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DDP shipping to Europe: who pays EU duty and VAT, DDP vs DAP, and what DDP makes you

Your customer was asked to pay customs fees at the door, or refused the parcel, and you want to ship duty paid.

The short answer

DDP means you pay the EU import duty and VAT, so your customer pays nothing at the door. If the country of import makes you liable for its import VAT and the goods are delivered there, your sale moves into that country and its VAT. Under EUR 150, IOSS handles the VAT; the EUR 3 duty is still due.

The short answer

DDP (Delivered Duty Paid) is an Incoterms rule under which the seller clears the goods for import and pays the import duty and taxes. Under DAP (Delivered at Place) the seller delivers at the destination without them. DDU is not one of the eleven current Incoterms rules (HMRC; European Commission, Access2Markets). The Incoterm is a term of your contract; EU law decides who owes what. Import duty is owed by the declarant and, under indirect representation, by the business it acts for (UCC Art. 77(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 77, paragraph 3Click opens the article on EUR-Lex.); a business outside the EU rarely declares goods itself (UCC Art. 170(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 2Click opens the article on EUR-Lex., 170(3)). Import VAT is owed by whoever the EU country of import names (VAT Directive Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex.); from 1 July 2028, on a consignment of EUR 150 or less sold to a consumer without IOSS, the seller, or the marketplace treated as the seller, owes it (Council Directive (EU) 2025/1539, Art. 1(1), Art. 2(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 2, paragraph 1Click opens the article on EUR-Lex.). Where you are the one liable and the goods are delivered in that country, your sale to the customer takes place there (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex., Art. 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex.): you charge its VAT, usually need a VAT number there (Art. 214(1)(a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 214, paragraph 1, point (a)Click opens the article on EUR-Lex.), and deduct the import VAT you paid (Art. 168(e)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 168, point (e)Click opens the article on EUR-Lex.). For consignments of EUR 150 or less, the import one-stop shop (IOSS) is the alternative: you charge the VAT at checkout and the import is exempt (Art. 143(1)(ca)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 143, paragraph 1, point (ca)Click opens the article on EUR-Lex., Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex.). From 1 July 2026 until 1 July 2028, such parcels sold to EU consumers also pay a customs duty of EUR 3 per item, DDP or not, unless they go without IOSS and claim a tariff preference (Council Regulation (EU) 2026/382, Art. 2; Delegated Regulation (EU) 2015/2446, Art. 1(24)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 24Click opens the article on EUR-Lex.). Selling directly to Great Britain, not through an online marketplace, you charge UK VAT at the point of sale on a consignment of £135 or less; consignments with excise goods and non-commercial goods such as gifts are outside that rule. No customs duty is charged at that value, other than on excise goods (gov.uk).

Last checked
Rests on
Directive 2006/112/EC (VAT Directive), consolidated text of 14 April 2025Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)The whole regulationClick opens the law on EUR-Lex.
Topics
DDP, customs, import, VAT, shipping

DDP decides who pays the customs fees at the door: you, before the parcel leaves, or your customer, before the carrier hands it over. The Incoterm is only your promise. Who EU customs and the tax office hold liable is set by EU law, and that is what decides your VAT.

What you do:

