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Low-value imports — consignments entering the EU below the EUR 150 customs duty de minimis threshold — have been the operational foundation of the direct-from-China e-commerce model that Temu, Shein, AliExpress, and thousands of individual sellers have used to ship goods to European consumers without paying the import duties that EU-established retailers and Amazon FBA sellers pay on every commercial shipment. That foundation is being systematically dismantled. Five converging regulatory changes — spanning customs duty exemptions, product safety requirements, data reporting obligations, VAT enforcement, and platform liability — are transforming the compliance cost structure of low-value imports into the EU in ways that will make the direct-from-China parcels model significantly more expensive to operate and significantly more legally risky to ignore.
For Amazon FBA sellers who import goods into the EU through a licensed fulfillment partner and pay full customs duty on every commercial shipment, these regulatory changes represent a competitive rebalancing rather than a threat: the cost disadvantage that compliant EU importers have absorbed relative to de minimis direct-from-China sellers is being reduced by regulation rather than by market forces. But understanding the five regulatory changes in detail matters for FBA sellers too — because several of them impose new compliance obligations on sellers whose import model already pays full duty, particularly around product safety documentation, IOSS registration, and platform-level VAT reporting that affects every seller on Amazon regardless of their import model.
This guide covers the five regulatory changes affecting low-value imports into the EU in 2025 and 2026, with specific focus on what each change means for Amazon sellers using EU fulfillment infrastructure and how the compliance requirements interact with the FBA operational model.
1. EU De Minimis Duty Exemption Reform: The EUR 150 Threshold Under Legislative Pressure
The EUR 150 customs duty de minimis threshold — established under EU Customs Code Article 23 — allows goods with a customs value at or below EUR 150 to enter the EU without payment of import duties. Since the VAT de minimis exemption was abolished in July 2021 (all consignments now attract VAT regardless of value, either through IOSS at point of sale or at importation), the duty exemption at EUR 150 is the sole remaining financial benefit of low-value import status. The European Commission's customs reform package, building on the European Parliament's resolutions calling for threshold reduction or elimination, proposes to remove duty relief for goods sold through online platforms — preserving it only for genuine personal consignments — with full legislative implementation targeted for 2028 at the latest under the current reform timeline.
The practical effect of de minimis duty elimination on a direct-from-China seller shipping EUR 120 clothing items to German consumers is a duty cost of 12 percent of customs value — EUR 14.40 per consignment — applied to shipments that currently enter duty-free. At the volume that Temu and Shein operate, this is a billion-euro annual cost increase across their EU shipment base. For individual sellers shipping low-value goods directly from Chinese warehouses to EU consumers, duty elimination on a EUR 80 electronics accessory at 3.7 percent duty adds EUR 2.96 per unit — a margin impact that many low-price-point direct-from-China products cannot absorb without price increases that reduce their competitiveness against EU-warehoused alternatives. Landed cost comparison: direct-from-China vs EU pre-stocked fulfillment calculates the landed cost differential between direct-from-China low-value shipments under current and post-reform duty regimes against the landed cost of the same goods imported commercially through a EU fulfillment center — quantifying the competitive gap that de minimis reform closes and the point at which EU pre-stocking becomes the lower total cost model even before the convenience and availability advantages of EU-warehoused inventory are factored in.
2. General Product Safety Regulation: Full Compliance Required for All EU Imports from August 2024
The EU General Product Safety Regulation (GPSR) — Regulation (EU) 2023/988 — replaced the General Product Safety Directive from 13 August 2024, introducing significantly stricter requirements for all consumer products sold in the EU market regardless of their value, origin, or sales channel. GPSR applies to every product sold to EU consumers, including low-value imports arriving as individual parcels under the de minimis threshold: the EUR 150 customs duty exemption provides no relief from GPSR compliance obligations, which are product safety requirements rather than customs or fiscal measures.
