PID Requirement in EU Customs Reform: A New Era for E-Commerce Shipments

EUROPEAN UNION CUSTOMS REFORM

Product Identifier (PID)

Data Collection Guide

Prepared for Navlungo sellers shipping to the EU

Effect: November 1, 2026   •   Basis: Delegated Regulation (EU) 2026/1022 + EU Commission Guide (June 2, 2026, §3.5)

30-second summary

Starting November 1, 2026, three product codes must be declared in the customs declaration for every product you ship to the EU: your own product code, the manufacturer's model code, and — if available — the barcode/GTIN.

If these codes are missing, your shipment will be held at customs, additional information will be requested, and in the worst-case scenario, the declaration will be rejected.

Table of Contents

1.   Why do we request this data?

2.   The three codes requested from you

3.   M-PID — Your seller product code

4.   NS-PID — Manufacturer model code

5.   S-PID — Standard barcode (GTIN / EAN / ISBN)

6.   Golden rule: each variant on a separate line

7.   10 most common mistakes

8.   What Do We Do As Navlungo?

1. Why do we request this data?

The European Union is implementing a comprehensive reform that tightens customs control on e-commerce shipments. As part of this reform, it becomes mandatory to identify each product on a product-by-product basis in the customs declaration of every product entering the EU via distance selling.

Basis and timeline: The legal basis of the PID obligation is the Delegated Regulation (EU) 2026/1022 (amendment to UCC-DA / 2015/2446, data element 12 03 000 000); Reg (EU) 2026/382 is the part of the same reform package that removes the €150 exemption, and is not the direct basis of the PID. Implementation is voluntary since July 1, 2026, and mandatory from November 1, 2026. No penalties are applied for missing or incorrect data during the voluntary period; they will be applied after November 1.

With these codes, the customs administration prevents the same product from being declared under different names by different sellers, can automatically scan for risks of under-declaration and incorrect HS code classification, and delegates product safety and counterfeit product controls to machines.

What happens if you do not comply

• The shipment is held at customs. Delivery is delayed, resulting in customer dissatisfaction.

• The customs administration sends a request for information (RFI); the process stops until you respond.

• The declaration may be rejected; the shipment enters the return process, and the freight cost is lost twice.

• Repeated errors increase your risk score with the carrier and customs. Your subsequent shipments will also be flagged for physical inspection more frequently.

This is a data obligation, not a tax

The PID requirement does not introduce any additional tax or duty. 

Having an A.TR certificate or being within the scope of the customs union does not exempt you from the PID. Exemptions relate to tax; PID, on the other hand, is a data obligation applicable to every distance selling shipment.

2. The three codes requested from you

Three separate fields will be completed for each product. Two are mandatory in all cases, and the third will be reported only if available.

3. M-PID — Your seller product code

It is the code that uniquely identifies the product in your own sales channel. Other sellers may also sell the same product; the M-PID is the counterpart of the product in your store. It is the code that your customer can see and find the product when searching.

4. NS-PID — Manufacturer model code

It is the model, part, serial, or style code assigned by the company manufacturing the product. Being "Non-standardised" means it is not based on an international standard (like GTIN), and the manufacturer creates this code using their own logic.

Its purpose is to make the product traceable back to the manufacturer. With this code, the customs administration can match the entry of products coming from the same factory into the EU through different sellers.

Where to find it

• The model/style code on the product label or inner neck label.

• The product code on the proforma invoice, waybill, or order form you received from the manufacturer.

• The reference number in the manufacturer's catalog, price list, or B2B portal.

• The "Model No." field on the user manual, warranty certificate, or packaging.

Important notice if you use contract / private label manufacturing

This is where people get stuck most often. The contract workshop producing the product under your brand usually does not have an official model code; the order is placed as "black t-shirt, size M".

In this case, the legislation requires the manufacturer to assign a code. Practically what needs to be done: sit down with your contract manufacturer and determine a permanent code for each product variant, and record this on order forms, labels, and invoices.

The code can be simple: your brand + product type + year + variant. Example: ATLAS-TS-24-BLK-M. The complexity of the format is not important; what matters is that the code is permanent and unambiguous.

5. S-PID — Standard barcode

It is a code based on an internationally recognized standard, machine-readable, and verifiable from official records. It is reported only if available.

Two things frequently confused

The sequence of numbers under the barcode is requested, not the image of the barcode. Do not send photos or barcode images, write the 13-digit number.

Amazon ASIN is not a GTIN. ASIN is Amazon's own code and is not written in the S-PID column, but in the M-PID column.

6. Golden rule: each variant on a separate line

The clearest rule of the legislation is this: a PID must correspond exactly to a single product variant. Same brand, same size, same color, same packaging. Two different products cannot share the same PID.

For most sellers, this means: you will enter separate items as many as your variant count, not your product count.

Manufacturer codes can be hierarchical. The combination of model code and color code can form a single NS-PID. For example, model code + color for trousers: TR7741-BLK, TR7741-BLU, TR7741-KHK. The legislation explicitly gives this structure as an example.

7. 10 most common mistakes

8. What Do We Do As Navlungo?

You enter the codes in the fields next to the product line on the shipping screen while creating the shipment — we take care of the rest:

•  We translate the codes into customs declarations. We match the three codes you enter on the screen to the correct field in the customs declaration (data element 12 03 000 000 “Supporting Document”) and to official document codes. 

•  We transmit them to carriers. We transfer the PIDs you entered into the carriers' systems in the correct format. 

•  We work proactively during the voluntary period. In the voluntary period between July 1 and November 1, 2026, we can transmit PIDs without penalties; you get ready when it becomes mandatory on November 1.

•  We follow the legislation on your behalf. We monitor changes in PID and customs reforms in the EU; if rules change, we update the screen and this guide, and keep you informed.

In short: enter your product codes while creating the shipment, and let Navlungo manage the customs and carrier side of the PID.