Six Billion Items: What the New EU E-Commerce Controls Mean for Your Imports

In 2025 around six billion items were released for free circulation in the EU, three times more than in 2022, and the control rate fell to 65 items per million imported (source: European Commission, E-commerce product compliance and safety). Those two numbers together explain the year we are in. The volume grew faster than the capacity to check it, so the checks that remain are being aimed rather than spread.

We act as EU authorised representative for more than two hundred brands from outside the European Union, and the practical consequence is already visible in our inbox. A shipment gets held, and the question that decides how long it sits there is never about the product. It is about the file.

That is the part most sellers have backwards. Customs does not have to prove your product is unsafe to stop it. It only has to find the paperwork missing.

1. What changed at the border in 2026

Two things changed, and they work on each other.

The first is the duty exemption. On 11 February 2026 the Council gave its final green light to new customs duty rules for small parcels, ending the relief for consignments valued under 150 euro. In its place comes an interim flat duty of 3 euro, levied on each different category of item in a parcel as identified by its tariff sub-heading. It applies from 1 July 2026 until 1 July 2028, when the EU customs data hub is expected to take over (source: Council of the EU, press release of 11 February 2026).

The second is targeting. In 2025 the Commission ran a Priority Control Area operation on e-commerce imports, with 27 customs authorities and 108 market surveillance authorities taking part, in two phases: April to June, and October to December (source: European Commission).

Read those together and you get the shift. The interim duty is charged per tariff sub-heading, so a parcel now has to be described down to the category of each item in it. That is a level of detail a control operation can filter on, and the 2025 operation shows the authorities filtering.

2. What those controls actually found

In every category where the Commission published a figure, more than half of what was checked failed, which is why it ran a second phase instead of stopping after the first.

In the first phase, on toys and small electronics, more than half of the controlled products did not comply with EU rules, and of the products that went on to laboratory testing, 84 percent were found dangerous. The risks named were choking, electric shock, chemical exposure and asphyxiation (source: European Commission).

The second phase widened the scope. Close to 6000 pieces of cosmetics were checked and 65 percent did not comply. Over 2000 pieces of personal protective equipment were checked and 60 percent did not comply. Close to 3500 pieces of food supplements were checked, with the United States, China and the United Kingdom as the leading origins of the non-compliant ones. In total the second phase covered 11 338 pieces. The operation was aimed at four major marketplaces, which between them account for more than 90 percent of low value consignments (source: European Commission).

Non-compliance rates like that do not lead to fewer controls. They lead to better aimed ones, and to more pressure on the marketplaces to filter their own sellers before the goods ever ship.

If you sell any of those categories into the EU, the honest reading is that more than half of what was checked in your category failed. Your job is to be able to show that yours is in the other half.

3. Why customs stops a parcel before anyone tests the product

Customs stops a parcel on its documents because the law tells it to, and the grounds are listed in one article. It is worth knowing the number, because it explains every hold letter you will ever receive.

Article 26, paragraph 1 of Regulation (EU) 2019/1020 requires border authorities to suspend release for free circulation if they establish, among other grounds, that the product is not accompanied by the documentation required by Union law, or that there is reasonable doubt as to the authenticity, accuracy or completeness of that documentation. The same paragraph covers products that are not marked or labelled as required, a CE marking affixed in a false or misleading manner, and a missing or unidentifiable economic operator under article 4, paragraph 4 (source: Regulation (EU) 2019/1020, article 26).

Note what is not in that list. Nobody has to have tested anything. Nobody has to have found a defect. An incomplete document, or a document that looks doubtful, is enough on its own.

There is a fifth ground, and it is broad: any other reason to believe the product does not comply or presents a serious risk. That is the one the targeting data feeds.

4. The four working days that decide a suspended shipment

A suspended parcel is released again if nothing happens within four working days, and almost nobody on the seller side knows that clock is running.

Article 27 says a suspended product shall be released for free circulation where all other requirements are met and either of two conditions is satisfied: within four working days of the suspension, the border authorities have not been asked by the market surveillance authorities to maintain the suspension, or those authorities have been informed of approval for release (source: Regulation (EU) 2019/1020, article 27).

So in practice you have four working days in which someone can produce a file. If a file exists and can be sent the same day, most holds end quietly. If it has to be requested from a factory in a different time zone that has never been asked for it before, the window closes while you are still waiting for an email.

The same article adds one line that is easy to miss and worth quoting to anyone who treats a cleared shipment as proof of anything: release for free circulation shall not be deemed to be proof of conformity with Union law.

If the file does not appear, article 28 applies. Market surveillance authorities require the goods not to be released and have a notice entered in the customs data-processing system: "Dangerous product, release for free circulation not authorised" for a serious risk, or "Product not in conformity, release for free circulation not authorised" for non-compliance (source: Regulation (EU) 2019/1020, article 28).

That notice sits in a system your future shipments are also filtered through.

5. Who has to be named on the product and for which products

The product itself has to carry the name and address of an economic operator inside the EU, but only for the product groups the law lists, and that list is where most of the confusion lives.

