For eCommerce businesses selling consumer goods into the European Union, customs compliance is becoming increasingly connected to something that sits much further upstream: product data.

From 1^st November 2026, Product Identifiers (PIDs) become a mandatory part of customs declarations for B2C distance sales of imported goods into the EU.

The requirement forms part of the latest changes to the Union Customs Code and follows the significant changes to low-value eCommerce imports introduced on 1^st July 2026.

While November may still feel some way off, businesses have already been given an important opportunity to prepare. Product Identifiers can be declared voluntarily from 1^st July 2026, providing retailers, marketplaces and their logistics partners with a window in which to identify missing information, test data flows and address potential problems before the requirement becomes mandatory.

This should not be viewed simply as another field to add to a customs declaration. It is another indication of the direction in which European customs is moving. Customs authorities increasingly want more detailed, structured and traceable information about the individual products entering the market.

What are Product Identifiers?

Product Identifiers provide customs authorities with more precise information about the goods being imported and improve the traceability of products sold through eCommerce.

Under the new requirements, three types of identifier are particularly important:

Merchant Product Identifier (M-PID)
This is the unique product identifier assigned by the online seller, marketplace or platform. It could, for example, be a merchant SKU or other unique product reference. The corresponding customs code is C127, and it is mandatory.

Non-Standardised Manufacturer Product Identifier (NS-PID)
This is a product identifier assigned by the manufacturer, producer or product supplier that does not rely on an internationally recognised standard. Examples could include a manufacturer model, style or product reference. The corresponding customs code is C128, and it is also mandatory.

Standardised Manufacturer Product Identifier (S-PID)
Where one exists, this is an identifier based on a recognised standard, such as an EAN, GTIN or ISBN. The corresponding customs code is C129. Where a product does not have a standardised identifier, Y081 is used to declare that no such identifier exists.

Importantly, the requirement applies at item level. This means businesses need to think beyond whether the information exists somewhere within their organisation. They need to consider whether the correct identifiers can be associated with the correct product and transmitted through the supply chain to the party making the customs declaration.  That distinction is important.

A retailer may already have thousands of SKUs within its product catalogue. Its suppliers may hold manufacturer references, while standardised identifiers may sit elsewhere within product information systems. Customs compliance increasingly depends on bringing those different pieces of information together and ensuring they remain connected to the individual item throughout the transaction.

The responsibilities therefore stretch across the eCommerce supply chain. Sellers and marketplaces need to assign and communicate the Merchant Product Identifier. Manufacturers and suppliers are an important source of the manufacturer identifiers. Declarants and customs representatives then need the correct information in order to submit it as part of the customs declaration.

A missing identifier at the point of clearance may therefore have its origins much earlier in the process.

This is really a data readiness issue

The practical question for retailers is not simply, “Do we have this information?”

It is, “Can we reliably get the right information to customs for every applicable product?”

That means reviewing the journey data takes from the product catalogue, supplier or marketplace through order management, warehouse and shipping systems and ultimately into the customs declaration.

Businesses preparing for November should be looking at whether they can consistently provide their Merchant Product Identifier and manufacturer product reference for each relevant item, whether standardised identifiers such as EANs, GTINs or ISBNs are being captured where they exist, and whether their systems can correctly identify where a standardised identifier does not exist.

The voluntary declaration period is therefore valuable. Rather than treating 1 November as the point at which preparations begin, businesses can use the months beforehand to test real product data, identify gaps within catalogues, engage with suppliers where information is missing and confirm that data can pass correctly between systems and partners.

This is particularly important for businesses with large or frequently changing product catalogues. Resolving missing manufacturer references across thousands of SKUs is a very different exercise from adding a new field to a customs declaration.

The PID requirement should also be considered in the context of the wider changes taking place across EU eCommerce customs.

From 1^st July 2026, the EU introduced significant changes affecting low-value distance sales, including the removal of the previous €150 customs duty relief and the introduction of a temporary €3 customs duty for eligible items. Product Identifiers represent another stage in that changing customs environment.

Taken together, these developments point towards a customs system in which product-level data, traceability and data quality play an increasingly important role in determining how efficiently goods move across borders.

