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 1st 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 1st 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 1st 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 1st 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 1st 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, 1st 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.