Free circulation: clear once, sell everywhere

Two models, one border

Selling into the EU from outside it runs on one of two models. In the first, every order crosses the border as its own parcel. Each one is a customs event, with duty, declaration obligations, and VAT friction attached, and the exposure recurs on every cross-border order. In the second, the brand ships bulk inventory into the EU in one import and holds it inside the union. On the usual route the stock is released for free circulation as it enters, with duty settled on the bulk, and every order afterwards moves as Union goods. Held under bond instead, duty and import VAT are deferred and stock is released as it is needed, so the declaration work moves to release rather than disappearing, and nothing is paid on stock that has not been released. Either way, the goods no longer cross a border parcel by parcel.

The difference is structural, not incremental. A border event per order scales with sales volume. A border event per bulk import does not.

Why the 2026 reform makes the status decisive

From 1 July 2026, a flat EUR 3 customs duty applies to each item (in the Commission's guidance, one line of the customs declaration per tariff classification) in a consignment valued at EUR 150 or less, sold at a distance to a consumer and entering the EU from outside it, under Council Regulation (EU) 2026/382. The charge lands per tariff category, rather than once per shipment, so a mixed parcel carries several of them; VAT and declaration costs sit on top. From 1 July 2028, the temporary charge is due to give way to standard customs duties.

The reform charges low-value consignments sold to consumers as they enter the EU. It does not apply to goods already in free circulation inside the Union. The exposure disappears when goods stop crossing the border parcel by parcel, which is what bringing stock in as one bulk import arranges, whether it is released on import or held under bond and released later.

A brand ships bulk inventory into the EU once. It is released for free circulation on arrival or, held under bond, as it is needed, and each release is its own declaration and its own tax point.

What changes in practice

• Stock enters the EU once, as one bulk import, not as repeated cross-border parcels.
• Every order ships as a domestic delivery inside the EU. Whichever route the stock came in by, the order moves as domestic freight, without a further customs event before the customer's door.
• Delivery times read as local, because the stock was already inside the EU.
• Returns route to an address inside the EU and back into the same stock pool, instead of shipping back to the country of origin across a border.

What free circulation is not

Free circulation is a customs status, and only that. It does not change where a product was made: origin is a separate determination under the rules of origin, covered in the note on Made-in-EU origin. It also does not discharge product-safety obligations: an in-scope consumer product still needs a responsible economic operator established in the Union under GPSR, Regulation (EU) 2023/988, covered in the note on the European Responsible Person.

It is also not the same rhythm as storing goods under bond. Stock released into free circulation at import clears one time and moves afterwards as Union goods. Stock held in a bonded warehouse is released as it is needed instead, and each of those releases is its own declaration and its own tax point. Which of the two suits a brand depends on how fast the stock turns and who clears it. Where the goods land in one EU country and the stock is held in another, they can be released at the port of arrival or moved under transit and released where the stock is held; T1 transit explained for importers compares the two.

EFC holds bulk inventory for non-EU brands inside the EU customs union, so stock enters the single market once and then ships to customers as domestic freight. The full reform analysis, with a calculator for a specific order profile, is at the 2026 reform explainer.