What changes in the customs process for B2C sellers
The reform changes how your B2C shipments are cleared.
The change runs across the whole journey, from booking to declaration to clearance. As an e-commerce seller, you only need to focus on providing the right information. Your international courier handles the rest.
The core process of how you book a shipment and how it travels stays mostly the same.
What changes sits in four places:
- The information needed at booking
- Who holds legal responsibility as the declarant
- How clearance is handled
- How refunds work on returns.
Only the first needs action from you. The other three are changes to stay aware of, with no action needed from you as a shipper.
Shipment booking
Shipping information required at booking remains the same. You provide an accurate description, value, quantity, HS code, and delivery details.
On top of the core shipment informations, which includes the description, value, quantity, HS code, and delivery details, two points need extra attention.
First, provide the HS code at the right level.
For IOSS shipments (if you are an IOSS holder or you sell through a marketplace that uses its own IOSS), a 6-digit HS code is required.
For shipments without IOSS, and for prohibited or restricted (P&R) goods such as alcohol, tobacco, excise goods, or items needing a licence, a full 10-digit HS code and country of origin are required.
Second, from November 2026, every declaration line item also needs a Product Identifier (PID), a code that identifies a specific product.
Three types of PID apply once the requirement takes effect:
- Merchant PID (mandatory): identifies the seller, marketplace, or platform behind the order. Usually your internal SKU, item code, or product code.
- Non-Standardised Manufacturer PID (mandatory): the manufacturer's own internal code for the product, such as their SKU or article number, where no global standard applies.
- Standardised Manufacturer PID (only if one exists): a globally recognised code such as a GTIN, EAN, MPN, or barcode number.
If your product has no standardised code, confirm that none exists. Do not leave the field blank. Use codes at product model level, not per batch or unit. PID requirements are set by the EU, and DHL Express cannot advise on which PID to use for your product.
Declarant of Import into EU
Previously, responsibility for many low-value clearances sat with the final consumer. Your courier filed the declaration in your customer’s name.
Under the reform, the IOSS holder comes first as the declarant and carries legal responsibility for the clearance.
Whether you are named as the declarant depends on how you sell:
- Selling through a marketplace: the marketplace is the IOSS holder and the declarant. You carry no declarant responsibility.
- Selling direct with your own IOSS: you are the declarant. As a non-EU business, you declare through an indirect customs representative, such as your courier. Your courier will ask for your name, address, EORI number, VAT ID, and confirmation of who acts as importer.
- Selling direct without IOSS: your courier’s customs representative acts as declarant, and VAT and duty are settled at the border.
Note: The execution of this change is handled automatically by your courier. No action is required from shippers.
VAT charge
The process remain the same as the ongoing practice.
For goods valued at €150 or less, VAT is collected at checkout through IOSS, or at the border if you are not registered for IOSS. Without IOSS, VAT is also charged on the duty and the handling fee.
Clearance process
Two things changed here, and both are operational, so your courier handles them fully.
First, low-value B2C parcels can no longer be cleared together as a consolidated group. Each parcel is cleared individually.
Second, non-IOSS B2C shipments (≤€150) must be cleared in the destination country where your customer is, not at the first EU point of entry.
What this means for you as an e-commerce seller is that each parcel is now cleared on its own data. Every parcel must carry complete standalone information, including its own value and its seller and buyer details. You can no longer rely on one dataset covering a consolidated batch.
This mainly affects non-IOSS direct sellers, while marketplace and IOSS sellers are less affected.
Duty refund on returns
Before the reform, customs duty paid on a returned B2C order could be reclaimed under normal refund rules.
From 1 July 2026, the €3 custom duty on B2C returns valued at €150 or less is generally no longer refundable.
The €2 EU handling fee is never refundable. This holds even if goods are faulty, returned or refused.
Two things stay the same:
- VAT refund rules for B2C returns continue as before
- Duty refunds still apply for defective goods, B2B returns, and non-distance sales.
Across every step above, the quality of the data you provide at booking is what decides how smoothly your shipments move.
Be sure to show the retail value of the goods on your commercial invoice, since value is what duty and VAT are assessed against, and review your commercial invoice process before you ship.