  1. Decide who pays at the door before you ship. Under DDP (Delivered Duty Paid) you clear the goods for import and pay the import duty and taxes, so your customer pays nothing on delivery. HMRC’s summary names import clearance and duty as the seller’s task only under DDP, not under DAP (Delivered at Place). DDU is a carrier term, not an Incoterm (HMRC, Incoterms). Until , for a parcel of EUR 150 or less, most EU countries make your customer liable for the import VAT, and the carrier collects it, often with a clearance fee, before delivery (VAT Directive Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex., Art. 369zDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zClick opens the article on EUR-Lex.; Explanatory Notes, chapter 5, scenario 4a, and question 3). From you owe the import VAT on a parcel of EUR 150 or less sold to a consumer without IOSS (Council Directive (EU) 2025/1539, Art. 1(1), Art. 2(1)).
  2. For parcels of EUR 150 or less to consumers, use the import one-stop shop (IOSS) if you want them duty paid. You charge the destination VAT at checkout, and the parcel enters with no import VAT to pay (Art. 33(c)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (c)Click opens the article on EUR-Lex., Art. 143(1)(ca)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 143, paragraph 1, point (ca)Click opens the article on EUR-Lex., Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex.). The EUR 3 duty per item still applies; whoever declares the parcel owes it, so price it in.
  3. Above EUR 150, or without IOSS, shipping DDP as the importer can move your sale into the EU. Where the country of import makes you liable for the import VAT and the goods are delivered in that country, your sale to the customer takes place there. You charge its VAT, usually need a VAT number there, and deduct the import VAT you paid (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex., Art. 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex., Art. 193Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 193Click opens the article on EUR-Lex., Art. 214(1)(a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 214, paragraph 1, point (a)Click opens the article on EUR-Lex., Art. 168(e)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 168, point (e)Click opens the article on EUR-Lex.). From 1 July 2028 that is the rule for every parcel of EUR 150 or less sold to a consumer without IOSS and delivered in the country of import, DDP or not (Council Directive (EU) 2025/1539, Art. 1(1), recital 1).
  4. Have an EU customs representative declare the goods. A business outside the EU can be the declarant only in a few cases, so your carrier or broker declares in its own name on your behalf, and you owe the duty with it (UCC Art. 170(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 2Click opens the article on EUR-Lex., Art. 18(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 18, paragraph 1Click opens the article on EUR-Lex., Art. 77(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 77, paragraph 3Click opens the article on EUR-Lex.). What number it asks you for is on EORI number; who counts as the importer is on importer of record.
  5. Put the duty, the VAT and the carrier’s handling fee into the checkout price. With Royal Mail’s PDDP, Royal Mail bills you after delivery for the VAT and duty the destination charged, plus a handling fee per item (Royal Mail, PDDP).
  6. Book duty paid wherever your carrier does not offer DDU. A parcel sent without the duty-paid data can come back to you instead of reaching the customer.
 DDP, as the importerIOSS, EUR 150 or lessDAP or DDU
What your customer pays at the doorNothingNo VAT. The EUR 3 per item is owed by the declarant, and a carrier may pass it on to your customer: Royal Mail’s IOSS_DDU term has the recipient pay the duties and fees (Royal Mail, Click & Drop)Import VAT, and any duty and fee the carrier passes on
Who pays the import dutyThe declarant, and you on whose behalf it declaresThe declarant, normally your carrier or intermediary as your indirect representative, and you with itThe declarant, usually the carrier, and your customer where the carrier declares as its indirect representative
Where your sale is taxedIn the EU country of import, if the goods are delivered in that country (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex., Art. 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex.)In the country the parcel goes to (Art. 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex., Art. 33(c)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (c)Click opens the article on EUR-Lex.)Outside the EU, where your customer is liable for the import VAT
Your EU registrationUsually a VAT number in that countryOne IOSS registration, through an EU intermediary if you are outside the EU, unless you are based in Norway and ship from there (Art. 369m(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369m, paragraph 1Click opens the article on EUR-Lex.)None for VAT
Risk of a refused parcelLow: nothing to pay at the doorLow, if your IOSS number reaches customsHigher: the parcel is held until the customer pays

For a parcel of EUR 150 or less sold to a consumer, the DAP or DDU column holds until . From , without IOSS, you owe its import VAT, your customer does not, your sale is taxed in the country of import, and you usually need a VAT number there (Council Directive (EU) 2025/1539, Art. 1(1), Art. 2(1), recital 1).

DDP and DAP in plain words

Incoterms are eleven trade terms published, updated and copyrighted by the International Chamber of Commerce (ICC). They split the costs and risks of a delivery between seller and buyer, and they live in your contract of sale (European Commission, Access2Markets glossary; International Trade Administration, Know Your Incoterms). Three of them deliver at a named place of destination.

