Möllenhoff & Partner mbB

Customs

EU Handling Fee for Distance Sales

Since 1 November 2026, the customs authorities of all Member States have been levying a Union handling fee of EUR 2 per goods item on goods from distance sales. It comes on top of the flat-rate customs duty of EUR 3 that has applied since 1 July 2026. Unlike that duty, the fee has no value threshold.

In our article New Union Customs Code published we pointed out that the amount of the fee still had to be set by a delegated act of the Commission. This has now been done with Delegated Regulation (EU) 2026/2152.

  1. Legal basis

Article 20 of Regulation (EU) 2026/2108 (new Union Customs Code, “nUCC”) provides that the fee is levied. Its amount is set by Commission Delegated Regulation (EU) 2026/2152 of 21 September 2026, which is based on Article 20(10) nUCC.
The Union handling fee is introduced as a fixed amount per goods item (Article 20(2) nUCC). It is payable for processing a declaration for release for free circulation where the goods are sold by way of distance sale to a purchaser in the customs territory of the Union. Under Article 20(6) nUCC it is non-refundable.
The amount of the fee is linked to the approximate costs of processing by the customs authorities. These include data checks, risk analyses, controls and infrastructure, including the services of the EU Customs Authority (EUCA) (Article 20(3) nUCC).

  1. Amount, calculation and scope

The fee is EUR 2 per goods item. It is a fixed amount and applies regardless of the value of the consignment. Unlike the EUR 3 duty, it is not time-limited. Under Article 5(78) nUCC, a goods item means one or more goods in a consignment that have the same tariff classification, the same description of goods and, where it must be stated in the declaration, the same origin. Since 1 July 2026, Article 1(61) UCC-DA (inserted by Delegated Regulation (EU) 2026/1022) has defined the term “item” in the same way. According to the Commission’s guidance, technical limitations of the IT systems mean that in practice the fee is charged per declaration item, however many units it covers. The chosen dataset can therefore affect the number of items. Since 1 July 2026, the H7 dataset has been available for all distance sales up to EUR 150 that are not subject to prohibitions or restrictions (Article 143a UCC-DA, new version). The H6 dataset is available to postal operators up to EUR 1,000 (Article 144 UCC-DA, new version). In H7, only the six- digit HS code is declared, without origin. In H6, the CN code is declared, without origin. In H1, by contrast, the ten-digit TARIC code is declared together with origin. The Commission gives the example of three women’s suits made of different materials. The H7 declaration results in one item (EUR 3 duty + EUR 2 fee). The H1 declaration results in three items (EUR 9 duty + EUR 6 fee), because the distinction is made solely on the basis of the commodity code declared in each case.

  1. Relationship to the EUR 3 flat-rate duty

Both charges are levied side by side and calculated using the same item logic. Where the EUR 3 duty applies, EUR 5 is therefore payable per item, plus import VAT.
Legally, however, the two differ significantly. Since Article 1(24) UCC-DA was amended by Delegated Regulation (EU) 2026/1022, the concept of “goods in postal consignments” no longer depends on carriage by a postal operator. It covers all distance-sale goods in consignments up to EUR 150, except IOSS goods and goods receiving preferential treatment. Apart from Article 2(a) of Regulation (EU) 2026/382, the EUR 3 duty therefore applies to almost all distance sales up to EUR 150.
Under Article 3(1) of Regulation (EU) 2026/382, the Commission was to examine by 1 October 2026, and monthly thereafter, whether trade diversion is occurring. If so, it will propose extending the EUR 3 duty to all goods in consignments up to EUR 150. No result of the review under Article 3(1) of Regulation (EU) 2026/382 has been published so far.

  1. Information in the customs declaration

Since 1 November 2026, the TARIC code Y126 must be entered in data element 12 04 002 000 for distance sales in H1, H6 and H7 declarations, and this triggers the fee. The decisive point in time is importation. Goods ordered before 1 November are therefore also covered if they are imported after that date.
On the same date, the voluntary phase for product identifiers ended. These could be provided from 1 July 2026 onwards (Article 2(3) Delegated Regulation (EU) 2026/1022; definitions in Article 1(57) to (60) UCC-DA). The following must be entered in data element 12 03 000 000 for each goods item:

  • C127: the trader’s or platform’s product identifier (e.g. article number)
  • C128: non-standardised manufacturer identifier (e.g. model number)
  • C129: standardised manufacturer identifier (e.g. EAN, ISBN), where available; otherwise code Y081 in data element 12 04

Where an item covers several products, the identifiers must be provided for each product. German Customs provides information on this in ATLAS-Info 0984/26. There is currently some uncertainty about the scope. According to the wording of Annex B UCC-DA (note on DE 12 03 000 000), the obligation applies to every item in a distance sale with no value threshold, which in the H1 dataset would include items above EUR 150. In point 8.2 of its guidance, the Commission announces a clarification that only consignments up to EUR 150 are meant to be covered.

What does this mean for your business?

  1. Clearly identify distance sales. Check your flows of goods to see whether a distance sale is involved. The decisive questions are whether the goods are supplied to non- taxable persons and whether the supplier is involved in the dispatch, even only indirectly. Pure B2B imports are not affected. However, since 1 July 2026 they have been subject to the regular customs tariff up to EUR 150.
  2. Recalculate costs. Calculate per declaration item, not per parcel or per unit. Keep in mind that an H1 declaration can generate more items than H6 or H7 because of the ten- digit classification and the origin information. A tariff preference may reduce the customs duty, but it does not reduce the fee.
  3. Review contracts with service providers. Anyone declaring as an indirect representative owes the fee themselves, alongside the person represented. Expressly agree who bears the costs, indemnification and the supply of data, and review the reference amount of your comprehensive guarantee.
  4. Factor in returns. The fee is charged for the processing. It is not refunded in the case of return shipments, non-release after acceptance of the declaration, or subsequent invalidation.
  5. Obtain the data. The trader, manufacturer and, where applicable, EAN identifiers must reach the declarant. Incorrect or incomplete information is a compliance risk

By: Maximilian Pohl