From 1 November 2026, businesses involved in online orders arriving from third countries will face an additional EU charge. Alongside the temporary customs duty of EUR 3 per product category introduced in July, an EU handling fee of EUR 2 will apply. The implications, however, extend well beyond making low-value parcels more expensive: the change could reshape e-commerce business models, increase customs agents’ financial and administrative burdens, and create new opportunities for European logistics providers. For Hungary, a particularly important question is what role it can play in the changing EU customs clearance system.
Another charge on online orders from third countries
The European Union is paying increasing attention to goods arriving from third countries through e-commerce, particularly the challenges surrounding their customs clearance. The volume of low-value consignments has grown significantly in recent years, placing pressure on customs authorities and raising competition, product safety and environmental concerns.
The EU sees numerous risks and potential distortions of competition in this trading model. It has therefore introduced, and continues to introduce, measures aimed at changing the customs rules governing predominantly low-value e-commerce imports from third countries.
The temporary rules introduced on 1 July 2026 abolished the previous customs duty exemption for import consignments worth up to EUR 150 and introduced a customs duty of EUR 3 per affected product category.
The next step is that from 1 November 2026, an additional EU handling fee of EUR 2 per customs clearance will be payable alongside the temporary EUR 3 customs duty, to help finance customs authorities’ increased inspection and administrative costs. The handling fee will also cover affected e-commerce consignments worth more than EUR 150
Under this trading model, consumers typically purchase goods through platforms based in the Far East or other third countries, where the platforms, as sellers, do not operate as businesses established in the EU. When ordering, consumers can see which platform they are buying from, but the goods arrive directly at their door and are cleared through a simplified customs system designed for this purpose,” explained István Falcsik, Head of Customs, Excise and Environmental Product Charges at RSM Hungary.
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Why does the EU want to change the system for low-value consignments?
One might ask why the EU appears intent on making this segment of e-commerce almost unviable, or at least fundamentally changing it.
For products shipped directly from third countries to consumers, the EU is examining both competitive conditions and product safety. EU traders must fulfil the obligations associated with placing products on the market, while monitoring and enforcing those obligations is often more difficult where remote online sellers are concerned. The changes to e-commerce customs procedures therefore seek to place greater responsibility on sellers and online platforms. The underlying reasons, however, are much more complex.
The longer-term objective is to make the businesses behind third-country platforms shipping goods into the EU visible to the EU economy and its authorities, and to ensure that they bear the same burdens and obligations as businesses established in the EU. Rather than direct sales from third countries to consumers, the EU favours a model in which the third-country business acts as a conventional importer of its products, with the subsequent sale to the end consumer taking place within the EU.
István Falcsik, Head of Customs, Excise and Environmental Product Charges at RSM Hungary, emphasised: “There is no doubt that this model gives authorities substantially more tools to enforce compliance by third-country platforms acting as importers and to create a level playing field for EU businesses selling similar products.
Enforcement of EPR and PPWR obligations may also come into focus
The significance of customs reform extends beyond paying customs duty and tax. Environmental compliance deserves particular attention.
Under the current model for trading low-value goods, waste management obligations are not always effectively enforced. The businesses behind goods arriving from third countries through e-commerce remain largely invisible to the extended producer responsibility (EPR) system, which was introduced as part of waste management reform and is based on circular economy principles.
EPR legislation sets out the waste management obligations of e-commerce sellers not established in the EU and the conditions for fulfilling them. In practice, however, these requirements are not always met. A rule cannot be effective without enforcement, and monitoring e-commerce sellers with limited or no visibility is extremely difficult.
The same applies to enforcing the PPWR provisions on packaging and packaging waste. Alongside compliant businesses, there is likely to be a substantial number of third-country e-commerce sellers importing low-value parcels that fail to fulfil their EPR obligations, fulfil them incorrectly, or disregard the packaging requirements that apply to them.
The EU’s ambition to bring about drastic change in this area is therefore understandable.
In this spirit, e-commerce will face another blow from November, with the introduction of a EUR 2 handling fee per customs clearance. The legislator’s stated reason is to compensate customs authorities for their workload. In reality, however, the rationale is more likely that the combined EUR 3 and EUR 2 charges will create an even greater deterrent to this trading model.
