TECHNICAL GUIDE
Product Identifiers for Fashion Brands: Customs PIDs from 1 November 2026, the GTIN and the DPP Identifier
From 1 November 2026, customs declarations for goods sold online from outside the EU to consumers in the EU must carry product identifiers for each item — up to three of them: one assigned by the merchant and one or two assigned by the manufacturer. Separately, once an ESPR delegated act that requires a passport applies to a product group, its products need a Digital Product Passport (DPP) connected to a persistent unique product identifier, and the Ecodesign for Sustainable Products Regulation (ESPR) already names the Global Trade Identification Number (GTIN) among the data a passport may contain.
These identifiers have different legal bases, owners and jobs. This guide sets out what each one is, who assigns it, at which level and from when — the three customs product identifiers, the DPP's identifiers, the registry's registration identifier and what online offers already have to show — and how to assign identifiers once and reuse them. It relies only on the EU's legal texts and the Commission's own guidance; the QR-code side is covered in our data-carrier guide.
1 Nov 2026
Product identifiers become mandatory for each item of goods sold in distance sales of imported goods (Delegated Regulation (EU) 2026/1022, Article 2(3)); operators may provide them voluntarily from 1 July 2026.
3 identifiers
The merchant product identifier, the non-standardised manufacturer product identifier and — where one exists — the standardised manufacturer product identifier.
EN 18219
The harmonised standard "Digital product passport – Unique identifiers", cited in the Official Journal on 15 July 2026 (Implementing Decision (EU) 2026/1736).
1. What customs will ask for from 1 November 2026
Delegated Regulation (EU) 2026/1022 amended the detailed customs rules in Delegated Regulation (EU) 2015/2446. It added five definitions to Article 1 of that Regulation (points (57) to (61)) and a new data requirement in Annex B for the data element "Supporting document" (12 03 000 000): the three identifiers "shall be provided for each item regarding goods sold in distance sales of imported goods", in the declaration columns H1, H6 and H7 (Annex, point (2)(a)). The requirement applies from 1 November 2026; operators may provide the data voluntarily from 1 July 2026 (Article 2(3)). The wording of this requirement sets no value limit, and the Commission's Q&A of 30 June 2026 reads it that way. The Commission's guidance of 5 October 2026, however, states that the requirement applies to goods in consignments with an intrinsic value not exceeding EUR 150, and that the Commission is amending Annex B to clarify this.
Distance sales are defined by reference to Article 14(4), point (2), of the VAT Directive — essentially goods dispatched from outside the EU to consumers in the EU. Ordinary wholesale imports for EU retailers are not covered. The definitions, as added to Delegated Regulation (EU) 2015/2446:
| Identifier | Definition (Article 1 of Delegated Regulation (EU) 2015/2446, as amended) | Assigned by | Required |
|---|---|---|---|
| Product identifier — point (57) | "a unique alphanumeric code assigned to a specific model, batch or article", at any packaging level, ensuring its identification and traceability at every stage of the supply chain | — | — (general definition) |
| Merchant product identifier — point (58) | "a product identifier assigned by an online seller, marketplace or platform" | Online seller, marketplace or platform | Always |
| Non-standardised manufacturer product identifier — point (59) | A product identifier assigned by a manufacturer, producer or product supplier "which does not rely on internationally recognised standards" | Manufacturer, producer or product supplier | Always |
| Standardised manufacturer product identifier — point (60) | A product identifier assigned by a manufacturer, producer or product supplier "which relies on internationally recognised standards" | Manufacturer, producer or product supplier | "if it exists for the item" |
An "item" means goods in a consignment sharing the same tariff classification, description and, where declared, origin (point (61)). The rule sits in a delegated act adopted under the current Union Customs Code; such acts continue to apply until they are repealed by acts adopted under the new Code (Regulation (EU) 2026/2108, Article 284(1)); see our guide to the new Customs Code.
