From 1 November 2026, B2C distance sale shipments into the EU must carry three Product Identifiers (PIDs) per SKU on the customs declaration. Over the past few months, PIDs have come up in nearly every conversation we've had with our merchants, and many of the same questions keep surfacing: Does the €150 threshold matter? What if a product has no barcode? Who assigns the NS-PID? How do bundles and personalized goods work?
We've collected the most common questions our customers are asking, with answers based on the EC Guidance of 5 October 2026.
This is a live document, updated regularly as new regulatory guidance is published and new questions are received.
1. Overview & Scope
Q: What are the three EU Product Identifiers and what do they mean?
| Short Name | Full Legal Name | TARIC Code | Required |
|---|---|---|---|
| M-PID | Merchant Product Identifier | C127 | Always required: no exceptions |
| NS-PID | Non-Standardized Manufacturer Product Identifier | C128 | Always required: no exceptions |
| S-PID | Standardized Manufacturer Product Identifier | C129 (present) / Y081 (absent) | Required where it exists; Y081 where it does not |
Key rule: M-PID and NS-PID are mandatory with no exceptions and no absence declaration. S-PID must be declared as C129 where it exists or as Y081 where it does not: silence is never acceptable.
Q: Do PIDs apply only to shipments valued at €150 or less?
The PID requirement still applies to all B2C distance sales of imported goods. There is no value threshold in the underlying legal obligation.
However, the EC Guidance published on 5 October 2026 introduces an administrative tolerance clarifying that the requirement is being interpreted by reference to consignments with an intrinsic value not exceeding €150, and the Commission is in the process of formally amending Annex B of the UCC-DA (Union Customs Code Delegated Act) to reflect this. Member States are expected to apply this tolerance in the interim.
It is important to stress that this does not reduce or suspend the obligation for merchants. The vast majority of e-commerce shipments into the EU fall within the ≤€150 range, and a single order containing multiple products (for example a €14 item and a €9 item in the same consignment) remains fully in scope. Merchants must proceed on the basis that full PID compliance is required for their catalogue.
The only meaningful exclusion is B2B: transactions to VAT-registered businesses where the recipient's VAT number is present on the declaration fall outside the distance sale definition under Article 14(4)(2) of the VAT Directive and are not subject to the PID requirement.
Q: What is a distance sale, and does it include B2B shipments?
Distance sales are defined in Article 5(15) of the new Union Customs Code (Regulation (EU) 2026/2108) by reference to Article 14(4)(2) of the VAT Directive (Council Directive 2006/112/EC) as supplies of goods dispatched or transported by or on behalf of the supplier from a third country to a customer in a Member State, where the supply is carried out for a non-taxable person.
B2B transactions: where the recipient is a VAT-registered business and their VAT number is present on the customs declaration (these fall outside this definition and are not subject to the PID requirement).
Q: Do PIDs apply to all our products, or only those we ship to Europe?
PIDs are required per SKU (Stock Keeping Unit) for all B2C distance sale shipments destined for any of the 27 EU Member States where the consignment value does not exceed €150. There is no product-type exemption for mainstream consumer goods, the full set of three PIDs applies across the board.
A very limited number of specific product categories benefit from simplified treatment under the EC Guidance: unprocessed agricultural and perishable goods, handmade and artisanal goods under specific commodity codes, antiques and collectibles, and certain healthcare products and medical devices with specific S-PID rules. These are narrow exceptions that do not apply to the vast majority of e-commerce products. All merchants should proceed on the basis that full PID compliance is required for their catalogue where shipments are ≤€150.
Q: When does this become mandatory?
PIDs could be provided voluntarily from 1 July 2026 with no penalties. From 1 November 2026, they are mandatory for all qualifying shipments. A declaration missing a mandatory identifier can be held or rejected at customs validation.
2. The Three PIDs: Rules and Requirements
Q: Can we put "None" for the NS-PID if the manufacturer does not have an internal reference?
No.
The NS-PID (Non-Standardized Manufacturer Product Identifier) is mandatory with no exceptions and has no absence declaration mechanism. If no NS-PID currently exists, the manufacturer must assign one - no specific format is required. Entering "None," "N/A," "TBC," or any other placeholder is not acceptable as these would be transmitted as real identifiers, constituting an inaccurate declaration. Leaving the field blank is equally unacceptable.
Q: Can we leave the S-PID blank if the product has no EAN (European Article Number) or barcode?
No. Where no standardized code exists, exception code Y081 must be actively declared. Before FlavorCloud can declare Y081 on a merchant's behalf, the merchant must explicitly confirm in writing that no standardized code exists for that SKU. Silence or a blank field is not acceptable.
Q: Do the three PID values have to be different from each other?
The general rule is that all three should be different, as each serves a distinct purpose. Two confirmed exceptions exist per the October 5th EC Guidance (Section 8.7):
- A manufacturer may use the S-PID also as the NS-PID: in which case C128 and C129 carry the same value
- An online platform may use the S-PID also as the M-PID: in which case C127 and C129 carry the same value
In both cases, both TARIC (Integrated Tariff of the European Union) document codes must still be declared separately even when the value is identical. The guidance explicitly notes these scenarios are not frequent in practice, and the default expectation remains three genuinely distinct values assigned independently by the merchant, the manufacturer, and the standardization body respectively.