Article 4, paragraph 1 of Regulation (EU) 2019/1020 says that a product covered by the legislation in paragraph 5 may be placed on the market only if there is an economic operator established in the Union responsible for the tasks in paragraph 3. That operator is the EU manufacturer, the importer, an authorised representative with a written mandate, or a fulfilment service provider where none of the others is established in the Union (source: Regulation (EU) 2019/1020, article 4).

Paragraph 4 then requires that operator's name and contact details, including a postal address, to be indicated on the product, its packaging, the parcel or an accompanying document. That is the requirement article 26, paragraph 1, point (d) enforces at the border.

The catch is paragraph 5. Article 4 applies only to a listed set of legislation: toys, machinery, personal protective equipment, radio equipment, electromagnetic compatibility, low voltage, RoHS, gas appliances, construction products and others. So toys, small electronics and PPE, three of the four categories in the control operation, fall squarely inside it. Cosmetics do not; they have their own responsible person under the cosmetics regulation. Food supplements sit under food law again.

Selling a mixed range means you are under more than one of these regimes at once, and the document that satisfies one does not satisfy another.

6. Where the GPSR covers what no directive names

For a general consumer product that no specific directive covers, the equivalent requirement sits in the GPSR.

Article 16, paragraph 1 of Regulation (EU) 2023/988 provides that a product may not be placed on the market unless there is an economic operator established in the Union responsible for the tasks in article 4, paragraph 3 of Regulation (EU) 2019/1020 (source: Regulation (EU) 2023/988, article 16). That is the same task list, reached through a different door.

And the file behind it is the one from article 9, paragraph 2 of the GPSR: an internal risk analysis and technical documentation, kept for ten years and made available to market surveillance authorities on request.

So whichever regime your product falls under, the border asks for the same two things: a party inside the EU who answers, and documentation that party can hand over. Our EU authorised representative service covers the first. The technical file service covers the second, and tells you which of your products can share one file.

7. Why a control rate of 65 per million is not comfort

A control rate of 65 per million looks like safe odds, and read on its own it is: six billion items, 65 checks per million, fewer than ten refusals per million.

Two things spoil that reading.

The first is that the risk is not spread evenly. A control operation that finds more than half of a category non-compliant does not stay at the same intensity in that category. And with e-commerce parcels now over 97 percent of all shipments entering the EU (source: European Commission), the data for aiming those controls is better than it has ever been.

The second is that a hold is not the expensive part. The expensive part is what a hold reveals. A suspension under article 26 puts your documentation in front of a market surveillance authority, and that authority is not limited to the parcel in front of it. The same file shortage that stops one shipment is the shortage that applies to everything you have already sold.

That connects directly to the liability side. From 9 December 2026 a missing technical file can be used in court as evidence that a product was defective, which we set out in our article on the technical file and REACH. A border hold is how most companies will find out they have that problem, and by then the product is already in the market.

8. What to have ready before your next shipment

This is the list we work through when we open a file for a new brand. None of it takes long if the documents exist, and all of it is slow if they do not.

1. The name and postal address of your EU economic operator, printed on the product, the packaging, the parcel or an accompanying document.
2. The EU declaration of conformity for every product subject to legislation that requires one, signed and naming the right standards.
3. The technical documentation, or a clear statement of which of your products share one file and why.
4. Test reports on the finished article, with dates and the standards tested against.
5. A mandate for your authorised representative, in writing, that the representative can produce on request.
6. A named person, reachable on a working day in the EU, who can send all of the above within four working days.
7. Labelling and marking checked against the actual product, not against the artwork file.

Point six is the one that is usually missing, and it is the cheapest to fix. Four working days is not a long time if the answer has to travel through a factory.

9. What to do this month

Start with the categories, not the paperwork. If you sell toys, small electronics, cosmetics or personal protective equipment, you are selling in the categories the 2025 operation chose, and the ones it will choose again.

Then check one shipment as if it had been stopped. Take a recent order, and see how long it actually takes to produce the declaration, the technical documentation and the test report. Measure it in hours. That number is your real exposure, not the control rate.

Where the answer is that nobody has the file, decide now whether you test, replace or accept the gap, and write the decision down. If your range sells through a marketplace, our page on selling on Amazon in the EU sets out which documents each step needs.

The controls are not going to get looser. But a parcel that arrives with a complete file is not a compliance problem at all. It is a parcel.

Sources

• European Commission, Taxation and Customs Union, E-commerce product compliance and safety: import volumes for 2022 to 2025, the 2025 control rate, the share of e-commerce parcels in total shipments, and the results of the 2025 Priority Control Area operation in both phases. Consulted 21 September 2026
• Council of the European Union, press release of 11 February 2026, Council gives final green light to new customs duty rules for small parcels: the end of the relief below 150 euro, the interim flat duty of 3 euro per category of item, and the application period from 1 July 2026 to 1 July 2028
• Regulation (EU) 2019/1020 on market surveillance and compliance of products: article 4 (tasks of economic operators, and the products it applies to), article 26 (suspension of release for free circulation), article 27 (release for free circulation and the four working day condition), article 28 (refusal to release for free circulation)
• Regulation (EU) 2023/988 on general product safety: article 9, paragraph 2 (internal risk analysis and technical documentation), article 16, paragraph 1 (responsible economic operator in the Union)