Term What it means, in HMRC’s summary Import duty and VAT
DDP, Delivered Duty Paid The seller delivers the goods cleared for import, ready for unloading at the named place, and bears all costs and risks to get them there The seller clears the goods for import and pays any import duty
DAP, Delivered at Place The seller delivers the goods ready for unloading at the named place and bears all risks to get them there Not among the seller’s tasks in HMRC’s summary
DPU, Delivered at Place Unloaded As DAP, but the seller also unloads the goods Not among the seller’s tasks in HMRC’s summary

So the DDP meaning, in one line: you deliver to the named place with the import cleared and its duty paid. DDU, delivered duty unpaid, is not one of the eleven current rules. Carriers still use it: Royal Mail’s own list of delivery terms has “DDU_DAP” for “Recipient pays all duties, taxes and fees”, beside “PDDP/DDP” for paying them all from your account (Royal Mail, How international customs works in Click & Drop).

HMRC’s summary of the eleven rules names import clearance and import duty as the seller’s task under DDP alone: under DDP the seller “must clear the products not only for export but also for import, to pay any duty for both export and import and to carry out all customs formalities” (HMRC, Customs valuation manual, Incoterms, updated 14 April 2026). HMRC adds that the rules “are not set by HMRC”, and that the term chosen does not restrict how customs values the goods. The full wording of each rule is published by the ICC and protected by copyright (International Trade Administration).

What shipping DDP as the importer means for EU VAT

The Incoterm does not decide your VAT. The law asks one question: who does the EU country of import make liable for the import VAT? Each country chooses: the customer, the seller or a marketplace (VAT Directive Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex.; Explanatory Notes, section 4.1.4). From 1 July 2028 the law chooses for a parcel of EUR 150 or less sold to a consumer without IOSS: the seller, or the marketplace treated as the seller (Council Directive (EU) 2025/1539, Art. 1(1), new Article 201(2)).

  • If it is your customer, your sale takes place where the goods start their journey, outside the EU, and is “not taxable in the EU”. Your customer owes the import VAT (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex., first paragraph; Explanatory Notes, section 4.1.4).
  • If it is you and the goods are delivered in that country, your sale and any later sale of the goods take place in the EU country of import (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex., second paragraph; Art. 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex.). You then owe that country’s VAT on your sale to the customer (Art. 193Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 193Click opens the article on EUR-Lex.), and you must be identified for VAT there, which usually means a VAT number (Art. 214(1)(a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 214, paragraph 1, point (a)Click opens the article on EUR-Lex.). The import VAT you paid comes back as a deduction in that country’s VAT return (Art. 168(e)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 168, point (e)Click opens the article on EUR-Lex.). A country may also make a business from outside the EU appoint a tax representative (Art. 204(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 204, paragraph 1Click opens the article on EUR-Lex.). From 1 July 2028, for a parcel of EUR 150 or less sold without IOSS, a seller established in a country that has a VAT assistance agreement with neither the EU nor the country of import must appoint one there (Council Directive (EU) 2025/1539, Art. 1(1), new Article 201(3)). When a country requires one is on EU VAT for online sellers.

So DDP as the importer usually means one VAT registration for each EU country you import into, with returns there. IOSS, below, avoids that for parcels of EUR 150 or less.

The Commission sets out both branches for low-value goods imported into the country they are delivered in, without IOSS: where the customer is liable for the VAT, “the distance sale of goods is not taxable in the EU”; where the supplier is liable, the place of supply is “where the goods are imported in the EU” and “the distance sales is taxable in the EU” (Commission, Explanatory Notes on VAT e-commerce rules, section 4.1.4). Its notes also record that “the general practice in Member States is to consider the customer/consignee to be the person liable for VAT” (chapter 5, scenario 4a).

Import VAT is charged on the customs value plus the duties due on import, and the transport and insurance up to the first place of destination in the country of import (Art. 85Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 85Click opens the article on EUR-Lex., Art. 86(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 86, paragraph 1Click opens the article on EUR-Lex.). Each country sets how it is paid, and may let a VAT-registered importer enter it in its VAT return instead of paying at the border (Art. 211Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 211Click opens the article on EUR-Lex.).

Parcels of EUR 150 or less: IOSS and the EUR 3 duty

For a parcel with goods worth EUR 150 or less, IOSS is the EU’s own duty-paid route for VAT. You charge the VAT of the country the parcel goes to at checkout, declare it in one monthly return, and the import is exempt once your IOSS number reaches customs with the import declaration (Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex., Art. 143(1)(ca)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 143, paragraph 1, point (ca)Click opens the article on EUR-Lex.). Your sale is taxed in the destination country through IOSS (Art. 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex., Art. 33(c)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (c)Click opens the article on EUR-Lex.), with no VAT number in each country. How to register, where the number goes and why VAT gets charged twice are on IOSS.

