On November 1, 2026, the European Union will stop accepting customs declarations that are missing product identifier data. If any of your customers sell direct to consumers in the EU27, this information is for you.
The EU added the PID rule so it can trace products back to their source. The European Commission reports that low-value shipments into the EU reached close to 5.9 billion items by the end of 2025. That is up from about 4.6 billion at the end of 2024. Its work on e-commerce product compliance and safety found that more than 60% of the products it checked failed EU standards. Those checks covered toys, electronics, cosmetics, protective equipment, and supplements. Product identifiers let customs find one unsafe item and then pull up every other shipment with the same code.
Below is what changed in EU shipping compliance, who it applies to, and what to do before the deadline of November 1.
What Is a Product Identifier Under EU Shipping Compliance?
A product identifier (PID) is a customs data code. It tells EU authorities three things about an item in a parcel: who sold it, who made it, and whether the item has a standard retail barcode. The codes come from Commission Delegated Regulation (EU) 2026/1022 of 30 June 2026, which updates the Union Customs Code Delegated Act. They must appear on customs declarations for goods sold to EU consumers from outside the EU.
A PID is not the same as an HS code. An HS code says what kind of product is crossing the border, such as a leather shoe or a ceramic mug. A PID says which exact product it is, down to the SKU, the supplier who made it, and the barcode on the box.
There are three codes:
| Identifier | Plain English | Who assigns it | TARIC code | Status |
|---|---|---|---|---|
| M-PID | Merchant product identifier, usually the seller's SKU or marketplace listing ID | The seller or the platform | C127 | Mandatory |
| NS-PID | Non-standardized manufacturer identifier, the factory's own part number | The producer or supplier | C128 | Mandatory |
| S-PID | Standardized manufacturer identifier, a retail barcode such as a GTIN, EAN, UPC, ISBN, or IMEI | The producer or supplier, using a standards body's scheme such as GS1 | C129 | Required where one exists |
All three go in the supporting document field on H1, H6, and H7 declarations. Some products have no standard barcode. In that case you must still say so, using exception code Y081. If you leave the field blank, customs treats the declaration as incomplete and will most likely reject it.
Two Examples
A pair of running shoes. This product has all three codes, so the declaration carries all three.
- M-PID (C127): SHOE-RUN-BLK-42, the seller's SKU
- NS-PID (C128): MFR-2024-RS-BLK-42, the factory's own model reference
- S-PID (C129): 5901234123457, the EAN-13 printed on the retail box
A custom mug with a printed logo. Promotional and custom items rarely have a retail barcode. That is allowed, as long as you declare it.
- M-PID (C127): GIFT-MUG-LOGO-RED, the seller's item code
- NS-PID (C128): PROMO-MUG-350ML, the blank mug's supplier reference
- S-PID: none exists, so the declaration carries exception code Y081
What to Do When There Is No Barcode
The EU does not make anyone create a barcode that does not exist. Work through it in this order:
- Does the product have a globally recognized retail barcode, such as a GTIN, UPC, EAN, or ISBN? If yes, declare it as the S-PID under code C129.
- If no barcode exists, declare exception code Y081.
Leaving the field blank is not the same as declaring the exception. Customs reads a blank field as missing data, not as "no barcode exists."
Use the exception only when it is true. Every Y081 is a formal statement that the product has no standard barcode, and customs authorities can search for every declaration that used it.
Does This Apply to Your Customers' Shipments?
Yes, if your customer sells the goods direct to a consumer in the EU and ships them in from outside the EU, this will affect them. The price of the order does not matter. In addition, here are three special cases to be aware of:
- Every VAT scheme is covered: The Import One-Stop Shop, the special arrangements, standard VAT registration. Using IOSS or not using it changes nothing here.
- Marketplace orders still need supplier data: An Amazon ASIN or a Shopify SKU can serve as the M-PID. But the marketplace does not know the factory part number or the retail barcode. The seller has to get those from the supplier.
- B2B is out of scope: Shipments to VAT-registered EU businesses are not sales to consumers, so the rule does not apply to them.
Three Things to Collect From Your EU Shippers Before November 1
Every EU parcel needs all three codes on the declaration. Confirm each one is in your item master and reaching whoever files your customs entries, whether that is your carrier or your broker.
