As of 1 November 2026, new requirements concerning Product Identifiers (PIDs) will apply to businesses engaged in international distance sales in e-commerce, in particular online sellers, marketplaces and platforms involved in cross-border trade in goods.
This is not a topic for customs teams alone.
In practice, preparing for the new requirements may also require the involvement of IT, e-commerce, logistics, sales, master data teams, as well as ERP and customs system providers.
What is changing?
The new regulations require the following Product Identifiers to be provided to customs authorities:
- M-PID (Merchant Product Identifier) – assigned by an online seller, marketplace or platform;
- NS-PID (Non-standardised Manufacturer Product Identifier) – assigned by the manufacturer or product supplier;
- S-PID (Standardised Manufacturer Product Identifier) – a standardised manufacturer identifier, where one exists for the product.
This does not automatically mean that businesses need to create a new product numbering system.
The key question is:
Not every product number will be sufficient
A company may use several different identifiers for the same product, such as a product number, offer number, manufacturer’s catalogue number, EAN/GTIN or logistics identifier.
However, not all of them will necessarily be suitable as a PID. The identifier should allow for the unambiguous identification of the product and meet requirements relating, among other things, to its uniqueness and persistence.
This is particularly relevant for marketplaces and platforms, where the same product may be offered by multiple sellers and product catalogues may change frequently. Merging catalogue entries, changing an identifier or removing a product may affect compliance with the new requirements.
Why should historical data also be considered?
A PID will be provided as part of the customs declaration and should make it possible to establish which product it relates to.
It is therefore worth checking not only whether the relevant identifier can be transferred to the customs system, but also whether it will be possible to reconstruct historical data at a later stage – for example, if the product, its identifier or the catalogue structure changes.
What should be checked before 1 November 2026?
Businesses should review:
- which product identifiers are currently used within the organisation;
- which of them could serve as an M-PID, NS-PID or S-PID;
- whether the identifiers are sufficiently unique and persistent;
- whether changes to product catalogues or sales systems affect their stability;
- whether the relevant data can be transferred to the customs system;
- whether the data can be reconstructed for the purposes of a potential subsequent customs control.
Voluntary reporting of PIDs has been possible since 1 July 2026, while mandatory application of the new requirements will begin on 1 November 2026.
What does this mean for e-commerce?
The new requirements are, above all, a challenge in terms of ensuring consistency between product, commercial and customs data.
Providing the identifier in the customs declaration is only the final step. Before that, businesses need to determine which identifier should be used, who is responsible for it, where it is stored and whether it remains consistent throughout the product lifecycle.
Not every company will need to rebuild its systems, but it is worth checking now whether the current product data management model will allow the business to meet the new requirements as of 1 November 2026.
Do you sell goods through distance sales and want to check whether your current product identifiers will meet the new PID requirements?
We can train your team, analyse your sales model, product data and customs processes, and identify the areas that may need to be adjusted before the new obligations take effect.
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