Buying from 
China for 
EU consumers: which product IDs (PID) to ask your supplier for when the item has no barcode in detail
No barcode is not a blocker. Under section 8 of the European Commission's customs guidance, from 1 November 2026 distance-sales goods worth up to €150 must be declared with product identifiers: a merchant PID (M-PID) and a non-standard manufacturer PID (NS-PID) are always required; a standard PID (S-PID, such as an EAN barcode) is reported only if the product already has one. If not, the exception code Y081 is used, and manufacturers are not obliged to obtain a barcode. A manufacturer with no code of its own should assign one, in any format, as long as it is unique per variant and stays the same over time.
- Applies to
- Importers, IOSS holders and online sellers bringing goods from Chinese factories to EU consumers in consignments up to €150. B2B imports are in principle out of scope.
Dear friend,
Welcome! This letter sets out what you need to know, plainly and in order.
Three identifiers: who assigns them and when to report
| Identifier | What it is | Assigned by | When reported | Code |
|---|---|---|---|---|
| Merchant PID (M-PID) | The seller's or marketplace's code, e.g. a SKU | Seller or platform | Always | C127 |
| Non-standard PID (NS-PID) | The manufacturer's or supplier's own model or item number | Manufacturer or supplier | Always; if none exists, the manufacturer should assign one, any structure | C128 |
| Standard PID (S-PID) | A global code such as EAN or ISBN | Manufacturer | Only where it exists; otherwise exception code Y081 | C129 |
Source: European Commission customs guidance, sections 8.4 and 8.6 (guidance PDF). The codes go in data element 12 03 000 000, for declarations with additional procedure codes F48, F49 or F53.
What a valid identifier looks like
- One per variant: each colour or size gets its own code (section 8.3).
- Persistent and compact (section 8.3).
- No batch or unit codes in place of a model code: where a model-level PID exists, declaring batch- or unit-level codes is an infringement (section 8.4).
- If one ID plays two roles, declare it under both codes (section 8.7).
- Bundles and sets: list each product inside (section 8.7).
- Second-hand and personalised goods get no special treatment.
- Deliberately defeating the requirement is an infringement under Article 274(1)(b) of the Union Customs Code.
Who is responsible
- Platform: assigns the merchant PID.
- Manufacturer: assigns the non-standard PID, provides the barcode if there is one, and passes the codes down the chain.
- Declarant (usually the IOSS holder, special-arrangements user or indirect representative): must take reasonable steps and check doubtful PIDs (section 8.5).
Tolerance for a few product groups
Section 8.8: for Chapters 1–15 (agricultural and food products), the handmade-goods codes listed in the guidance, and headings 9701–9706 (art, collectors' pieces, antiques), declaring the merchant PID and non-standard PID is deemed enough. The guidance gives no end date. For medical devices, the UDI-DI counts as the standard PID. Check exact codes in the guidance.
What to ask your Chinese supplier for (our suggestions, not official text)
- A list of every variant (each colour and size) with the factory's model or item number.
- If the factory has no item numbers, ask it to assign a fixed one per variant and put it in your purchase order.
- Barcode if one exists. If not, you do not need to buy one: mark it "none, Y081".
- Give the list to your customs broker or platform together with the product description and 6-digit HS code.
- Voluntary from 1 July 2026 with no penalty; mandatory from 1 November 2026 (section 8.2).
Unknowns
- Penalties in each member state for wrong or missing PIDs: the guidance gives no figures, so this page cites none.
- Upload formats required by marketplaces or carriers: follow their seller rules.
- This page summarises public official information. It is not legal advice.
Sources for this letter
Wishing you good business,
The mouwise team
Checked 2026-10-29
Contact us