EU Customs Product Identifiers: What FBM Sellers Must Send From November 1, 2026

On October 21, 2026, Amazon posted a short item in its Selling Partner API changelog that matters far beyond developers. It says: "Starting November 1, 2026, EU customs will require product identifiers for all business-to-consumer (B2C) goods shipped into the EU from outside of the EU."

The European Commission's own guidance is narrower than Amazon's one-line summary: the requirement covers goods sold to consumers in consignments with an intrinsic value of no more than €150 (more on that below). If you sell on Amazon.de, .fr, .it, .es, .nl or another EU store, and you ship seller-fulfilled (FBM) orders from the UK, the US, China or anywhere else outside the EU, this applies to you. Amazon is clear that missing identifiers "can cause a shipment to be held or returned at customs, at the seller's expense."

Here is what the rule is, where it comes from, what Amazon fills in for you, and what you need to sort out before the deadline.

Where the rule comes from

This is an EU requirement, not an Amazon policy. It is part of the EU Customs Reform, the same package that ended the duty exemption on low-value parcels. The European Commission's guidance announcement sets out the timeline:

• 1 July 2026: "the temporary €3 customs duty starts to apply. The Product Identifiers (PIDs) can be declared on a voluntary basis."
• 1 November 2026: "Product Identifiers (PIDs) become mandatory to improve traceability and safety checks."
• 1 July 2028: "EU Customs Data Hub deployment will streamline e-commerce imports."

The Commission frames the identifiers as a safety measure, "helping customs authorities detect and block unsafe or non-compliant goods." It points to inspections across the EU in 2025 in which "over 60% of checked products failed EU standards." In practice, an identifier lets customs match a parcel to a specific product, rather than relying on a free-text description such as "cosmetics" or "phone case."

Which parcels: the €150 limit

Amazon's notice says "all" B2C goods. The Commission's customs guidance on the €3 duty (version of 5 October 2026) is more precise. It says the requirement "applies to all goods sold in distance sales of imported goods with an intrinsic value not exceeding EUR 150 as from 1 November 2026." It adds that the Commission "is in the process of amending" the legal text "to clarify that the requirement only applies to goods with an intrinsic value not exceeding EUR 150," and that business-to-business shipments "are in principle not concerned."

Intrinsic value is not the same as what the customer paid. The guidance defines it as the price of the goods themselves, excluding transport and insurance costs "unless they are included in the price and not separately indicated on the invoice," and excluding other taxes and charges. So an order of €140 of goods with €20 of separately invoiced shipping is still in scope. Shipping that is built into the price and not shown separately does count, so only a consumer consignment whose intrinsic value is more than €150 on that basis falls outside this particular requirement. Your carrier or shipping software may still ask for the identifiers on every EU parcel, though, so check with them before you build two processes.

The guidance also confirms the timing. During the voluntary period from July 1, "no sanction, penalty or other measure could be imposed" for missing or incorrect data. "Effective enforcement starts from 1 November 2026."

If you have not caught up with the €3 duty side of the reform, we covered it in our post on the EU small parcel levy for Amazon sellers. The two measures are separate. The duty changes what a parcel costs. The identifiers change what data the parcel must carry.

Who is affected

Amazon's notice applies to "all EU Amazon stores." The people it addresses directly are developers whose software buys shipping labels or manages carrier integrations "for seller-fulfilled (Fulfilled by Merchant, FBM) orders shipped from outside the EU to EU destinations." In plain terms, that is you if:

• You are a UK seller who ships FBM orders to Amazon EU customers from a UK warehouse.
• You are a US or Asia-based seller who fulfils EU orders yourself, or through a 3PL, from outside the EU.
• You use a shipping tool, multi-channel order manager or 3PL portal that buys labels for those orders.

Amazon's changelog item is written for FBM. It does not describe any change to FBA, so do not read it as a statement about inventory you have already sent into an EU fulfilment centre.

If your EU orders all ship from stock held inside the EU, this particular notice is not about you, because those goods are not crossing the EU border on their way to the customer.

The three identifiers Amazon says to send

According to Amazon, "Your integration must supply three identifiers for each item":

• The ASIN, which Amazon calls the Merchant Product Identifier (M-PID). "Amazon adds this automatically on Buy Shipping label purchases."
• The manufacturer's part number or model number, the Non-Standard Product Identifier (NS-PID). Amazon adds: "If a product has neither, send a barcode number in its place."
• The Standard Product Identifier (S-PID), "for products that have one. Examples include EAN, GTIN, UPC, ISBN, and ISSN."

The trap is in the second one. Amazon says it "adds the ASIN automatically but does not add the part number, model number, or barcode from the product's listing, so your integration must send those." Even if your part number is already on your Amazon listing, Buy Shipping will not copy it onto the customs data for you.

Amazon describes the part or model number as required and the barcode fields as optional when you buy labels through Buy Shipping. If a product has no part or model number, Amazon says the barcode goes in that required field instead. The Commission's guidance only accepts that where the manufacturer uses its barcode as its product code, so check step 2 below before you rely on it.

Optional in Amazon's request is not optional for customs. The Commission's guidance says the merchant identifier and the manufacturer's identifier are the minimum, and "If it exists, the standardised PID shall be declared as well." If your product has an EAN, GTIN or UPC, send it. A label that goes through without one does not mean the declaration is complete. Where a product genuinely has no standard barcode, customs has a separate code for declaring that none exists, so ask your carrier or shipping software how they handle it.

