets held at the border.
Contact us at info@inex.ca