2. How the Commission expects the identifiers to work
The Commission's guidance for Member States and trade on the EUR 3 duty (version of 5 October 2026) explains the requirement in detail. It is a Commission services document, not law; the binding rules are those in the Delegated Regulation. Its main points:
| Topic | What the Commission's guidance says |
|---|---|
| Purpose | Better risk management in e-commerce: identifiers let customs extend the result of a control on one product to all products that present a similar risk. The guidance calls the requirement a first step, to be complemented by more comprehensive product data once the EU Customs Data Hub for e-commerce is deployed from July 2028. |
| Merchant identifier | Assigned by the operator that organises the offer for distance sale; expected to be unique on each website, marketplace or platform, whatever the number of sellers offering the product there. |
| Non-standardised manufacturer identifier | Assumed to exist for every product; where none exists, the manufacturer, producer or product supplier is expected to assign one, with no required structure. It may also use its standardised identifier as the non-standardised one. |
| Standardised manufacturer identifier | Names the EAN (European Article Number) as the most common in Europe. There is no obligation to have one; where none has been assigned, an exception code is declared. |
| Level | Each identifier should refer to exactly one product variant (same brand, size, colour, packaging). Deliberately reporting batch- or unit-level identifiers where a model-level identifier exists is considered contrary to the objective of the requirement and thus an infringement. |
| Declaration codes | Document codes C127 (merchant), C128 (non-standardised manufacturer) and C129 (standardised manufacturer), declared in data element 12 03 000 000 (Supporting document); where no standardised identifier exists, code Y081 is declared in data element 12 04 (Additional reference type). Where an item covers several products, the identifiers of each product are reported. |
| Who reports | The declarant. For consignments up to EUR 150, under the declarant cascade, usually the IOSS holder, the special-arrangements operator, their indirect customs representative or the importer's indirect customs representative. Merchants and manufacturers are expected to pass their identifiers along the supply chain so they reach the declarant. |
| Second-hand and personalised goods | No special treatment: for a second-hand product, the identifier of the original product; for a textile personalised with a logo or name, the identifier of the underlying textile. |
Why accuracy matters
Under the current rules, the person lodging a customs declaration is responsible for the accuracy and completeness of the information in it, as the guidance recalls. From 21 September 2027, the new Union Customs Code requires Member States to penalise at least the "failure to comply with the obligation to provide or make available complete and accurate data to customs authorities in accordance with customs legislation" (Regulation (EU) 2026/2108, Article 274(1)(b)).
3. The DPP's own identifiers
The ESPR defines the unique product identifier as "a unique string of characters for the identification of a product that also enables a web link to the digital product passport" (Article 2, point (30)). The passport "shall be connected through a data carrier to a persistent unique product identifier" (Article 10(1)(a)), and each delegated act decides whether the passport is established at model, batch or item level (Article 9(2)(d)). The ESPR also defines a unique operator identifier for actors in the value chain and a unique facility identifier for locations or buildings (Article 2, points (31) and (33)).
Annex III lists the data a delegated act may require or allow in a passport. Besides the unique product identifier at the level the delegated act indicates (point (b)), it includes "the Global Trade Identification Number as provided for in International Organization for Standardisation/International Electrotechnical Commission standard ISO/IEC 15459-6 or equivalent of products or their parts" (point (c)), commodity codes such as the TARIC code (point (d)), the manufacturer's and other operators' unique operator identifiers, unique facility identifiers, and the importer's EORI number (points (g) to (j)). The data carrier, the unique product identifier, the unique operator identifiers and the unique facility identifiers must, where relevant, comply with the ISO/IEC 15459 series (Annex III, second paragraph); Article 10(1)(c) requires the data carrier and the unique product identifier to comply with one or more of those standards "or equivalent European or international standards until the references of harmonised standards are published in the Official Journal of the European Union". On that wording, the time limit was reached on 15 July 2026, when the references of EN 18219 (unique identifiers) and EN 18220 (data carriers) were published (Implementing Decision (EU) 2026/1736).
Since 15 July 2026, the Official Journal has cited EN 18219:2026, "Digital product passport – Unique identifiers", among six harmonised standards for digital product passports (Implementing Decision (EU) 2026/1736). A passport that conforms to cited harmonised standards is presumed to meet the requirements of Articles 10 and 11 to the extent those standards cover them (ESPR Article 41(2)).
Not the same identifier
The registry adds a third kind of number. When the operator uploads the passport's identifiers, the registry returns "a unique registration identifier associated with the unique identifiers uploaded in the registry" (ESPR Article 13(5)). That registration identifier — together with the commodity code — is what customs will, as a minimum, check against the registry before release, once the registry is interconnected with customs systems (Article 15). It is not the unique product identifier, and the registry's communication is not proof of compliance. Our customs guide covers that check.
