State of play of the Customs Reform and the removal of de minimis

Several developments in EU legislation on e-commerce and imports are redefining the trade policy of the EU lately.

While the discussions on the Union Customs Code (UCC) reform are still undergoing – notably on the seat of the EU Customs Authority as of 2028 and the details on the introduction of a handling fee for customs purposes from November 2026 – the EU Member States are shifting their focus on another matter strictly linked to the UCC reform: the removal of the customs threshold of €150 for goods imported in the EU. The removal of this so-called de minimis was already part of the UCC reform as proposed by the European Commission in May 2023, but was not subject to the co-decision procedure with the European Parliament, and, consequently, it was officially adopted by the Council of the EU in December 2025. One major difference compared to the Commission’s proposal is that the removal of the threshold, as approved by the Council, would not occur in 2028, but on 1 July 2026.

The change of entry into force of the customs duty threshold’s removal is a strongly important message that the EU wants to convey to the international arena, to its citizens and national politics: the EU is addressing the rising volumes of e-commerce and high percentage of non-compliance in e-commerce imports, and is putting forward a quick solution which can be extraordinarily be implemented in the short-term (instead of the initially proposed 2028). The earlier removal of the customs threshold is also one way to deliver on the expectations set by the February 2025 E-commerce Communication of the European Commission, which stated that immediate responses need to be tabled. The European Commission also committed to assess its level of commitment, and if needed, level it up, within one year from the publication.

At Ecommerce Europe, we strongly support the removal of the threshold as one way to achieve a better level playing field between EU and non-EU based companies. However, we also believe that the removal of de minimis is one of the pieces of the puzzle to ensure a fair competition in the Single Market, and that this provision should not be presented or perceived as a standalone measure. Alone, the removal of the customs threshold will generate new revenues, but it will not reduce the competitive advantage of certain non-EU players, where those players have extremely and unfairly low prices, and it will not improve the product compliance of imports per se. Indeed, it will not prevent the occurrence of undervaluation of goods or splitting of consignments, although it will make it more challenging to commit these frauds.

Besides these challenges, one major question is to be addressed regarding the operationalisation of the removal of de minimis: how will it work? The details agreed by the EU Member States in December 2025 focus on a temporary IT solution for the collection of customs duties at the EU level, including the introduction of an interim €3 fixed duty per item. While this agreement moves in the right direction towards levelling the playing field between EU companies and non-EU based companies, businesses will require more concrete operational details to ensure legal certainty and to adapt their compliance models and internal IT systems. In particular, the details on the functioning of the Import One-Stop Shop (IOSS) – which is a central tool for VAT simplification, accountability and transparency in e-commerce imports – have yet to be defined, given that it has been reported that the €3 customs duty will apply only when goods are declared with an H7 declaration and so imported via the IOSS. For non-IOSS imports, the traditional tariff classification applies. Many questions arise on several aspects and details of this solution, including how the system will function operationally, which loopholes will need to be closed, the readiness of the IOSS in light of the ongoing IOSS securisation work that the European Commission is currently working on, and more.

While the European Commission and the relevant industry stakeholders, including Ecommerce Europe, are discussing these practicalities in the Trade Contact Group, time is needed for the finalisation of these details, and for the completion of the UCC reform in its entirety. E-commerce companies will require sufficient lead time to adapt their systems and make sure that legitimate trade will not be impacted negatively by the introduction of this milestone change in the EU customs and import system on 1 July 2026.