The €3 rule: what the end of the €150 threshold means for your CN codes

For most sellers importing into the EU, the customs classification of a product has been a field somebody fills in once. From 1 July 2026 it is a line item on a cost model.

The change is small to describe and awkward to implement, and the awkward part is not the duty — it is that the duty is calculated from a field most catalogues hold badly.

What actually changed

The €150 duty relief for low-value consignments ended on 30 June 2026. In its place, a temporary flat customs duty of €3 applies to goods in consignments up to €150 sold in distance sales, and it runs until 1 July 2028, after which normal duties apply according to the goods.

It applies regardless of VAT scheme — IOSS, the special arrangements, or standard VAT. If you assumed IOSS registration insulated you from this, it does not.

All of the above is from the Commission’s guidance and legal text, published 8 June 2026: Guidance and legal text on the temporary flat fee on low-value imports, DG TAXUD. The wider reform sits under EU customs reform.

The part that touches your product data

“Item” is counted by tariff classification, not by unit.

The Commission’s own example is the clearest statement of it:

5 T-shirts → €3 1 T-shirt + 1 watch → €6

Five units of one classification are one item. Two units of two classifications are two items. So the duty on a parcel is a function of how many distinct tariff classifications it contains — which means the total is computed from your CN codes, and a wrong or missing code is now a wrong invoice rather than a tidiness problem.

Two consequences follow, and neither is a customs problem:

Your CN code belongs on the variant, not the product. A T-shirt and a watch are obviously different classifications. So, less obviously, are a cotton garment and the same garment in a synthetic blend, and a device sold with and without a battery. If your catalogue holds one classification on the parent and inherits it down, the duty computed from your data will be wrong in exactly the cases where variants differ materially — which is most of them.

Basket composition is now a cost input. Bundling two classifications into one parcel costs €6 where two parcels of one classification each also cost €6, and one parcel of five identical items costs €3. Nobody needs to re-plan their range around this, but the number should at least be computable from the catalogue rather than discovered on a customs invoice.

Product Identifiers become mandatory on 1 November 2026

The same guidance sets two dates for Product Identifiers (PIDs):

• Voluntary from 1 July 2026
• Mandatory from 1 November 2026

That is the date worth putting in a plan. “Voluntary” is a four-month window in which the identifier can be added to product records incrementally, by whoever maintains the catalogue, at normal pace. After it, an identifier missing from a product record is a consignment that cannot be declared correctly.

Four months is generous for adding one field and hopeless for discovering, in November, that the field has to be added to every variant of forty thousand SKUs by a team that also has a Christmas peak.

What this makes a readiness rule

If you take one thing from this: “CN code present and valid, per variant” is now a check that belongs beside your other pre-submission checks, not in a spreadsheet somebody opens at quarter end.

Present is the easy half. Valid is the half that needs a source: a code that existed in the Combined Nomenclature two years ago may have been reallocated, and a code that is syntactically fine can still be the wrong one for the goods. The practical rule most teams can hold is: present on every variant, checked against the current nomenclature, and reviewed when the variant’s material composition changes.

Add the Product Identifier to the same rule from 1 November 2026 and the customs half of a product record is answerable from the catalogue rather than from an inbox.

Where TOVIA stands

The EU compliance attributes — CN code per variant, EPR registration per market, GPSR responsible person, Product Identifiers — are in development. They are not finished and are not in use against real data.

The readiness engine that will enforce a rule like “CN code present and valid per variant” is built and runs on a local build against synthetic data. There is no live customs integration and none is planned for the near term; what TOVIA is building here is the product-data half — the classification on the right record, checked before it becomes an invoice.

Product Master is where those attributes live, with the state of each one on the page.

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Sources: DG TAXUD, guidance and legal text on the temporary flat fee (8 June 2026), and EU customs reform. This article is not tax or customs advice; the classification of your goods is a question for your customs agent.