The EUR 150 is the intrinsic value: the price of the goods, without transport and insurance shown separately on the invoice (Art. 1(48) of Delegated Regulation (EU) 2015/2446).

The EUR 3 duty applies DDP or not. From until , a customs duty of EUR 3 per item applies to a consignment of EUR 150 or less that enters under IOSS, or that is sold at a distance to an EU consumer without IOSS (Council Regulation (EU) 2026/382, Art. 2; Art. 1(24) of Delegated Regulation (EU) 2015/2446). Shipping duty paid changes who pays it, not whether it is due. Goods that claim a tariff preference escape it only without IOSS, in a full (H1) import declaration. The proof such a claim needs is on certificate of origin.

  • An item is all the goods in the parcel that share one tariff classification, description and, where declared, origin (Art. 1(61) of Delegated Regulation (EU) 2015/2446). Five T-shirts pay EUR 3; a T-shirt and a watch pay EUR 6.
  • The declarant pays it: the IOSS user, the carrier using the special arrangements, their indirect representative, or the importer’s indirect representative. The Commission calls it “not a tax on consumers” (Commission, Guidance on the temporary flat fee).

The duty itself, who owes it on each route and what changes after 1 July 2028 are on EU de minimis. The tariff rate it replaces, and how the rate on a line is set, are on EU import duty rates.

The Commission lists the goods affected as “all goods in consignments up to €150 sold in distance sales (e.g. e-commerce to consumers), regardless of VAT scheme (IOSS, Special Arrangements, or standard VAT)”, excluding goods under preferential trade agreements “as long as the VAT has not been collected using IOSS and they are declared in H1”. It gives the T-shirt examples, and names the consumer as the payer “only in very residual cases” (Guidance on the temporary flat fee, 8 June 2026, last updated 20 July 2026). The Regulation sets the duty “without considering the origin of the goods” (Council Regulation (EU) 2026/382, recital 6). Who the declarant is for a parcel of EUR 150 or less, in order, is on EORI number.

Who declares DDP goods at EU customs

At customs, the person who answers for the import declaration is the declarant: whoever lodges it, or in whose name it is lodged (UCC Art. 5(15)Regulation (EU) No 952/2013, Union Customs CodeArticle 5, paragraph 15Click opens the article on EUR-Lex.). That person must be established in the EU, apart from occasional declarations and two other listed cases (UCC Art. 170(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 2Click opens the article on EUR-Lex., Art. 170(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 3Click opens the article on EUR-Lex.). So a seller outside the EU that ships DDP appoints a customs representative established in the EU to declare in its own name on the seller’s behalf. The representative is the declarant, and the seller owes the import duty with it (UCC Art. 18(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 18, paragraph 1Click opens the article on EUR-Lex., Art. 18(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 18, paragraph 2Click opens the article on EUR-Lex., Art. 77(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 77, paragraph 3Click opens the article on EUR-Lex.). For parcels, the declarant is usually a postal operator, express carrier or customs agent, acting as a direct or indirect representative (Explanatory Notes, section 4.3.4). The two customs and product-law roles behind the word “importer” are on importer of record. A seller shipping from the UK has the UK export side as well; it is on export from UK to EU.

Countries and carriers that refuse DDU, and Royal Mail’s PDDP

DDU is a carrier’s service, and carriers do not offer it to every destination. Royal Mail warns that a parcel sent on its duty-paid service without full electronic customs data “may be delivered as DDU (delivery duties unpaid) or where this is not offered locally returned to the UK”. Its PDDP page does not list the destinations where DDU is not offered (Royal Mail, PDDP).

