The Product Identifier customs ask for from 1 November 2026
From 1 November 2026, imported goods sold at a distance need a Product Identifier for EU customs. What the guidance asks for, and what it does not.
A Product Identifier is a code that distance sales of imported goods must make available to EU customs. The DG TAXUD guidance of 2 June 2026 names three and requires two in all cases. The required two are the one the merchant creates for the offer and the manufacturer’s own. Until 1 November 2026 the use of identifiers was voluntary. The requirement applies from 1 November 2026.
Suppose a consumer electronics brand sells one model of wireless earbud through three marketplaces and its own webshop. Each channel carries a different internal code for the same product. One comes from the first marketplace’s catalogue import and one the agency set up years ago. The warehouse uses another on the pick label, and a fourth sits on the invoice. Nobody has ever needed them to agree, because nobody downstream was reading them. From 1 November 2026 customs is reading them.
What does the guidance ask for?
The instrument is the amended Union Customs Code Delegated Act, Commission Delegated Regulation (EU) 2015/2446. The working document is the European Commission’s guidance, version of 2 June 2026, published by DG TAXUD, the Commission’s Directorate-General for Taxation and Customs Union. Its title is “Importation and exportation of low value consignments: the EUR 3 temporary customs duty, guidance for Member States and Trade”.
The requirement covers distance sales of imported goods: sales dispatched to a customer in the Union from outside it. For those goods, product identifiers must be provided or made available to customs. The guidance is candid about why. An EU-wide customs control operation was run by the 27 member state customs authorities, with market surveillance authorities. It looked at low value goods imported directly from third countries to EU consumers. It found that a high percentage of them do not comply with EU product requirements and safety rules. The identifier lets customs take the result of one control on one product and apply it to every listing of that same product.
Two identifiers, not one
The guidance names three codes and requires two of them in all cases.
The merchant Product Identifier, M-PID, is assigned by the online seller, marketplace or platform: the operator organising and managing the offer for the distance sale. It is expected to be unique on each website or marketplace, whatever the number of individual sellers listing the product there.
The non-standardised manufacturer Product Identifier, NS-PID, is assigned by the manufacturer, producer or product supplier and does not rely on internationally recognised standards. The guidance assumes one already exists, since manufacturers normally need a code to track what they make. Where none exists, the manufacturer is expected to assign one, and no particular structure is required.
The third, the standardised manufacturer Product Identifier, S-PID, is reported only where it exists. In Europe this is usually the EAN, the European Article Number encoded in the retail barcode, or the ISBN for books. No manufacturer is obliged to obtain one, and where none has been assigned an exception code is available instead.
So each listing of the earbud owes two codes as a minimum. They are the offer code of the website or marketplace that carries that listing, and the factory’s. The barcode is the third, if there is one.
Unique per variant, persistent across the lifecycle
Two design characteristics decide whether a code qualifies. Uniqueness: each identifier must refer to exactly one product variant, meaning the same brand, size, colour and packaging, and two different items cannot share one. Persistence: the identifier stays unchanged through the product’s lifecycle, at least from manufacturing to offer for sale to delivery. It normally does not change when the goods move between operators, warehouses or platforms.
That sentence does not say what the earbud brand feared. Four merchant codes for one variant, one per channel, is what the guidance expects. The M-PID belongs to the website or marketplace that runs the offer, and each of them reports its own. What the brand owes on top is the manufacturer’s identifier, plus the barcode if there is one. The identifier is one code for the variant that stays the same behind all four listings and can be mapped to each of them. The failures are different ones. A code the warehouse reassigns at re-labelling fails persistence. A code reported at batch or unit level where a model-level code exists fails too, for the reason set out below. Fixing either is a catalogue exercise, not a customs exercise, and it is cheaper before a declaration is lodged than after.
What changes on 1 November 2026
| Claim | Figure | Source |
|---|---|---|
| Product Identifier, voluntary window opens | 1 July 2026 | DG TAXUD, Customs Guidance on EUR 3 customs duty, version of 2 June 2026, sec 3.5.2 |
| Product Identifier, applies and enforced from | 1 November 2026 | Same guidance, sec 3.5.2 |
| Identifiers required per offer | Merchant PID plus manufacturer PID, in all cases | Same guidance, sec 3.5.4 |
| Grouping of items under Article 228(1) UCC-IA where the EUR 3 applies | Not allowed | Same guidance, sec 3.3.1 |
The guidance is precise about the two dates and it is worth repeating them in its own terms. Operators could voluntarily provide the required identifier to customs from 1 July 2026. During that initial voluntary period, no sanction, penalty or other measure could be taken because the data was not provided or was incorrect. Effective enforcement starts from 1 November 2026, when the requirement applies to all goods sold in distance sales of imported goods.
The declaration mechanics arrive on the same calendar. New document codes exist from 1 July 2026 to be declared. C127 is for the merchant identifier, C128 for the non-standardised manufacturer identifier, and C129 for the standardised one. Y081 is used where no standardised manufacturer identifier exists for the declared product. They sit in the supporting document data element, and from 1 November 2026 they are present in the TARIC conditions.
One misreading is worth closing. Where a model-level identifier exists, reporting at batch or unit level is, as a rule, treated as an act contrary to the requirement’s objective. Deliberately granular is not the safe choice.
What EFC does with a brand’s product identifiers
The identifiers belong to the brand and its manufacturer. EFC does not create or assign them, and no service can, because the merchant code follows the offer and the manufacturer code follows the factory. What EFC does is work with what a brand supplies and make sure it reaches the declaration intact.
In practice that is a data conversation held early. When a brand’s goods move through the operating base and are declared, the codes have to be present per variant. They have to be matched to the right tariff line and consistent between the channel catalogue and what the warehouse holds. EFC’s compliance work treats that catalogue as documentation like any other, reviewed before the first declaration rather than at the border. The importer of record question sits beside it. That is because whoever lodges the declaration carries responsibility for the accuracy and completeness of what is in it. The responsibility comes from Article 15 of the Union Customs Code, Regulation (EU) No 952/2013.
This sits inside a wider reform, the EUR 3 temporary customs duty and its scope. The reform is set out in EUR 3 customs duty: per item, not per parcel and on the 2026 reform page.
What a Product Identifier is not
It is not a certificate and it does not prove anything about a product. It is a traceability key, and the guidance says so: it lets customs identify goods and scale a control outcome. A correct identifier on a non-compliant product simply identifies it faster.
It is not CE marking, not a safety file, and not the GPSR Responsible Person role for consumer products. Those are separate obligations with separate holders.
It was not a mandate on 1 July 2026, whatever a supplier email may say. Until 1 November 2026 the use of identifiers was voluntary, expressly without sanction. The guidance invited operators to use that time to get their data in order.
And it is not an EU-wide product registry. Nobody issues these codes. The merchant assigns one, the manufacturer assigns one, and customs asks to see them.
If your catalogue carries more than one manufacturer code for the same variant, that is the thing to reconcile now. What the declarations need can be raised through the contact page.