The GPSR requirements most directly affecting low-value import sellers are: the mandatory EU-established responsible person requirement (every product sold in the EU must have an EU-established economic operator — manufacturer, importer, authorised representative, or fulfilment service provider — whose name and address appears on the product or packaging and who can be contacted by market surveillance authorities); the product traceability requirement (a unique product identifier linking each product to its technical documentation and risk assessment); and the online marketplace obligation (platforms including Amazon must verify that third-party sellers have an identifiable EU responsible person before listing their products). Low-value imports arriving as individual parcels from China without GPSR-compliant labelling and an EU responsible person are non-compliant consumer products regardless of their customs value — and Amazon is increasingly enforcing GPSR listing requirements by suppressing listings that do not demonstrate responsible person compliance. GPSR compliance integration in EU fulfillment and FBA prep implements the responsible person documentation, product labelling verification, and traceability record management that GPSR requires for every product processed through the fulfillment center — ensuring that FBA prep includes the GPSR compliance check that Amazon's listing requirements and EU market surveillance authorities expect from EU-established economic operators handling consumer goods.
3. IOSS Enforcement Tightening: Customs Cross-Checks Now Operational in Major EU Member States
The Import One Stop Shop (IOSS) — the VAT simplification scheme that allows sellers to collect VAT at point of sale on consignments below EUR 150 dispatched to EU consumers and remit it through a single monthly IOSS return — has been operational since July 2021. In 2025 and 2026, the enforcement infrastructure that validates IOSS use has matured to the point where customs authorities in Germany, France, and the Netherlands are performing automated cross-checks between IOSS numbers declared on customs entries and the IOSS registration database — identifying invalid, expired, or incorrectly applied IOSS numbers on individual parcel declarations in real time rather than through post-clearance audit.
The consequences of IOSS non-compliance have also tightened: consignments declaring an invalid IOSS number at the EU border are now being held for VAT collection at importation rather than released on the basis of the declared IOSS number and followed up later. For sellers using third-party IOSS numbers provided by marketplaces or logistics intermediaries — a common arrangement where the marketplace collects and remits IOSS VAT on the seller's behalf — the IOSS number must be correctly transmitted from the marketplace's system to the customs pre-notification data for every individual parcel. Transmission failures that result in a consignment arriving at a German or French customs point without a valid IOSS number generate the import VAT collection that the IOSS was designed to avoid, plus the administrative burden of reclaiming the double-charged VAT from the customs authority. IOSS number transmission and customs pre-notification accuracy validates the IOSS number in the customs pre-notification data for every inbound low-value consignment before the shipment departs origin — catching the transmission errors and number validity issues that generate customs holds and double VAT charges at the EU border before the consignment is in transit and the correction window has closed.
4. DAC7 Platform Reporting: Customs Authorities Now Have Seller Transaction Data from Marketplaces
DAC7 — Council Directive (EU) 2021/514 on administrative cooperation in taxation, operational from January 2023 — requires digital platforms to report seller transaction data to EU tax authorities annually. For Amazon sellers, DAC7 reporting means that German, French, and other national tax authorities receive annual reports from Amazon containing each seller's EU transaction volume, gross revenue by member state, and identification data linking the Amazon account to the seller's tax registration. The 2026 enforcement cycle represents the third consecutive year of DAC7 data, giving tax authorities a multi-year transaction history for every active Amazon seller — sufficient to identify VAT registration gaps, OSS filing inconsistencies, and low-value import VAT non-compliance patterns that single-year data could not establish conclusively.