Royal Mail’s PDDP, Postal Delivered Duties Paid, is its duty-paid service for UK senders:

  1. You can collect the import VAT, the duty and Royal Mail’s handling fee from your customer at checkout, and you complete the customs declaration, which Royal Mail writes as “CN23” (Royal Mail, International Non-Personal Correspondence services user guide, July 2026, p. 16). What goes on a CN22 or CN23 is in customs declaration CN22 and CN23.
  2. You book the parcel on a PDDP product code through an approved shipping solution, with full electronic customs data.
  3. The destination’s customs calculate the VAT and duty and bill Royal Mail. Your customer pays nothing at the door.
  4. Royal Mail bills you the VAT and duty, plus a handling fee per item, on an invoice separate from postage.

Royal Mail lists PDDP for Austria, Cyprus, Denmark, Estonia, France, Germany, Italy, Ireland, Luxembourg, Malta, the Netherlands, Portugal, Slovakia, Spain and Sweden, and for Norway, Switzerland and the United States. To Luxembourg and Spain it takes parcels up to EUR 150 only; to Denmark, Estonia and Slovakia, sales to consumers only. It states that the EUR 3 duty on an item of EUR 150 or less is not refundable on a return (Royal Mail, PDDP, read 2026-10-06).

Royal Mail’s Click & Drop splits the same choice into four delivery terms: “PDDP/DDP” when you pay all taxes, duties and fees from your account; “DDU_DAP” when the recipient pays them all; “IOSS_DDP” when the VAT was prepaid through IOSS and you pay the duty and fees; and “IOSS_DDU” when the VAT was prepaid through IOSS and the recipient pays the duty and fees (Royal Mail, How international customs works in Click & Drop). PDDP is a carrier’s service and its fees are set in Royal Mail’s own terms; the law behind it is the same as for any DDP parcel above.

DDP shipping to the UK: the £135 rule

Great Britain has its own rule. For a parcel of £135 or less it puts the VAT on you, whatever the Incoterm.

  • A consignment of £135 or less, sold directly to a customer in Great Britain and not through an online marketplace: you charge UK VAT at the point of sale and account for it to HMRC, so you register for UK VAT. If a business customer gives you its UK VAT number, it accounts for the VAT instead. The rule does not cover consignments with excise goods, or non-commercial goods such as gifts. No customs duty is charged on goods of £135 or less, other than excise goods.
  • Above £135: normal import rules apply. Import VAT and any customs duty are charged at the border. Shipped DAP, the delivery company bills your customer before delivery and holds the parcel for about 3 weeks; unpaid, it goes back to you. If you sell to a customer in Great Britain and then import the goods yourself, HMRC counts you as an overseas seller, and an overseas seller must register for UK VAT for any taxable sale in the UK (HMRC, VAT Notice 700/1, sections 12.1 and 12.2).

The £135 is the value of the whole consignment, without transport and insurance shown separately. Sales through an online marketplace follow other HMRC rules, and so do sales into Northern Ireland (HMRC, VAT and overseas goods sold directly to customers in the UK; GOV.UK, Goods sent from abroad: tax and duty). What a UK VAT number is and who needs one is on what is a VAT number.

What happens if you ship DDU and the customer will not pay

Your customer gets the parcel only after the import VAT is paid, often with the carrier’s clearance fee on top. The Commission itself warns that customers used to a VAT-inclusive price may refuse the parcel (Explanatory Notes, question 3). A refused or unpaid parcel goes back to the address you give, and the sale is lost.

Under the special arrangements for parcels of EUR 150 or less, the carrier pays customs only the VAT it actually collected; for a parcel not accepted, it keeps proof that the goods left the EU, the goods go back to your address, and the import declaration is invalidated (Explanatory Notes, section 4.3.5). The country of import may charge its standard VAT rate on every parcel under these arrangements, whatever the goods (Art. 369zaDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zaClick opens the article on EUR-Lex.). The special arrangements end on 30 June 2028; from 1 July 2028 the seller owes that import VAT (Council Directive (EU) 2025/1539, Art. 1(1), Art. 1(6), Art. 2(1)). With IOSS, the Commission says, the customer “is not confronted with unexpected costs (VAT and, in principle, additional clearance fee)” (question 1).

Regulation (EU) 2026/2108 (OJ 19.9.2026) repeals the Union Customs Code, Regulation (EU) No 952/2013Regulation (EU) No 952/2013, Union Customs CodeThe whole regulationClick opens the law on the EU Publications Office., and applies from ; the UCC articles on this page are the ones in force until then (Regulation (EU) 2026/2108, Art. 284(1), Art. 287(2)).

