Most of what was written before 1 July 2026 about the EU 150 euro threshold removal was forecasting. Two months of freight data have replaced the forecasts, and they are unambiguous about the direction even though they say nothing directly about where the volume went. Start with the numbers, because they are the part that is not arguable.
The evidence: a 24% fall in one month, and no recovery
China to Europe e-commerce air cargo demand fell 24% in July 2026 month on month, to 112,000 tonnes. Freighter capacity on the lane dropped about 10% within days of 1 July and was 28 to 30% below June levels by August, with no recovery. The cuts were specific and named:
- Air China Cargo withdrew 25 weekly flights on the Europe lane
- China Central Airlines went from 30 weekly flights to 20
- SF Express went from 20 to 10
- Year on year e-commerce air cargo growth to Europe flatlined entirely, against plus 23% globally over two years
The last line is the one that matters most. A seasonal dip shows up as a level shift against a rising trend. This is a growth rate falling to zero on one lane while the global figure kept climbing, which is what a structural change to unit economics looks like rather than a soft quarter.
What the numbers prove, and what they do not
They prove that direct parcel economics changed permanently enough for carriers to take metal off the route. They do not prove where the goods went. The honest reading of the precedents is that the United States in August 2025 and Brazil in August 2024 both saw partial recovery within roughly twelve months, and in both cases recovery came through relocated inventory rather than restored parcel flows. Europe following the same path is a reasonable inference, and we are calling it an inference rather than dressing it as a measurement.
You will also meet a widely quoted figure for the share of one large platform's European sales now running through local warehouses. It comes from a stated target in a January 2025 article, not from a measurement of what happened. Do not put it in a business case, and be wary of anyone who does.
The mechanism: EUR 3 per item, not per parcel
Council Regulation (EU) 2026/382, published in the Official Journal on 8 June 2026, abolished the EUR 150 customs duty relief from 1 July 2026 and replaced it with a flat EUR 3 per item on consignments up to EUR 150 sold by distance sale from a third country. The transitional regime runs to 1 July 2028, after which normal tariff classification applies through the EU Customs Data Hub.
An item is not a parcel. An item means goods sharing a tariff classification, a description and an origin, so a parcel containing four different products carries EUR 12 rather than EUR 3. Cheap multi-packs and bundled accessory baskets are hit hardest, and the damage scales inversely with unit price. Model the actual composition of your basket, not an average parcel value.
That per-item reading is why the response was a capacity cut rather than a price increase. On a basket of four low-value items the charge is a large percentage of goods value, and there is no volume at which it improves, because it is flat rather than proportional.
Liability, Product Identifiers and the handling fee
Liability sits with the declarant: the seller, the importer, the IOSS holder, the user of the special arrangements, or their indirect representative. Consumers pay only in residual cases. The party the EU intends to identify and reach is on the seller side, which is the structural reason this is not simply a cost that can be pushed down the chain.
Two more dates belong on the same page. Product Identifiers become mandatory on 1 November 2026, having been voluntary since 1 July 2026. And a handling fee is due to apply by 1 November 2026, with the level set by Commission delegated act. We are not going to quote an amount. The figure circulating widely traces to the original Commission proposal rather than to an adopted act, and we could not confirm the act as adopted. Treat any provider quoting a precise number as quoting a proposal.
The alternative: clear once, then sell from inside the EU
The reason exporters are looking at bulk import instead of direct parcels is not sentiment about warehousing. It is that a bulk import on your own EORI, properly valued and cleared once, takes the transaction out of the low-value import regime entirely. There is no EUR 3 per item, no Product Identifier problem at the parcel level, and no handling fee, because there is no distance sale from a third country. There is a single customs entry, duty at the normal classification and valuation, and import VAT.
After that the goods are EU stock and the sale to the consumer is a domestic or intra-EU supply. Distance sales from EU stock to consumers in other member states go into one OSS return instead of a registration in each destination country. The limit worth repeating: OSS does not remove a local VAT registration where you hold the stock. Goods in a German warehouse mean German supplies and a German VAT number whatever your Estonian company does. Separately, ViDA has been adopted and brings single VAT registration and an OSS extension to movements of own goods in July 2028, with non-EU businesses identifying through the member state of dispatch and call-off stock ending; mandatory IOSS for B2C imports was dropped from ViDA and the EUR 150 threshold structure survives.
Whether bulk beats parcels is arithmetic, not ideology. It depends on your duty rate, your basket composition, storage cost and how much stock you are willing to strand. What has changed is that the comparison is no longer close for low-value multi-item baskets. If you still need the low-value route, IOSS covers consignments up to EUR 150 and a non-EU seller needs an EU-established intermediary for it. We do not act as intermediary, because that role carries joint and several liability for the seller's import VAT.