Two shipping routes, two sets of rules

If you buy labels through Amazon Buy Shipping

This covers labels bought through Amazon's Shipping API and Merchant Fulfillment API, which many shipping tools use behind the scenes. Amazon says your integration "must send these identifiers on the label purchase request." It also warns that "Amazon applies no format validation and transmits the submitted values to the carrier as provided, so you are responsible for the accuracy of the information you submit."

Amazon's instructions to developers include: "If a request fails, show the seller the error and provide a field to enter the missing number. Do not submit placeholder values." If your shipping tool starts asking for a model number on November 1, that is why. Do not type "N/A" or "0000" to get past it.

If you send customs data to carriers directly

Many sellers ship EU orders on their own carrier accounts, or through a 3PL that does. Amazon says this path is also required from November 1, "including for labels purchased outside Amazon." Here, "Amazon does not receive or validate this data," so the responsibility sits with you and your carrier integration.

Amazon tells developers on this route to "Confirm the required fields and format with each carrier you support," to add the ASIN, the part or model number and the barcode number for each item to the customs data, and to check that "every item has a part or model number before the seller confirms the shipment."

Field names and formats vary by carrier. Ask yours directly which fields carry each identifier, and whether its customs data upload is ready.

What it costs if you get it wrong

The direct risk is a parcel that sits at the border or comes back. Amazon puts it bluntly: missing identifiers can cause a shipment to be held or returned "at the seller's expense."

The knock-on effects can hurt more. A parcel held in customs arrives late, if it arrives at all. A parcel that never reaches the customer can lead to a refund, an unhappy buyer and, potentially, negative feedback or an A-to-z claim. On a single order, the cost can include any extra carrier charges and the lost sale. Across a peak season of EU orders, it can turn a profitable marketplace into a losing one without anything showing up as a fee line.

That is worth checking at the SKU and marketplace level, not just at account level. Compare profit and refund rates by marketplace and SKU for your EU stores before and after November 1 to see whether the extra work still pays.

What to do this week

1. List the SKUs you ship FBM into the EU from outside it. Start with your last 90 days of EU FBM orders. That is your working list.
2. Collect a part or model number for each one. Check supplier invoices, packaging, spec sheets or your own catalogue. If a product genuinely has neither, Amazon lets you send its barcode instead. The Commission's guidance accepts that where the manufacturer uses its standard barcode (EAN or UPC) as its product code, so use the manufacturer's barcode. Do not substitute a retailer-only stock code such as your SKU. Otherwise the guidance expects the manufacturer or supplier to assign a product code. If you sell under your own brand, that may well be you, in which case a product code you assign as the manufacturer can serve; confirm it with your customs declarant or carrier.
3. Collect barcodes for every product that has one. EAN, GTIN or UPC. Amazon's Buy Shipping request marks them optional, but the Commission's guidance says an existing standard identifier must be declared.
4. Store them in one place your shipping tool can read. The goal is that nobody has to type a model number by hand at the packing bench.
5. Ask your shipping software vendor or 3PL one question: "Will you send the part or model number and barcode on EU-bound customs data from November 1, and where do I enter them?" Get a yes in writing.
6. Test a shipment before the deadline. The Commission notes PIDs could be declared voluntarily from July 1, 2026, so you can start sending them now rather than finding the gaps on November 1.
7. Decide what to do with SKUs you cannot fix in time. For some sellers, pausing EU FBM on those SKUs for a few days will cost less than parcels held or returned at customs. Weigh it against your own margins and volumes.

If you sell into the EU through several routes, this is also a good moment to look at your VAT and cross-border setup together. Our Amazon VAT management page covers the VAT side, and our guide to FBM requirements in the UK and Germany covers other seller-fulfilled rules for European marketplaces.

Key takeaways

• From November 1, 2026, EU customs requires product identifiers on goods sold to EU consumers from outside the EU in consignments with an intrinsic value of no more than €150 (separately invoiced shipping is excluded; shipping built into the price counts), per the European Commission's guidance. Amazon's SP-API changelog announces the same date with broader "all B2C goods" wording.
• Amazon's notice targets FBM orders shipped from outside the EU to EU customers, across all EU Amazon stores.
• Three identifiers per item: the ASIN, the manufacturer's part or model number (the same barcode can fill both fields only where the manufacturer uses it as its product code), and a standard product identifier such as an EAN, GTIN or UPC where one exists.
• Buy Shipping adds the ASIN automatically but not the part number, model number or barcode. You or your software must send those.
• If you send customs data to carriers yourself, Amazon does not check it. Missing identifiers can get a parcel held or returned at your expense.
• If a product has an EAN, GTIN or UPC, it must be declared, even where Amazon's API marks the field optional.
• Gather part numbers and barcodes for your EU FBM SKUs now, and confirm with your shipping tool or 3PL that they will transmit them.

Want to see whether your EU marketplaces are actually profitable once shipping, returns and fees are counted? Start a 21-day SellerLegend trial and look at the numbers by marketplace and SKU.

Sources

• Amazon Selling Partner API changelog: EU Customs Will Require Product Identifiers for FBM Shipments to the EU (October 21, 2026)
• European Commission, Taxation and Customs Union: Guidance and legal text on temporary flat fee on low-value imports (8 June 2026, updated 20 July 2026)
• European Commission: Customs guidance on the EUR 3 customs duty, section 8 on product identifiers (version of 5 October 2026)