What you can skip

What the law leaves open

  • Whether paying your customer’s import charges through a carrier makes you the importer for VAT. The VAT Directive leaves the choice of who is liable for import VAT to each EU country (Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex.), and the Commission records that most make the customer liable (Explanatory Notes, chapter 5, scenario 4a). No EU text says whether a carrier’s duty-paid service, billing you for charges declared in your customer’s name, changes that. If the country holds your customer liable, your sale stays outside the EU (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex., first paragraph); if it holds you liable and the goods are delivered there, the second paragraph applies and your sale is taxed there. From 1 July 2028 the question no longer arises for a parcel of EUR 150 or less sold to a consumer without IOSS: you are liable for its import VAT (Council Directive (EU) 2025/1539, Art. 1(1), new Article 201(2)).

Sources

22 sources
  1. Art. 14(4)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 14, paragraph 4Click opens the article on EUR-Lex., 14a(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 14a, paragraph 1Click opens the article on EUR-Lex., 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex., 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex., 33(c)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (c)Click opens the article on EUR-Lex.Directive 2006/112/EC (VAT Directive), consolidated text of 14 April 2025 - distance sales of goods imported from third countries; the marketplace as deemed supplier of imported consignments up to EUR 150; place of supply of goods with transport, and the sale by the importer liable under Art. 201 in the country of import; the IOSS exceptions. Accessed 2026-10-06
  2. Art. 85Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 85Click opens the article on EUR-Lex., 86(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 86, paragraph 1Click opens the article on EUR-Lex.Directive 2006/112/EC (VAT Directive), consolidated text - the taxable amount on import: the customs value plus duties, transport and insurance to the first place of destination
  3. Art. 143(1)(ca)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 143, paragraph 1, point (ca)Click opens the article on EUR-Lex.Directive 2006/112/EC (VAT Directive), consolidated text - import VAT exemption when the IOSS number reaches customs with the import declaration
  4. Art. 168(e)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 168, point (e)Click opens the article on EUR-Lex., 193Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 193Click opens the article on EUR-Lex., 204(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 204, paragraph 1Click opens the article on EUR-Lex.Directive 2006/112/EC (VAT Directive), consolidated text - deduction of import VAT; who pays VAT on a supply; the tax representative
  5. Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex., 211Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 211Click opens the article on EUR-Lex., 214(1)(a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 214, paragraph 1, point (a)Click opens the article on EUR-Lex.Directive 2006/112/EC (VAT Directive), consolidated text - who pays import VAT, how it is paid, and who must be identified for VAT
  6. Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex., 369m(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369m, paragraph 1Click opens the article on EUR-Lex., 369yDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369yClick opens the article on EUR-Lex., 369zDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zClick opens the article on EUR-Lex., 369zaDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zaClick opens the article on EUR-Lex.Directive 2006/112/EC (VAT Directive), consolidated text - the EUR 150 scope of IOSS; who may use IOSS, with or without an intermediary; the special arrangements without IOSS, until 30 June 2028: the customer is liable and the person presenting the goods collects
  7. Art. 1(1), 1(6), 2(1); recital 1Council Directive (EU) 2025/1539 - from 1 July 2028 the seller, or the marketplace treated as the seller, owes the import VAT on a consignment up to EUR 150 sold without IOSS, which requires a VAT registration in the country of import; a tax representative where the seller's country has an assistance agreement with neither the EU nor the country of import; the special arrangements deleted. Accessed 2026-10-06
