VAT Rules Remain Unchanged
The new regulation builds on the existing VAT framework:
Since July 2021, the €22 VAT exemption has already been abolished. VAT applies to all imported goods, including low-value shipments.
👉 From 2026, VAT continues to apply with new customs duties introduced.
Additional Handling Fees Expected by November 2026
The European Commission has also proposed a new EU-wide handling fee for low-value imports, expected to be implemented by November 1, 2026. Details are still under discussion, however the move is likely to create additional cost pressure for exporters and consumers.
New Product Data Requirements for EU Customs Clearance
Beyond taxation, data compliance requirements will become stricter.
For shipments below €150 (excluding certain B2B shipments), exporters will need to provide three types of product identification codes in customs declarations:
- Seller Product Identifier (SKU, item number, or internal product code)
- Non-standard Manufacturer Identifier (Manufacturer-specific product code)
- Standardized Identifier (International codes such as EAN, UPC, or barcode, if available)
Early data preparation is strongly recommended to avoid disruptions.
Exceptions and Special Cases
1. B2B Shipments (VAT-Registered Importers)
- Subject to standard customs duties (HS code-based)
- Not eligible for the €3 simplified duty rule
2. Free Trade Agreement (FTA) Goods
- If NOT sold under IOSS: May still qualify for duty exemption under FTA rules
- If sold under IOSS: €3 duty per declaration line applies
As these rules can be complex, consulting with customs or tax specialists is highly recommended.
Impact on Japan-Based Cross-Border E-Commerce Businesses
1. Increased Costs for Low-Value Orders
Businesses selling products under €150 will face direct cost increases.
- Previously duty-free items now incur €3 minimum duty (or more depending on declaration structure)
- This particularly impacts low-margin, high-volume business models.
2. Checkout and Pricing Transparency Becomes Critical
Businesses must prepare to clearly display at checkout:
- Duties
- VAT
- Total Landed Cost
Why this is important: Pricing transparency ensures customers are not kept in the dark or surprised by additional costs. This can help reduce delivery refusal, improve trust, and minimize customer service issues.
3. Urgent Need for Product Data Standardization
Incomplete product data may lead to:
- Customs clearance delays
- Shipment holds
- Increased return rates
It will be essential to ensure that your systems include SKU, manufacturer codes, and global identifiers (EAN/UPC).