For retailers, marketplaces and logistics providers, this changes where customs preparation begins.

It no longer starts when a parcel reaches the warehouse or when a customs declaration is created. Increasingly, it begins when a product is first added to a catalogue.

That makes customs compliance a conversation not only for logistics and customs teams, but also for eCommerce, IT, product, procurement and supplier management teams.

Preparing now for 1^st November

Businesses selling B2C goods into the EU should use the period before November to understand what data they currently hold, where it originates and whether it can be transmitted accurately through their systems. The key is to test rather than assume.

Take representative products from across your catalogue and follow their data through the complete journey. Can you identify the M-PID? Do you hold the manufacturer’s NS-PID? Is there an EAN, GTIN, ISBN or other standardised identifier? If there is no standardised identifier, can that be communicated correctly? Most importantly, does all of that information reach your customs declarant at item level?

Finding those gaps now provides time to fix them. Finding them when goods are already moving towards the EU is considerably more difficult.

At UKP Worldwide, we are working with customers to prepare for the changing EU customs environment and ensure the data required for customs clearance can be captured and transmitted correctly.

For businesses selling consumer goods into Europe, 1^st  November 2026 should already be on the implementation calendar.

The regulation may be changing in November, but the work required to comply with it starts with the product data businesses hold today.

For years, eCommerce businesses selling internationally have concentrated much of their compliance effort on what is inside the parcel: product descriptions, commodity codes, values, country of origin, VAT and customs declarations. Increasingly, businesses also need to think about the parcel itself.

From 12 August 2026, the initial requirements of the EU’s Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) apply across the European Union.

PPWR replaces the previous Packaging and Packaging Waste Directive (PPWD) and introduces a new framework designed to reduce packaging waste, improve recyclability and increase the use of recycled materials. Requirements are being introduced progressively, with further measures coming into application through to 2040.

For UK eCommerce businesses selling packaged goods to EU consumers, this should therefore be viewed as more than an environmental initiative. It forms part of a much wider change in what businesses need to consider when placing goods on international markets.

What does PPWR mean for UK exporters?

PPWR applies broadly to businesses placing packaging on the EU market, including manufacturers, importers, distributors and retailers. It covers packaging types throughout the supply chain, including primary, secondary, tertiary and service packaging.

For an eCommerce retailer, that means compliance considerations can extend beyond the packaging immediately surrounding the product to other packaging used to prepare and transport an order.

Among the requirements applying from 12 August is a restriction on the concentration of lead, cadmium, mercury and hexavalent chromium within packaging or packaging components. Their combined concentration must not exceed 100 mg/kg. Specific restrictions also apply to PFAS in food-contact packaging.

The regulation also establishes recyclability requirements for packaging, although many of the more detailed measures – including future recyclability performance criteria, recycled-content targets, labelling requirements and measures designed to reduce unnecessary packaging – are being introduced progressively.

This is therefore not a single regulatory deadline. 12^th August 2026 marks the beginning of a much longer transition in the way packaging placed on the EU market is designed, documented and managed.

The bigger issue for cross-border eCommerce

PPWR highlights something increasingly important for international retailers: customs compliance and wider market compliance cannot always be considered separately.

A shipment can contain accurate customs data, the correct commodity codes and values, and the appropriate VAT arrangements, but that does not automatically mean everything associated with placing those goods on the EU market is compliant. That distinction matters.

UK Government guidance specifically warns exporters that failure to comply with PPWR could result in goods being rejected at EU borders.

For eCommerce businesses accustomed to thinking of the border primarily as a customs checkpoint, this requires a broader compliance mindset.

Getting the customs declaration right remains essential – but it is only one part of successfully placing a product onto an increasingly regulated international market. Packaging compliance is becoming a data challenge too

There is another important parallel with the changes we are already seeing across customs. Businesses are increasingly expected to know more about their products and provide better-quality, more granular information about them. Packaging is heading in a similar direction.

UK Government guidance advises exporters to collect and maintain relevant PPWR and Extended Producer Responsibility (EPR) data. EPR requirements can involve information including packaging type, weight, recyclability and recycled content.

