From 1 November 2026, every B2C shipment 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? Are second-hand or personalized goods exempt?
We've collected the most common questions our customers are asking, with answers based on the EC Guidance.
| Short Name | Full Legal Name | What it is | Required |
|---|---|---|---|
| M-PID | Merchant Product Identifier | The unique listing or SKU ID assigned to the product by the online seller, marketplace, or platform. Typically the platform SKU or listing ID. | Always required: no exceptions |
| NS-PID | Non-Standardised Manufacturer Product Identifier | The manufacturer's own internal product reference: a model number, style code, or part number. No prescribed format. | Always required: no exceptions |
| S-PID | Standardised Manufacturer Product Identifier | An internationally recognised product code: typically an EAN-13, GTIN, UPC, or ISBN. | Required where it exists (C129). Where absent, exception code Y081 must be actively declared: silence is not acceptable |
Q1: Do PIDs apply only to shipments valued at €150 or less?
No. The €150 threshold applies only to the €3 temporary customs duty, which is a separate obligation. PIDs apply to all B2C distance sales into the EU regardless of consignment value. Legally speaking, as of today, a €10 shipment and a €500 shipment are treated identically. 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.
Q2: Can we put "none" for the NS-PID if the manufacturer does not have an internal reference?
No, and this is a common misunderstanding. Unlike the S-PID, there is no absence declaration for the NS-PID. It is mandatory with no exceptions. If a manufacturer does not currently have an internal product reference, they are required to assign one: no specific format, length, or character set is prescribed, so it can be as simple as a short alphanumeric code they create and formally adopt going forward. Entering "none," "N/A," or leaving the field blank is not a valid submission.
Q3: Can we leave the S-PID blank if the product has no EAN or barcode?
No. If no standardised code exists, exception code Y081 must be actively declared: silence or a blank field is not acceptable. Before FlavorCloud can declare Y081 on a merchant's behalf, the merchant must explicitly confirm in writing that no standardised code exists for that SKU.
Q4: 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. One confirmed exception: if the NS-PID is not available and cannot be obtained, the S-PID may be provided in its place (if it exists). The EC Guidance also confirms that a manufacturer may choose to use the S-PID as the NS-PID as a simplification, where both refer to the same standardised code. Whether M-PID and NS-PID could share the same value when the merchant is also the manufacturer. It is not explicitly forbidden by the EC Guidance, but has not been formally confirmed.
Q5: Can a Job Order be used as the NS-PID?
No, if JO refers to Job Order numbers tied to a specific production run. 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 requirement. Vendors need to assign a permanent product-level reference per SKU.
Q6: 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. If no NS-PID exists, the merchant should go back to their manufacturer and ask them to assign one. The format is entirely flexible.
Q7: Do PIDs apply to all our products, or only those we ship to Europe?
PIDs are required per SKU for all B2C distance sale shipments destined for any of the 27 EU Member States. There is no product-type exemption for mainstream consumer goods. Only 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, or 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.
Q8: We sell second-hand and personalized products: are we exempt?
No. Second-hand, refurbished, personalized, custom, and print-on-demand goods are not exempt. 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, the PID of the underlying good or service in the offer applies.
Q9: 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 shipments. A declaration missing a mandatory identifier can be held or rejected at customs validation.
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.