4. What online offers already have to show
Independently of customs, the General Product Safety Regulation (EU) 2023/988 requires every offer made online or through other distance sales to indicate clearly and visibly, among other things, "information allowing the identification of the product, including a picture of it, its type and any other product identifier" (Article 19, point (c)). Once a DPP applies, the operator placing a product on the market must also give dealers and online marketplaces a digital copy of the data carrier or the unique product identifier, as relevant — on request, that copy or a webpage link, free of charge, promptly and in any event within five working days — so that customers who cannot physically access the product can reach the passport (ESPR Article 10(3)). For a brand selling through marketplaces, product identifiers already travel with every listing; from 1 November 2026, they also have to reach customs for distance sales of imported goods.
5. One identifier strategy
Mapped side by side, the identifiers look like this:
| Identifier | Legal basis | Assigned or issued by | Level | From |
|---|---|---|---|---|
| Merchant product identifier | Delegated Regulation (EU) 2015/2446, Article 1, point (58) | Online seller, marketplace or platform | One per product, unique on each website, marketplace or platform (Commission guidance) | 1 November 2026, distance sales |
| Non-standardised manufacturer product identifier | Point (59) | Manufacturer, producer or product supplier | One per product variant (brand, size, colour, packaging) — not batch or unit where a model-level identifier exists (Commission guidance) | 1 November 2026, distance sales |
| Standardised manufacturer product identifier (e.g. EAN, per Commission guidance) | Point (60) | Manufacturer, producer or product supplier | One per product variant — not batch or unit where a model-level identifier exists (Commission guidance) | 1 November 2026, where it exists |
| DPP unique product identifier | ESPR Article 2, point (30); Article 10(1)(a) | The actors the delegated act designates to create the passport (Article 9(2)(g)) | Model, batch or item, as the delegated act specifies | When a delegated act for the product group applies |
| GTIN (as passport data) | ESPR Annex III, point (c) | — | Products or their parts | Only if a delegated act requires or allows it |
| Unique registration identifier | ESPR Article 13(5) | Issued by the DPP registry | Per registered product | On registration |
| Commodity code | ESPR Article 13(1) and 15(2); Annex III, point (d) | Tariff classification of the product | — | Stored in the registry for products intended for release for free circulation |
On the texts as they stand, the customs identifiers and the DPP identifier are separate obligations: the first are operational codes reported in e-commerce declarations from 1 November 2026, the second is a persistent identifier that must link to a passport at the level a future delegated act sets. Whether a textile passport will use the GTIN, at which level its unique product identifier will sit and which data carrier it will use are for the textile delegated act to decide (Article 9(2)). What can be done now is to keep one clean, persistent identifier per product variant in your master data — never per batch or unit where a variant-level code exists — pass it consistently to platforms and declarants, and build any future passport identifiers to the cited harmonised standards.
DPP AUDIT
One clean identifier per product variant, reused consistently.
Customs declarations, marketplace listings and a future passport all draw on the same product master data. We help you structure it once, correctly. Under NDA.
Start Your DPP Audit6. Timeline
| Date | What happens | Source |
|---|---|---|
| 1 July 2026 | Product identifiers may be provided voluntarily; declaration codes available | Delegated Regulation (EU) 2026/1022, Article 2(3); Commission guidance |
| 15 July 2026 | EN 18219:2026 (unique identifiers) and five other DPP standards cited in the Official Journal | Implementing Decision (EU) 2026/1736 |
| 1 November 2026 | Product identifiers mandatory for each item of goods sold in distance sales of imported goods | Delegated Regulation (EU) 2026/1022, Article 2(3) |
| Second half of 2027 (indicative) | Adoption of the ESPR delegated act for textiles (apparel); no adoption date has been fixed. The Commission lists the adoption for Q3–Q4 2027 (DPP timeline, together with aluminium and tyres) and for Q4 2027 (textile apparel page) | Commission DPP page; Commission textile apparel page |
| 21 September 2027 | New Union Customs Code applies in general, including the penalty for incomplete or inaccurate data | Regulation (EU) 2026/2108, Articles 274(1)(b) and 287(2) |
| 1 July 2028 | Importers for distance sales must provide their data through the EU Customs Data Hub | Regulation (EU) 2026/2108, Article 285(2) |
A textile delegated act applies no earlier than 18 months after it enters into force, except in duly justified cases (ESPR Article 4(4)); only then does the DPP's unique product identifier become an obligation for those products.