- The M-PID, your customer's SKU.
- The NS-PID, the factory's part number.
- The S-PID, the retail barcode, or the Y081 exception.
If any of the three is missing on November 1, the declaration is incomplete. Customs will likely reject it and hold the parcel.
One thing to note on the timeline: for most 3PLs, the challenging part of this compliance won't be configuration, it will be collecting product data from suppliers and manufacturers. The factory part number is sourced from the supplier's records, so send your requests now so you aren't still waiting on data after November 1.
Your Readiness Checklist Before November 1
If this affects your operation, our help center has the current guidance on how Extensiv will be updating Small Parcel Suite to offer the data fields you need to have updated.
Frequently Asked Questions
What is an EU product identifier (PID)?
An EU product identifier is a customs data code that identifies a specific product in a shipment to an EU consumer. There are three types: the M-PID assigned by the seller, the NS-PID assigned by the manufacturer, and the S-PID, which is a standard retail barcode such as a GTIN or EAN. They are declared using TARIC document codes C127, C128, and C129.
When do EU product identifiers become mandatory?
November 1, 2026. Product identifiers have been optional since July 1, 2026, with no penalty for errors during that window. From November 1, a declaration missing required PID data can be rejected and the shipment held.
Does the PID requirement only apply to orders under €150?
No. The €150 threshold applies to the flat €3 duty, which is a separate rule. Product identifiers are required on H1, H6, and H7 declarations. They apply to any sale to an EU consumer of goods shipped in from outside the EU, whatever the order is worth.
What happens if a product does not have a barcode?
You have to declare an exception. Exception code Y081 states that the product has no standard manufacturer identifier. The M-PID and NS-PID are still required. A blank field is not the same as the exception, and customs will treat it as missing data.
Can one SKU be used for more than one PID type?
No. Each code answers a different question: who is selling the item, who made it, and what standard code identifies it. Using the same value for all three produces a declaration that looks complete but does not hold up if customs checks it against the TARIC field definitions.
Does an Amazon ASIN count as a PID?
An ASIN can serve as the M-PID, because it is a listing identifier assigned by the platform. It does not cover the other two codes. Amazon has no visibility into the supplier's part number or whether a GTIN was ever registered, so the NS-PID and S-PID still have to come from the supplier.
Does a UPC count as an S-PID if there is no EAN?
Yes. Any globally recognized retail barcode standard qualifies, including GTIN, UPC, EAN, and ISBN for books. What matters is that a recognized standards body scheme assigned it, rather than someone creating it internally.
What happens if a parcel ships without a PID after November 1, 2026?
The declaration is treated as incomplete. Expect rejected customs entries and parcels held at the border instead of automatic clearance. There is no fallback to the old €150 exemption.
Is there a penalty during the voluntary period?
No. July 1 to November 1, 2026 is a testing phase, and no penalties apply for missing or incorrect PIDs during it. That protection ends when the requirement becomes mandatory.
Does using IOSS change the PID requirement?
No. The rule follows the definition of a distance sale in the EU VAT Directive. It applies whether your customer uses the Import One-Stop Shop, the special arrangements, or standard VAT registration.
Who is responsible for PID data, the 3PL or the brand?
By law, the importer and the declarant are responsible. That is usually your customer or their broker. In practice, the 3PL holds the item master and takes the delay when data is missing. So most of the work of collecting and keeping identifiers ends up in the warehouse.
Official Sources on the New EU Shipping Compliance
- European Commission, Commission Delegated Regulation (EU) 2026/1022 of 30 June 2026. The legal text that defines the M-PID, NS-PID, and S-PID and applies them across declaration types H1, H6, and H7.
- European Commission, guidance and legal text on the temporary flat fee on low-value imports, which runs until 1 July 2028.
- European Commission, Customs Guidance on the EUR 3 customs duty. The technical guidance, including the TARIC document codes in section 3.5.6 and the full PID definitions in section 3.5.
- European Commission, Goods bought online: facts and figures. Source of the 5.9 billion figure.
- European Commission, e-commerce product compliance and safety. Source of the 60% figure.
- European Commission, EU Customs Reform. The wider reform this sits under.
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