The introduction of the flat EUR 3 customs duty has itself raised numerous practical questions. Customs agents, who initiate customs procedures before the authorities and are indispensable to customs clearance, have played an essential role in resolving those issues smoothly.
Customs agents are essential to keeping the current system running smoothly
According to the customs authority’s communications, the new rules caused no disruption when introduced in the summer. In my view, however, the information published by the Hungarian Tax and Customs Administration (NAV) did not sufficiently acknowledge the crucial role customs agents play in making the current e-commerce customs clearance arrangements work at all.
Under the EU’s current customs system, and in the practical operation of customs clearance in Hungary, customs agents are indispensable. Someone must present e-commerce goods to the customs authority and request their clearance. This does not happen automatically: it is a process governed by customs law.
Under the current e-commerce customs clearance model, it is not the recipient of the product—its end user—who initiates clearance. Instead, this is handled by customs agents operating as businesses specialising in customs services. They hold the relevant customs authorisations and provide substantial financial guarantees enabling them to offer customs representation as prescribed by customs legislation.
The volume of goods arriving through e-commerce is so large that the customs authority cannot immediately issue an individual assessment for every item on which customs duty is payable. In Hungarian practice, the customs authority issues consolidated daily assessments for each customs service provider, which subsequently allocates the amounts to its clients
As goods can only be released once the customs debt has been paid or secured in some way, customs agents also help resolve this issue, predominantly through the guarantees they provide.
Customs agents providing indirect customs representation in e-commerce undertake activities involving considerable financial risk. They contribute at least as much as the customs authority to the smooth customs clearance of e-commerce goods.
The justification for the EU handling fee of EUR 2 to be introduced in November is that processing e-commerce creates additional work for customs authorities, warranting compensation through such a charge. The points above demonstrate, however, that customs agents’ involvement in e-commerce creates at least as much additional work and risk.
Compensation for this is left to the customs services market: the businesses concerned must decide for themselves whether further fee increases are necessary.
Who will bear the increased costs of customs clearance?
Low-value consignments have faced a series of setbacks in customs clearance recently. Consumers may soon need to factor in additional costs approaching EUR 5 per clearance, as these charges are likely to be incorporated into product prices.
The EU’s expectation that the flat EUR 3 customs duty and EUR 2 handling fee will affect e-commerce appears well founded: statistics suggest that the number of customs clearances for goods arriving through e-commerce is declining.
At Budapest Airport, the number of customs clearances fell by almost 40% following the introduction of the EUR 3 customs duty in the summer. It remains to be seen whether this reflects a decline in the volume of goods entering the EU through this channel, or simply a restructuring of e-commerce flows and their customs clearance.
E-commerce business models could change
If the EU achieves its objective, a model in which Chinese and other third-country platforms establish warehouses in an EU Member State could become more prominent in e-commerce. These platforms would then have a physical presence as economic operators within the EU, holding stocks of individual products and fulfilling customer orders from those facilities.
This could bring several benefits for Member States. The arrival of third-country businesses could increase demand for transport, warehousing and customs services. More significantly, these e-commerce sellers would become accessible to, and subject to checks by, not only customs authorities but also waste management, environmental, consumer protection and other authorities.
The form in which these traders will establish a presence in the EU remains an open question. Under the current Hungarian rules, they generally need to appoint a fiscal representative who also handles accounting and tax administration.
The likely direction is clear: these platforms may increasingly become economic operators within the EU market as well.
Under the customs rules governing the EU customs union, clearance of their imported products may be initiated in different Member States, subject to the applicable conditions. Member States have already been competing to attract customs procedures initiated by businesses operating in the EU, together with the associated demand for transport and warehousing capacity and services. The expected restructuring of e-commerce could bring this competition into even sharper focus.
Hungary is well placed to serve as a customs clearance hub and logistics distribution centre within the EU.
Such a position could be significant not only for customs duty and import VAT revenue, but also for the economic benefits generated by associated services, particularly logistics. The opportunity is there and, in my view, Hungary should seize it.