7. What to do now
If you sell to EU consumers from outside the EU, or through marketplaces that ship from outside the EU, make sure that by 1 November 2026 your declarant receives, for every product, the identifiers it must report — the merchant identifier (assigned by you as online seller, or by the marketplace or platform), your own manufacturer identifier and, where you have one, your standardised code — and that the marketplaces you sell through receive your manufacturer identifiers; all per product variant rather than per batch or unit.
Clean up your product master data: one persistent identifier per product variant (for example each colour and size), used the same way in listings, warehouse data and customs data. Decide how second-hand and personalised products are identified before they ship.
For the passport, nothing is mandatory for textiles yet; but identifiers built now to ISO/IEC 15459 and EN 18219 are the ones the ESPR points to.
Frequently asked questions
Do the new customs product identifiers apply to our wholesale imports?
We do not use EAN codes. Do we have to buy them?
Is the customs product identifier the same as the DPP's unique product identifier?
Who has to send the identifiers to customs?
How are second-hand or personalised garments identified?
Sources
- Customs product identifiersCommission Delegated Regulation (EU) 2026/1022 of 30 April 2026 amending Delegated Regulation (EU) 2015/2446 as regards definitions, customs declarations and data elements related to the temporary EUR 3 customs duty on distance sales of imported goods in a consignment with an intrinsic value not exceeding EUR 150 (OJ L, 2026/1022, 1.7.2026; date corrected by corrigendum, OJ L, 2026/90556, 3.7.2026). Recitals 10 and 11; Article 1, point (1) (Article 1, points (57) to (61), of Delegated Regulation (EU) 2015/2446); Article 2(3); Annex, point (2)(a) and (c). CELEX 32026R1022 ↗
- ESPRRegulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC (OJ L, 2024/1781, 28.6.2024). Article 2, points (30), (31) and (33); Articles 4(4), 9(2), 10(1) and (3), 13(1) and (5), 15 and 41(2); Annex III. CELEX 32024R1781 ↗
- Harmonised DPP standardsCommission Implementing Decision (EU) 2026/1736 of 14 July 2026 on harmonised standards for digital product passports drafted in support of Regulation (EU) 2024/1781 of the European Parliament and of the Council (OJ L, 2026/1736, 15.7.2026). Annex (EN 18219:2026). CELEX 32026D1736 ↗
- General product safetyRegulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety, amending Regulation (EU) No 1025/2012 of the European Parliament and of the Council and Directive (EU) 2020/1828 of the European Parliament and the Council, and repealing Directive 2001/95/EC of the European Parliament and of the Council and Council Directive 87/357/EEC (OJ L 135, 23.5.2023). Article 19. CELEX 32023R0988 ↗
- The new Union Customs CodeRegulation (EU) 2026/2108 of the European Parliament and of the Council of 16 September 2026 establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013 (OJ L, 2026/2108, 19.9.2026). Articles 274(1)(b), 284(1), 285(2) and 287(2). CELEX 32026R2108 ↗
- VAT DirectiveCouncil Directive 2006/112/EC of 28 November 2006 on the common system of value added tax (OJ L 347, 11.12.2006), as amended by Council Directive (EU) 2017/2455 (OJ L 348, 29.12.2017) — consolidated version of 14 April 2025. Article 14(4), point (2), as added by Article 2, point (1), of Directive (EU) 2017/2455. CELEX 02006L0112-20250414 (consolidated) ↗
- European CommissionThe temporary EUR 3 customs duty and the Union handling fee – Guidance for Member States and Trade ↗, version of 5 October 2026, section 8 (Product identifiers).
- European CommissionQuestions & answers – EUR 3 customs duty guidance ↗, version of 30 June 2026 (question 3(b) on a value threshold for product identifiers, update of 18 June 2026).
- European CommissionDigital Product Passport ↗ (indicative DPP timeline: adoption of the ESPR delegated acts for textiles, aluminium and tyres).
- European CommissionTextile Apparel and the Digital Product Passport (DPP) ↗ (planned adoption of the ESPR delegated act for textiles).
The legal acts were read in their Official Journal versions published by the EU Publications Office (EUR-Lex), and their corrigenda were checked; the VAT Directive was read in its consolidated version of 14 April 2025, a documentation tool without legal effect. The Commission guidance and Q&A are Commission services documents without legal force, available in English only; they and the Commission's textile apparel page were accessed on 06.10.2026; the Commission's DPP page was last checked on 13.10.2026. This is general information, not legal, financial or investment advice.