  8. Art. 5(15)Regulation (EU) No 952/2013, Union Customs CodeArticle 5, paragraph 15Click opens the article on EUR-Lex., 18(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 18, paragraph 1Click opens the article on EUR-Lex., 18(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 18, paragraph 2Click opens the article on EUR-Lex., 77(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 77, paragraph 3Click opens the article on EUR-Lex., 170(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 2Click opens the article on EUR-Lex., 170(3)Regulation (EU) No 952/2013, Union Customs CodeArticle 170, paragraph 3Click opens the article on EUR-Lex.Regulation (EU) No 952/2013 (Union Customs Code), consolidated text of 12 December 2022 - the declarant; customs representation; the debtor of the import duty; who may lodge a declaration and where it must be established. Accessed 2026-10-06
  9. Art. 1, 2, 4; recital 6Council Regulation (EU) 2026/382 - end of the EUR 150 customs duty relief; the temporary EUR 3 duty per item from 1 July 2026 until 1 July 2028. Accessed 2026-10-06
  10. Art. 1(24)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 24Click opens the article on EUR-Lex., 1(48)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 48Click opens the article on EUR-Lex., 1(61)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 61Click opens the article on EUR-Lex.Delegated Regulation (EU) 2015/2446, consolidated text of 1 July 2026 - definitions of goods in postal consignment, intrinsic value and item. Accessed 2026-10-06
  11. Commission guidance, not lawEuropean Commission, Explanatory Notes on VAT e-commerce rules, published July 2026 - section 4.1.4 (place of supply when the supplier is liable for import VAT), section 4.2.4 (who can use IOSS directly; Norway the only mutual assistance country), sections 4.3.4 and 4.3.5 (special arrangements: who declares, a parcel not accepted), questions 1 and 3, chapter 5 scenario 4a (the general practice on who is liable for import VAT). Accessed 2026-10-06
  12. Commission guidance, not lawEuropean Commission, Guidance and legal text: temporary flat fee on low value imports, published 8 June 2026, last updated 20 July 2026 - goods affected regardless of VAT scheme, per item, who pays. Accessed 2026-10-06
  13. Commission guidance, not lawEuropean Commission, Access2Markets glossary - Incoterms: the eleven terms, copyrighted by the ICC. Accessed 2026-10-06
  14. Tax authority guidanceGOV.UK, HMRC Customs valuation manual, Incoterms, updated 14 April 2026 - what DAP and DDP mean; Incoterms are not set by HMRC. Accessed 2026-10-06
  15. Government guidance, not lawInternational Trade Administration (trade.gov), Know Your Incoterms - the eleven Incoterms 2020 rules, published and copyrighted by the ICC. Accessed 2026-10-06
  16. Tax authority guidanceGOV.UK, HMRC, VAT and overseas goods sold directly to customers in the UK, last updated 13 May 2022 - the £135 consignment rule for direct sales, and the excise and non-commercial goods it excludes. Accessed 2026-10-06
  17. Tax authority guidanceGOV.UK, HMRC, Who should register for VAT (VAT Notice 700/1), updated 5 August 2026 - sections 12.1 and 12.2: a seller established outside the UK that sells to customers in Great Britain and then imports the goods is an overseas seller, and must register for any taxable sale in the UK. Accessed 2026-10-06
  18. Government guidance, not lawGOV.UK, Goods sent from abroad: tax and duty - VAT and Customs Duty above and below £135; the delivery company holds a parcel about 3 weeks. Accessed 2026-10-06
  19. Carrier policy, not lawRoyal Mail, Postal Delivered Duties Paid (PDDP) - how PDDP works, the destinations, value and B2C limits, DDU where data is missing, the EUR 3 duty not refundable. royalmail.com refuses automated reads; read 2026-10-06 in a browser
  20. Carrier policy, not lawRoyal Mail, International Non-Personal Correspondence services user guide, July 2026 - the PDDP service and its steps, p. 16 ("Sender completes customs declaration (CN23)"). royalmail.com refuses automated reads; read 2026-10-06 in a browser
  21. Carrier policy, not lawRoyal Mail Click & Drop Help Centre, How international customs works in Click & Drop - the delivery terms DDP, DDU_DAP, IOSS_DDP and IOSS_DDU, updated 14 August 2026. Accessed 2026-10-06
  22. Art. 284(1)Regulation (EU) No 952/2013, Union Customs CodeArticle 284, paragraph 1Click opens the article on EUR-Lex., 287(2)Regulation (EU) No 952/2013, Union Customs CodeArticle 287, paragraph 2Click opens the article on EUR-Lex.Regulation (EU) 2026/2108 (new Union Customs Code, OJ 19.9.2026) - repeals Regulation (EU) No 952/2013 and applies from 21 September 2027. Accessed 2026-10-06