One example in the Commission’s guidance explains the EU customs duty on small parcels better than the rule itself. Three knitted women’s suits, one of artificial fibre, one of wool, one of another material, travel from China in a single consignment with VAT collected through IOSS. Filed as an H7 or an H6, the consignment pays the temporary duty once. Filed as an H1, it pays three times. Same box, same invoice, same buyer (Commission guidance, 5 October 2026). The difference is €6 on goods worth €140, and EU customs duty on small parcels now turns on that kind of detail.
Where the extra €6 comes from
The EU de minimis removal took effect on 1 July 2026. Council Regulation 2026/382 deleted the €150 relief and put a €3 duty “per item” in its place for consignments up to €150, running to 1 July 2028, and the Commission may propose an extension if the EU customs data hub is not ready. An item is goods sharing the same tariff classification, description and, where the declaration asks for it, origin. The Commission’s Q&A gives the plain version: five T-shirts cost €3, a T-shirt and a watch cost €6 (Commission Q&A). Its guidance adds the catch. Because of IT limits, the EU €3 customs duty is applied per declaration line, whatever the quantity on that line.
So the customs duty per declaration line depends on how finely the dataset sorts goods. The Commission’s trade portal gives the depth: H7 asks for six digits (HS), H6 for eight (CN), H1 for ten (TARIC). The three suits share HS 6104 19 and CN 6104 19 90 and split only at TARIC, into 6104 19 90 10, 20 and 90. One line in the first two datasets, three in the third (Access2Markets).
A seller cannot always pick the cheaper dataset. The guidance makes H1 mandatory for goods under prohibitions or restrictions, for excise goods, for consignments above €150, and for preferential-rate claims when VAT was not collected through IOSS. H7 and H6 are barred for the first two. Origin splits lines as well, at least in H1, the only dataset that carries it: in the guidance’s own bicycle-parts case, identical carbon-fibre parts sit on two lines because five came from China and one from Thailand.
The first question for the broker is which dataset do you file for my usual basket, and how many lines it produces. An invoice that says “accessories” is a poor basis for grouping, and Avalara warns that generic descriptions such as “accessories” become risky under the new data rules.
Consolidation does not hide parcels
Sellers who consolidate B2C orders into one bulk consignment to cut lines run into two rules. Orders for two different consumers are always separate consignments with separate declarations, and the guidance’s anti-abuse clause lets customs split grouped individual sales and apply the duty to each. FedEx has gone further for its own service: from 1 July its Direct Distribution cannot carry consolidated B2C shipments of €150 or less per buyer, and if it finds one inside a consolidation, the whole consolidation goes back to origin (FedEx guide, 6 October 2026).
Who is billed
In law the declarant owes the duty: the platform, the seller, or the carrier or agent lodging the declaration. The Commission’s Q&A says the debtor cannot be the consumer. Its TAXUD FAQ page leaves a residual case open, a consumer in a member state that offers a free online declaration tool.
In practice the contract decides. FedEx writes that under DDP the shipper pays duties, taxes and handling, under DAP the recipient does, and that it disburses to customs first and invoices afterwards. Its own charges sit on top: a disbursement fee of €15 or 2.5% of duty and tax, whichever is higher, from 20 July, and €2.40 per shipment for inbound processing from 3 August. On a one-line parcel where FedEx disburses the €3, that €15 minimum is five times the duty (the guide says the fee does not apply when the customer uses IOSS).
A €2 fee whose start date is still provisional
The Union handling fee was set at €2 per item by Commission delegated regulation C(2026)6694 of 21 September, which is under scrutiny by Parliament and Council. The Commission’s document register still marks it “Act not yet in force”. The guidance expects it to apply from 1 November, the tenth day after entry into force. The European Post reports that Official Journal publication is expected on 22 October, so the date is provisional until then.
The fee has no value threshold, so parcels above €150 pay it too. Declarants will need TARIC code Y126 on every distance-sale declaration from 1 November, the same day product identifiers become mandatory. The guidance applies both charges per declaration line, which turns the suits parcel into €5 on H7 or H6 and €15 on H1, the sums The European Post also gives. Irish Revenue describes the fee per distinct item, and an Italian news site, Pasquale Pillitteri, notes that Italian press reads “item” as article while the Dutch government writes “per product group”. The Commission also says national handling fees must stop once the Union fee starts.
Which side of a date a consignment lands on is already a live question. Estonian customs says every parcel declared on or after 1 July pays the duty, whenever it was ordered or shipped. For air freight crossing into November, AirCargoMCP air cargo tracking returns the Cargo-IMP timeline of an airway bill (RCS, DEP, RCF, NFD, DLV), with station, flight, pieces and weight on each milestone, so the arrival shows up as a milestone on that timeline. It does not count declaration lines, and the declaration date stays in your broker’s record.
Official Journal publication of C(2026)6694 is the next date to watch.