The specific DAC7 enforcement risk for low-value import sellers is the cross-check between reported transaction volumes and IOSS registration status. A seller shipping 50,000 low-value consignments per year to EU consumers without an IOSS registration — relying on the marketplace's IOSS number without verifying the correct application — generates a DAC7 record of 50,000 transactions that the tax authority can cross-reference against IOSS returns to determine whether VAT is being correctly accounted for on each consignment. Where the DAC7 transaction volume materially exceeds the IOSS-reported consignment volume for the same seller, the discrepancy identifies the VAT gap that enforcement action recovers. Transaction volume reconciliation for IOSS and DAC7 compliance reconciles the seller's IOSS-reported consignment data against the transaction record that DAC7 reporting captures — identifying the categories of transactions that IOSS is covering, the categories that are being incorrectly excluded, and the volume discrepancies that DAC7 cross-checking would flag before the tax authority performs the same reconciliation and initiates an enforcement enquiry.
5. ViDA Deemed Supplier Extension: Platforms Become the VAT Collector for All EU Sales from 2027
The EU's VAT in the Digital Age (ViDA) package — formally adopted by the EU Council in 2024 — extends the deemed supplier rule that currently applies to non-EU sellers on digital marketplaces to cover all marketplace-facilitated sales in the EU regardless of seller location. From the ViDA implementation date for this pillar (targeted for 2027), Amazon and other platforms will be deemed to have made the VAT-able supply to the EU consumer for every sale facilitated through their marketplace — collecting and remitting VAT themselves rather than the seller, and issuing a B2B supply to the seller at the zero VAT rate. This structural change removes the seller from the VAT collection chain for direct-to-consumer EU sales through marketplaces, transferring the VAT compliance obligation and liability to the platform.
For low-value import sellers, the ViDA deemed supplier extension eliminates the VAT compliance gap that currently exists when sellers ship below-EUR-150 consignments without valid IOSS registration — because the platform will collect VAT at point of sale for all transactions regardless of value, and the seller's IOSS registration becomes irrelevant for marketplace sales. However, ViDA does not affect customs duty obligations: the EUR 150 duty de minimis (if it still exists post-reform in 2027) will continue to apply at the border regardless of the platform's VAT collection. The interaction between ViDA deemed supplier VAT collection and de minimis duty reform creates a compliance environment where VAT is platform-managed but duty compliance remains the seller's (or their EU representative's) responsibility for every consignment entering the EU. Preparing fulfillment operations for ViDA deemed supplier implementation plans the operational changes that ViDA's deemed supplier extension requires in the fulfillment workflow — adapting invoice generation, VAT accounting, and customs documentation processes to reflect the platform-collected VAT model that ViDA introduces, while maintaining the import duty compliance documentation that remains the seller's obligation regardless of the VAT collection structural change.
The EU Is Closing the Compliance Gaps That Once Favoured Low-Value Import Sellers
The five regulatory changes covered in this guide — de minimis duty reform, GPSR product safety compliance, IOSS enforcement tightening, DAC7 transaction cross-checking, and ViDA deemed supplier extension — are not isolated policy adjustments. They are components of a coordinated EU regulatory programme that is progressively closing the compliance gaps that have allowed direct-from-China low-value import sellers to operate in the EU market at lower cost than EU-compliant importers who pay full duties, meet product safety requirements, and maintain accurate VAT reporting. The timeline for full implementation of all five changes runs through 2028, but the enforcement consequences of non-compliance with the changes already in effect — GPSR from August 2024, IOSS enforcement, and DAC7 cross-checking — are active now.
FLEX Fulfillment provides the EU-established fulfillment infrastructure that positions sellers correctly in the post-reform regulatory environment: commercial import through a licensed German customs broker with full duty payment, GPSR-compliant responsible person documentation and product labelling verification during FBA prep, and inventory location tracking across EU member states that supports accurate VAT registration, IOSS reconciliation, and DAC7-consistent transaction reporting — the compliance foundation that low-value import reform is making the baseline requirement for every seller operating in the EU market.
Located in the center of Europe, FLEX Fulfillment provides FBA prep, EU customs clearance, GPSR compliance support, and pan-European fulfillment for Amazon sellers navigating the regulatory changes affecting low-value imports into Germany and the EU in 2026.
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