Import VAT, and the 12 month seasoning trap
Estonia allows import VAT to be deferred under VAT Act § 38(2-1): the import VAT is declared in box 4-1 of the KMD and deducted as input VAT in the same return, so the net cash effect is zero. You apply through the LUBA system in e-MTA and get a decision within 30 days. All three conditions have to hold at once:
- VAT-registered for at least the preceding 12 consecutive months
- No late VAT returns in the preceding 12 months
- No tax arrears
A company incorporated this year cannot satisfy the first condition this year. That is the item most often missing from a quote. Budget for paying 24% import VAT at the border and reclaiming it through the monthly return. It is a timing cost rather than a real one, but on a first bulk shipment it is working capital you have to find, and it arrives at the same moment as the goods.
Customs warehousing: the year-one alternative
Goods placed under customs warehousing or temporary admission do not trigger import VAT until they are released for free circulation, and the storage duration is unlimited. For a first year without deferment, that converts an upfront VAT payment on a whole container into payments spread across actual sales. The requirements are EU establishment, demonstrated proper conduct and a guarantee, so it is not a formality, but it is the standard answer to the seasoning problem.
Estonia has free zones at Muuga, Sillamäe and Paldiski. Whether Estonian storage makes sense for your goods is a separate question from where the company sits, and for most sellers serving Germany or France the answer is that the warehouse belongs elsewhere.
The 2028 horizon: the Customs Data Hub and the deemed importer
The EU customs reform was agreed by Council and Parliament on 26 March 2026. It treats platforms and distance sellers as the importer, carrying the customs formalities and the payment. The sequence is the handling fee by 1 November 2026, then the Customs Data Hub live for e-commerce and the deemed importer rule operative on 1 July 2028, voluntary access for other traders in 2031, and mandatory for all customs formalities on 1 March 2034. A new EU Customs Authority will sit in Lille. Penalties for systematic non-compliance reach 6% of annual import value, with access restrictions on top.
Legal commentary reads the reform as requiring non-EU sellers either to establish an EU presence or to appoint an EU-based representative with AEO or equivalent trusted trader status, explicitly in order to discourage shell entities. AEO is not a registration. It requires demonstrated customs competence, solvency and record-keeping systems, assessed by a national customs authority. That is a 2028 date and nobody can sell you the 2028 answer today. What it is good for is deciding when to start: a company with two years of clean VAT returns, a real import history and organised records will be assessed very differently from one incorporated in the month the rule takes effect.
One boundary, stated plainly. We are Estonian accountants. We handle the Estonian side of this: the company, the EORI and VAT registrations, the returns that the deferment application will eventually be judged on, the OSS filings and the records a customs officer would ask to see. A question of German, French or Polish law needs a specialist in that country, and we will say so rather than guess.
Frequently asked questions
What happened after the EU removed the EUR 150 threshold?
China to Europe e-commerce air cargo demand fell 24% in July 2026 month on month to 112,000 tonnes, freighter capacity dropped about 10% within days and was 28 to 30% below June levels by August with no recovery, and year on year growth on the lane flatlined while the global figure rose 23% over two years.
Is the new EU customs charge EUR 3 per parcel or per item?
Per item. An item means goods sharing a tariff classification, description and origin, so a parcel with four different products carries EUR 12. It applies to consignments up to EUR 150 sold by distance sale from a third country, from 1 July 2026 to 1 July 2028.
How much is the EU e-commerce handling fee?
The amount is set by Commission delegated act and we could not confirm that act as adopted. The political agreement of 26 March 2026 provides for the fee to apply by 1 November 2026. A specific figure circulates widely but traces to the original Commission proposal, so treat any quoted number as a proposal rather than law.
Is it cheaper to import in bulk instead of sending parcels?
It depends on your duty rate, basket composition and storage cost, but bulk import on your own EORI takes the transaction out of the low-value import regime entirely, so there is no per-item charge and no handling fee. For cheap multi-item baskets the comparison is no longer close.
Can a new company defer Estonian import VAT?
Not in its first year. VAT Act § 38(2-1) requires VAT registration for the preceding 12 consecutive months, no late VAT returns in that period and no tax arrears. Budget for paying 24% at the border and reclaiming it monthly, or place the goods under customs warehousing until they are sold.
What changes in 2028 for non-EU sellers?
The Customs Data Hub goes live for e-commerce and the deemed importer rule becomes operative on 1 July 2028, treating platforms and distance sellers as the importer. Commentary reads it as requiring an EU presence or an EU representative with AEO or equivalent status, which is a reason to build filing history early.
TagsEU 150 euro threshold removed effectChina Europe air freight 2026import in bulk instead of direct parcels EUEUR 3 per item customs charge
General information, not tax advice
This article reflects Estonian law as it stands on the date shown. Rules change and individual circumstances differ - confirm your own position with us before acting.