Product identifiers at EU customs from 1 November 2026: make your listing, label and GPSR file name the same product

2026-11-09 · IberTrust Global

New EU customs rule · in force for e-commerce imports since 1 November 2026 · with practical notes from our GPSR files

Hypothetical example of a typical scenario: a seller in Shenzhen ships Bluetooth speakers straight to customers in Spain. The marketplace page calls the product “Speaker Pro 2026”, the rating label says model “X7”, and the declaration of conformity in the EU Responsible Person’s file says “BT speaker, wireless”. Nobody ever compared the three.

Since 1 November 2026, customs does. For every item in a low-value parcel sold at a distance from outside the EU to an EU customer, the customs declaration must now carry product identifiers — the marketplace reference, the manufacturer’s model reference and, where one exists, the barcode number. The European Commission says the aim is simple: when customs finds one unsafe or non-compliant product, it can extend that result to every identical product, “even when they are sold by other sellers or on other platforms”.

Identifiers you already use have become compliance data. If your listing, label and GPSR documents name the product differently, that link is harder to defend.

The three identifiers customs now asks for

Identifier	Who assigns it	Example	Required?
M-PID – merchant product identifier (TARIC document code C127)	The online seller, marketplace or platform. On a marketplace it is the platform’s reference, unique on that platform whatever the number of sellers	The reference number on the product page	Always
NS-PID – non-standardised manufacturer product identifier (C128)	The manufacturer, producer or product supplier	Model, part or style number	Always. If none exists, the manufacturer is expected to assign one
S-PID – standardised manufacturer product identifier (C129)	The manufacturer, producer or product supplier, under an international standard	EAN, UPC, ISBN	Only where it exists. Otherwise the declaration uses exemption code Y081

A manufacturer may use its barcode as its model reference, and a platform may use the barcode as its own reference; the same value is then declared under both codes.

Who must do what

The declarant files the identifiers and is responsible for the accuracy of the declaration (Article 15 of the Union Customs Code). For these low-value distance sales this is usually the IOSS holder, the special-arrangements operator or an indirect customs representative.
The platform or online seller assigns the M-PID and passes it on.
The manufacturer or product supplier assigns the NS-PID (and the S-PID, if any) and passes them down the supply chain.

So “my logistics provider handles customs” is only half true. The declarant can only declare what it receives from you, and the guidance tells declarants to take reasonable measures when in doubt, for example checking the product itself against its barcode.

Why this is a GPSR question too

The General Product Safety Regulation already asks for the same consistency:

Manufacturers must put a type, batch or serial number or other identifying element on the product (GPSR, Article 9(5)).
Every online offer must show information identifying the product, including a picture, its type and any other product identifier (Article 19).
The EU Responsible Person must be able to give authorities the documents for that product (Regulation (EU) 2019/1020, Article 4).

The model reference that now travels to customs as the NS-PID should be the one on the product label, in the listing and on the declaration of conformity or test report kept by your Responsible Person. When they match, customs, market surveillance and your Responsible Person are looking at the same product. When they do not, every enquiry starts with “which product is this, exactly?”.

Step by step: build one identifier sheet per product

List every variant you sell. The guidance says each identifier must point to exactly one variant (same brand, size, colour, packaging). One model number for five colours is not enough if you sell them as separate products.
Record the manufacturer’s model reference (NS-PID) for each variant. If your factory never assigned one, ask it to; it should stay the same across platforms.
Record the barcode (S-PID) where it exists, or write “none” so the declarant knows to use code Y081. Do not invent one.
Record the merchant reference (M-PID) per platform, or your own shop’s reference if you sell from your website.
Check the label. The model reference printed on the product or packaging (GPSR Article 9(5)) must match the NS-PID.
Check the listing and the documents. The model in each online offer (Article 19) and in the declaration of conformity, test reports and manual held by your Responsible Person should be the same.
Send the sheet to whoever declares your parcels and keep it updated.

Common mistakes

Declaring batch or serial numbers instead of the model reference. The guidance treats deliberately reporting identifiers at batch or unit level, when a model-level identifier exists, as an infringement, because it stops customs from linking identical products.
One identifier for a whole range, or one barcode reused across variants.
Bundles declared as one product. For a bundle, the identifiers of each product in it must be declared.
Assuming personalised or second-hand goods are exempt. For second-hand goods, the original product’s identifiers are declared. For a personalised textile, the identifiers of the underlying textile are declared.
Renaming the model for each platform, or treating this as a customs-only task. Marketing names can differ; the model reference on the declaration, label and documents should not.

Who this does not apply to

B2B imports. The guidance says business-to-business flows are in principle not concerned.
Goods already in the EU when sold, for example stock shipped from an EU warehouse. A distance sale of imported goods requires the goods to be outside the EU at the time of supply.
Higher-value consignments. The Commission is amending the rules to make clear that the requirement covers goods in consignments with an intrinsic value not exceeding EUR 150 — that EUR 150 figure is the legal / regulatory threshold under the customs rules, not a price charged by IberTrust.
Some categories get an administrative tolerance (for example certain hand-made goods, antiques and art, and unprocessed agricultural goods, under specified commodity codes). For medical devices, the UDI-DI counts as the standardised identifier.

Not being in scope of the customs rule does not switch off GPSR. Label, listing and Responsible Person duties still apply.

The Commission calls this a first step: more comprehensive product data requirements are planned once the EU Customs Data Hub for e-commerce is deployed from July 2028.

FAQ

Do I have to buy EAN barcodes for my products?

No. Manufacturers have no obligation to assign a standardised identifier. If none exists, the declaration says so with code Y081. The model reference (NS-PID) is always required.

Is the merchant identifier my own SKU?

On a marketplace, the guidance says the merchant identifier is the platform’s own reference, unique across that platform, not each seller’s internal code. On your own website it is the reference your shop uses.

Who is responsible if the identifiers are wrong?

The person who lodges the customs declaration is responsible for its accuracy. The guidance expects declarants to make sure the identifiers are made available to them, so they will need correct data from you.

Does this replace GPSR labelling?

No. It is a customs data requirement. GPSR still requires an identifying number on the product and identification information in every online offer.

Can my EU Responsible Person declare the identifiers?

The Responsible Person under GPSR is not automatically your customs declarant. What it can do is check that the identifiers you give the declarant match your labels and the documents it holds.

Want your identifiers, labels and GPSR file to match?

IberTrust Global S.L. acts as EU Responsible Person for non-EU sellers and keeps the product documents authorities may ask for. Send us your product list with model references, label photos and listing links, and we will point out where the listing, the label and the documents do not tell the same story.

Request a GPSR identifier and label check →
Or email contact@ibertrust.info.

Sources: European Commission, DG TAXUD, “Product identifiers for e-commerce imports mandatory from 1 November 2026” (3 November 2026); European Commission, “The temporary EUR 3 customs duty and the Union handling fee – Guidance for Member States and Trade”, version of 5 October 2026, section 8; Commission Delegated Regulation (EU) 2026/1022; Regulation (EU) 2023/988 (GPSR), Articles 9 and 19; Regulation (EU) 2019/1020, Article 4. General information, not legal advice.