Non-VAT businesses count as consumers for the EUR 2 handling fee

From 1 November 2026Emta every distance-sale consignment from a third-country e-shop or platform pays a handling fee (käitlustasu)Emta of EUR 2 per goods itemEmta, whatever the consignment is worthEmta. A goods item (kaubaartikkel) is goods on one declaration line sharing tariff classification, description and origin where requiredEmta: two identical T-shirts on one line cost EUR 2 in total, a T-shirt and a phone case on two lines cost EUR 4. The fee rests on Commission Delegated Regulation (EU) 2026/2152Emta and applies on uniform terms in every Member State.

The business-to-business exclusion is now qualified. Consignments where sender and recipient are both businesses stay outside the fee, except where the recipient is a non-VAT-registered legal personEmta: that recipient counts as a consumerEmta, and the consignment is a B2C distance saleEmta. A distance sale exists only when four conditions hold together: the goods were bought from a non-EU e-shop and sit outside the EU at the moment of the transaction, the buyer or recipient is a private individual or a non-VAT-registered legal person, the sender organises the transport directly or indirectly, and the goods move from business to consumer.Emta The transport condition is not an Incoterms test: goods count as sent by the seller unless the customer collects them personally or arranges transport entirely alone without the seller's involvementEmta.

Distance-sale declarations carry new codes. Every distance-sale declaration bears additional code Y126.Emta Consignments worth up to EUR 150 from outside the EU also carry a product identifier (PID) at goods levelEmta: C127 for the trader's product mark, C128 for a non-standard manufacturer's mark, and C129 for the standardised product identifier, or Y081 instead of C129 only where no standardised identifier existsEmta. C127 and C128 are always required at goods levelEmta, and the system refuses a declaration missing C127, C128 or C129/Y081Emta. Because readiness to file PIDs is low and no formal transition period exists, substantive checks start flexibly: where the real PID reference is not yet available, the reference field may carry the relevant information as text, including for handmade goods without standardised identifiers. The fee's charge code in the systems is F00 and the special-arrangement payment-method code is 7.

Y126 corrections follow the declaration's state. Once goods are released, Y126 cannot be removed under any circumstancesEmta; while goods are unreleased, Y126 can be removed on an H1 declaration, and it can always be added later. The Impulss system does not yet check whether a legal-person importer is VAT-registeredEmta, so the declarant remains responsible for the dataEmta; a system check is under development. The decisive date for the fee is the declaration dateEmta: goods ordered or arrived before 1 November 2026 still attract the fee when declared on or after that dayEmta. After release, an invalidated declaration brings no refundEmta, because the control costs the fee covers have already arisen. The fee forms part of the VAT taxable amountEmta: for IOSS consignments collected at sale it sits inside the VAT declared through IOSSEmta, otherwise import VAT is paid on the customs declaration.

The legal basis is Commission Delegated Regulation (EU) 2026/2152, applied through the declaration rules for distance-sale consignments from 1 November 2026Emta.