EU Adopts EUR 2 Handling Fee: What E-commerce Businesses Should Prepare Now

On 21 September 2026, the European Commission adopted the delegated regulation that sets the new Union handling fee at EUR 2 per item. The fee applies to goods sold through distance sales and released for free circulation in the EU. It follows the publication of the new Union Customs Code, Regulation (EU) 2026/2108, in the Official Journal on 19 September.

The fee is not being collected yet. The delegated regulation must first pass an objection period for the European Parliament and the Council and then be published in the Official Journal. It applies from the tenth day after publication. The Commission's timetable is introduction by 1 November 2026. At the time of checking, the act had not been published.

A second deadline matters just as much: product identifiers become mandatory in customs declarations for B2C imports from 1 November 2026.

Three Measures, Three Different Timelines

EUR 3 temporary duty - in force since 1 July 2026: Council Regulation (EU) 2026/382 removed the EUR 150 customs duty exemption from 1 July 2026. In its place, a flat duty of EUR 3 per item applies to goods sold in distance sales in consignments with a total intrinsic value of up to EUR 150. It applies whichever VAT scheme is used - IOSS, the special arrangements or standard VAT - with specific rules for goods claiming preferential treatment.
EUR 2 Union handling fee - due by 1 November 2026: Set by Commission Delegated Regulation C(2026) 6694 of 21 September 2026. Like the duty, it is charged per item, not per parcel. It sits alongside the duty, not in place of it.
Transition from temporary duty to normal tariffs - 1 July 2028: The EUR 3 flat duty is temporary and applies until 1 July 2028. After that, normal customs tariffs apply according to the type of product, the same day the EU Customs Data Hub becomes mandatory for e-commerce imports.

A Worked Example

A consignment with a total intrinsic value of EUR 90 contains three separately declarable customs items. Assuming it qualifies for the flat duty, it attracts EUR 9 in duty and, once the handling fee applies, EUR 6 in handling fees: EUR 15 in total, excluding VAT and any other costs.

At scale, 50,000 chargeable items generate EUR 100,000 in handling fees alone.

Key Provisions & Analysis

The fee is not limited to low-value parcels

This is the point most likely to be missed. The EUR 150 limit applies to the flat duty, not to the handling fee. The handling fee applies to distance sales generally, including goods valued above EUR 150. The Commission's explanatory memorandum confirms it: in calculating the amount, the Commission left sales above EUR 150 out as a conservative assumption, "even though they are also subject to the handling fee".

Why item counts matter more than parcel counts

An item is one or more goods in a consignment that share data elements such as tariff classification and origin. A single parcel can therefore contain several items and attract several fees. Modelling the cost from parcel volumes alone will understate it.

Product identifiers: the operational deadline

From 1 November 2026, product identifiers become mandatory in customs declarations for B2C imports, after a voluntary period that began on 1 July 2026. Carrier guidance indicates the requirement applies whatever the value of the goods. Identifiers include the merchant's own product code, the manufacturer's model or part number and, where one exists, a standard code such as a GTIN or EAN.

Budget readiness is not declaration readiness. If sellers and suppliers cannot supply this data, and brokers or carriers cannot transmit it, shipments risk delay regardless of who pays the fee.

Who owes the fee

Under the Regulation, the debtor of the handling fee is the debtor of the customs debt. Once the importer-for-distance-sales rules apply, that is the importer for distance sales. Until then, it is the declarant - typically the person entitled to use IOSS, or an indirect customs representative. The Regulation states that the consumer should not be a debtor.

Contracts can allocate who ultimately bears the cost, but a contract does not change who is legally liable. Sellers who build the fee into prices are making a commercial decision, not meeting a legal requirement on the shopper.

The amount can change

The EUR 2 figure reflects the Commission's assessment of Member States' customs supervision costs. Those costs are to be reviewed in a Commission report every two years, so treat the fee as reviewable, not permanent.

Customs warehouses: a lower fee from 2028, amount not yet set

The Regulation provides for a lower handling fee for goods sold from a customs warehouse for distance sales, applying from 1 July 2028. That status is open only to operators meeting Trust and Check trader criteria. The delegated regulation does not set this amount, so any business weighing EU-based warehousing cannot yet quantify the saving.

Not the only cost

Member States can still recover the cost of exceptional control measures, or of checks by authorities other than customs, separately from the EU-wide fee. The handling fee is one line on a customs bill, not the whole bill.

Watch point

The Council required the Commission to assess by 1 October 2026 whether the flat duty is diverting trade flows, and to propose changes if appropriate. We had not located a published outcome when this alert was checked. An assessment does not change the rules by itself, but any follow-up proposal would.

Implementation & Support

Seven actions before 1 November

Map which of your flows count as distance sales into the EU, across all VAT schemes and including orders above EUR 150.
Count customs items, not parcels, and check which consignments stay within the EUR 150 total for the flat duty.
Confirm who acts as declarant on your shipments, and therefore who legally owes the fee.
Agree with brokers, carriers and platforms who invoices, absorbs or passes on the fee, and how often you will be billed.
Re-run landed-cost and margin calculations at EUR 2 per item, alongside the EUR 3 duty where it applies.
Model returns: confirm with your broker whether any fee can be recovered on returned goods rather than assuming it can.
Confirm that sellers and suppliers can provide product identifiers, and test their transmission through your broker's or carrier's declaration system.

How ECTM can help

ECTM offers a focused handling fee readiness review covering shipment scope and customs-item counts, declarant and representation arrangements, pricing, returns and cash-flow exposure, and product-data transmission and carrier invoice checks. Questions of legal interpretation are handled with Grayston & Company.