Q: Can the merchant assign the NS-PID if the manufacturer does not have one?
No. The NS-PID must be assigned by the manufacturer, producer, or product supplier; but not the merchant. If no NS-PID exists, the merchant should go back to their manufacturer and ask them to assign one. The format is entirely flexible: no specific structure is required.
Q: Our vendors use Job Order (JO) numbers: can these be used as the NS-PID?
If JO refers to Job Order numbers tied to a specific production run, no. The NS-PID must identify the product at model/variant level and remain stable across its entire life, regardless of production run. A Job Order number is a batch-level reference that changes with each production cycle, which does not meet the requirements. Vendors need to assign a permanent product-level reference (a model number, style code, or part number) per SKU.
Q: We sell second-hand and personalized products: are we exempt?
No. Second-hand, refurbished, personalized, custom, and print-on-demand goods are not exempt from the EC Guidance (Section 8.8). Full PID compliance is required:
- For second-hand goods: the PID of the original product must be provided
- For personalized textiles: the PID of the underlying textile applies
- For print-on-demand goods (for instance, a mug with a photo or custom text printed on it): the PID of the underlying goods or service in the offer applies
Q: At what level must PIDs be declared: per consignment, per order, or per product?
Per product variant. The EC Guidance (Section 8.3) is explicit that each PID must refer to exactly one product variant: same brand, size, colour, packaging.
Where one declaration line groups several products (for example a bundle), the PID set of each product must be reported separately as a repetition of the supporting document data element. Products are never merged into one identifier set.
Q: Can PIDs change over time: for example, when a product is relaunched or repackaged?
No, persistence is one of the core characteristics of all PIDs. The EC Guidance (Section 8.3) states that the identifier must remain unchanged throughout the product's lifecycle, at least from manufacturing through offer for sale to delivery, and possibly up to end of life. Most PIDs do not change when moving between economic operators, warehouses, or platforms. Where a product is genuinely a new variant (different size, colour, or packaging) a new PID set is appropriate. Where it is the same product under a different commercial presentation, the original PID must be maintained.
Q: Are there any restrictions on the characters or length that can be used in PID values?
No specific restrictions are imposed by the regulation. The EC Guidance (Section 8.7) notes that as declarations are processed by national customs systems, acceptance of special characters may vary by Member State. Where a national system does not accept certain special characters, the most equivalent accepted character may be substituted. In practice, letters, digits, hyphens, full stops, slashes, and underscores are broadly accepted. As a general rule, avoid pasting values from formatted documents as these may introduce invisible characters that cause validation errors.
Q: Are sectoral identifiers such as the Digital Product Passport, EUDR (EU Deforestation Regulation) Due Diligence Statement reference, or CPNP (Cosmetic Products Notification Portal) number accepted as PIDs?
No, these are distinct from the PID requirement. The EC Guidance (Section 8.3) draws a clear distinction between PIDs created pursuant to sectoral legislation and PIDs defined by economic operators for operational or supply chain purposes. Sectoral identifiers such as the Digital Product Passport, EUDR Due Diligence Statement reference, or CPNP reference do not replace or substitute for the M-PID or NS-PID under the new PID requirement. They follow their own separate TARIC rules where applicable.
3. Specific Product Scenarios
Q: Can we use a prefix before our SKU as the NS-PID: for example AB-TEE1001?
Yes, the NS-PID is entirely free format. The EC Guidance imposes no rules on length, character type, or composition.
Using a prefix before an existing reference is a valid approach, provided the result meets the core conditions:
- uniqueness (one identifier per product variant),
- persistence (stable across the product's life and across production runs), and
- model/variant level granularity (not batch, lot, or serial number level).
The manufacturer must formally adopt it as their permanent product reference going forward.
Q: We make custom apparel using blank garments from various suppliers. What is the NS-PID?
The blank garment manufacturer's internal product reference is the NS-PID. The EC Guidance (Section 8.8) is explicit that for personalized textiles, the PID of the underlying textile must be provided, not a reference to the artwork or customization applied.
For new products, capture the blank manufacturer's style or model code at the time of sourcing.
For existing products where this data is not available, the manufacturer should be contacted to confirm or assign their internal reference.
Where a manufacturer has genuinely never assigned one, the EC Guidance requires them to create one: no specific format is required.
Q: For posters, stickers, and other paper goods, the printer may not have a manufacturer's ID. What do we use?
The printer or paper goods supplier is the manufacturer for PID purposes and is expected to have or assign an internal product reference for their stock. Where a supplier has never formally assigned one, the EC Guidance requires them to create one (no specific format is required). Contact your print suppliers and ask them to confirm or assign an internal reference for the specific stock used per product.
Q: For our in-house merchandise, we do not register with a global system. What is the S-PID and how do we declare it?