For retailers with hundreds or thousands of products, this raises an important operational question:

How much do you actually know about the packaging travelling with each product?

It may no longer be sufficient for this information to sit solely with a procurement team or packaging supplier. Businesses selling crossborder increasingly need reliable access to packaging specifications, supplier evidence and relevant compliance documentation.

That turns packaging compliance into a supply-chain data issue as much as a sustainability issue. And, as customs and regulatory systems become increasingly data-led, the ability to retrieve accurate information quickly is becoming an important part of keeping goods moving.

What should UK eCommerce businesses be doing now?

The first step is understanding the packaging being placed on the EU market.

Businesses should consider auditing packaging used for EU orders and speaking to packaging manufacturers and suppliers to establish whether the relevant requirements are being met.

Documentation is particularly important. UK Government guidance advises businesses to prepare a Declaration of Conformity for each packaging type being placed on the market from 12 August 2026 and to ensure that the necessary technical documentation is available to demonstrate compliance with the applicable requirements.

Businesses should also establish who within their supply chain is responsible for providing, maintaining and accessing this information.

Alongside PPWR itself, UK exporters should review their Extended Producer Responsibility (EPR) position in the EU countries in which they sell. This can involve registering with relevant national EPR schemes, reporting packaging data and paying applicable fees. Businesses should also establish whether an authorised representative is required to manage obligations locally.

Micro-enterprises are not automatically outside the regulation either. Although lighter requirements can apply in some circumstances, the UK Government guidance makes clear that they remain subject to core PPWR obligations.

Most importantly, businesses should avoid treating packaging compliance as an isolated project. Procurement, sustainability, compliance, logistics, eCommerce and customs teams may all hold different pieces of the information required. Connecting those pieces is likely to become increasingly important.

Customs arrangements don’t remove packaging obligations

It is also important to separate packaging compliance from the mechanism’s businesses use to manage VAT, duty and delivery. IOSS, DDP and DAP/DDU arrangements may influence how VAT, duties, risk and customs clearance are managed, but they do not remove a business’s packaging obligations when placing packaged goods on the EU market.

A retailer can therefore have an effective IOSS arrangement, accurate customs declarations and a well-structured international delivery solution and still have separate PPWR and EPR responsibilities to address.

This is why looking at cross-border compliance as a complete journey, rather than simply a customs declaration, is becoming increasingly important.

Compliance is moving beyond the customs declaration

PPWR is another example of a wider trend affecting cross-border eCommerce.

From increasingly detailed customs data requirements to product, environmental and packaging regulation, authorities are demanding greater transparency, traceability and accountability from businesses placing goods onto international markets.

For retailers, the question is therefore becoming broader than simply:

“Can we clear this parcel through customs?”

The better question is:

“Do we have the information, processes and evidence needed to place this product – and everything travelling with it – on the destination market compliantly?”

That is a much bigger conversation.

At UKP Worldwide, our role is to help businesses navigate the customs and cross-border elements of that journey, ensuring international delivery and customs processes are structured correctly as regulatory requirements evolve. Packaging manufacturers and specialist compliance advisers should be used where businesses require confirmation that packaging itself meets the applicable technical requirements.

PPWR will continue to evolve as further requirements are introduced over the coming years. For businesses selling into the EU, the important step now is to make packaging part of the wider cross-border compliance conversation – rather than waiting until a compliance issue interrupts the movement of goods.

Further information

UK businesses can find guidance on PPWR, EPR requirements and recommended actions through the UK Government’s Business.gov.uk service:

UK Government – EU Packaging and Packaging Waste Regulation (PPWR)
https://www.business.gov.uk/campaign/europe/european-union-eu-regulations/eu-packaging-and-packaging-waste-regulation-eu-ppwr/

The full legislation is available through EUR-Lex:

Regulation (EU) 2025/40 – Packaging and Packaging Waste
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040

This article provides general information on regulatory developments and should not be considered legal or packaging-compliance advice. Businesses should seek specialist advice regarding the obligations applicable to their products, packaging and supply-chain structure.