Where no standardized code (EAN (European Article Number), GTIN (Global Trade Item Number), UPC (Universal Product Code), ISBN (International Standard Book Number)) has been assigned, the S-PID is declared as absent using TARIC exception code Y081.
FlavorCloud handles this declaration on your behalf: what we need from you is explicit written confirmation per SKU that no standardized code exists.
For the NS-PID on your own in-house merchandise: since you are the manufacturer, you are the party responsible for assigning the NS-PID. You can use your own internal product reference or SKU, provided it identifies the product at model/variant level and you formally adopt it as your permanent manufacturer reference.
Q: For physical media purchased wholesale from record labels, we cannot reach the manufacturer to get the NS-PID. What can we do?
We recommend requesting the internal product reference through your wholesale buyer contact at the record label. Where obtaining the NS-PID proves genuinely impossible despite reasonable efforts, the EC Guidance (Section 8.7) confirms that the S-PID may be used as the NS-PID as a simplification, meaning you would declare the UPC in both C128 (NS-PID) and C129 (S-PID) fields. Both codes must still be declared separately even when the value is identical.
This is acceptable but we would encourage you to continue pursuing the correct NS-PID from the label as a parallel workstream.
Q: Can we use the ISBN as the NS-PID?
Yes, this is explicitly confirmed in the EC Guidance (Section 8.7). A manufacturer or product supplier may decide to use the S-PID also as the NS-PID to simplify their operations, and the guidance states this is perfectly acceptable. The ISBN qualifies as an S-PID and may be submitted in both C128 (NS-PID) and C129 (S-PID) fields where no separate internal manufacturer reference exists.
Both codes must still be declared separately. This decision must be made by the manufacturer and not applied by the merchant on their behalf.
Q: For bundled products sold under one SKU, do we need PIDs for each product inside the bundle?
Yes. The EC Guidance (Section 8.7) is explicit: each distinct product within a bundle must carry its own NS-PID and S-PID, declared as separate repetitions under the same declaration line.
The bundle SKU serves as the M-PID for the line as a whole.
For the S-PID, Y081 should only be declared where none of the grouped products has a standardized code. Where at least one product in the bundle has an S-PID, that S-PID must be reported.
Q: For a multipack of the same product, should we use the product's standardized code or declare None?
Use the product's standardized code (EAN, UPC, ISBN etc.) a multipack of identical items is a single product variant. The single product's identifiers apply regardless of quantity and Y081 does not apply where the product has a standardized code.
Q: For medical devices, what is the correct S-PID to declare?
The EC Guidance (Section 8.8) provides specific rules per device type:
- Medical devices under MDR (Medical Device Regulation) 2017/745 or IVDR (In Vitro Diagnostic Regulation) 2017/746 with a UDI-DI (Unique Device Identifier - Device Identifier): the UDI-DI is deemed to be the S-PID
- Legacy devices not yet subject to UDI-DI until 27 November 2026: the CELEX number of the applicable legal act must be provided: 32017R0745 for MDR or 32017R0746 for IVDR
- Other medical devices not subject to UDI-DI: any other S-PID where it exists, otherwise Y081
- Medicinal products and OTC (Over The Counter) pharmaceuticals under Directive 2011/62/EU: the product code (AI 01) may be used as S-PID
The guidance specifically calls out that customs will endeavor to carry out speedy controls on medical consignments to avoid interrupting treatment regimes for patients depending on repeat or subscription-type shipments.
Q: The EC Guidance mentions that PIDs are the first step in a broader product data requirement. What comes next?
The PID requirement is the first tranche of a broader product dataset obligation that will expand significantly from 1 July 2028, when the EU Customs Data Hub for e-commerce is deployed under the new Union Customs Code (Regulation (EU) 2026/2108).
From that date, customs authorities will require a much more comprehensive set of data for every distance sale shipment into the EU, including:
- Identity of the importer, seller, buyer, manufacturer, and product supplier
- Identity of the responsible economic operator in the EU under applicable product safety legislation
- Product value, origin, tariff classification, and description
- Unique consignment reference and location
- Compliance status with all relevant EU legislation applied by customs authorities
This means the data infrastructure merchants are building today for PIDs (manufacturer references, standardized codes, product-level identifiers) is not a one-off exercise. It is the foundation of a significantly broader product data requirement coming in 2028. Merchants who invest in clean, accurate product data now will be better positioned for what follows. FlavorCloud will communicate further guidance as the 2028 milestones approach.
The takeaway: every SKU you ship to EU consumers needs complete, valid PIDs by 1 November 2026. Blank fields and placeholders are not accepted, and a declaration missing a mandatory identifier can be held or rejected at customs validation.
If your catalogue has gaps, start with your suppliers now. NS-PIDs must come from the manufacturer, and collecting them across a large catalogue takes time.
FlavorCloud's compliance-ready Cross-Border Commerce OS helps merchants manage PID requirements at scale so EU orders keep moving after the deadline. Talk to our team to check your catalogue's readiness.
