Rules checked 16 Sep 2026
EU customs · gift relief

Can you just mark it as a gift?

It is the first workaround suggested in every seller thread since the €150 exemption disappeared. Gift relief does still exist — it just has never applied to a shop, and the reason it fails is not the one most people reach for.

The short version

Gift relief survived. The July 2026 change deleted Chapter V of Regulation (EC) No 1186/2009 — the €150 commercial relief. Gift relief lives in Chapter VI, which was left untouched. The €45 allowance still stands.

It has never covered a business shipment. The relief runs from one private individual to another, and one of its three conditions is that the parcel is sent free of payment of any kind. A customer who paid you fails that condition whatever the customs form says.

The cost argument is the one that should stop you. Gift relief is relief from customs duty only. Import VAT is due from the first euro, and your product-safety obligations do not depend on how the parcel is labelled. The workaround risks a false declaration to avoid €3 while leaving the two larger bills exactly where they were.

Why the question appeared now

Council Regulation (EU) 2026/382, of 11 February 2026, is one short instrument that did two things. Its Article 1 is a single line:

"Chapter V of Title II of Regulation (EC) No 1186/2009 is deleted." Council Regulation (EU) 2026/382, Article 1

Chapter V is Articles 23 and 24 — "consignments of negligible value", the €150 duty-free threshold that most cross-border e-commerce ran on. Article 2 of the same regulation puts a flat €3 per item in its place, from 1 July 2026 to 1 July 2028.

Gift relief is somewhere else entirely. It is Chapter VI — "consignments sent by one private individual to another", Articles 25 to 27. 2026/382 does not mention Chapter VI, or Articles 25, 26 or 27, anywhere in its text. That chapter is exactly as it was.

So the premise behind the workaround is correct, which is what makes it tempting. One relief was abolished and a neighbouring one was not. The question is only whether a shop can stand in the surviving one, and the answer is in the conditions.

The three conditions, and where a shop fails

Article 25(1) sets the frame: the relief applies to goods sent from a private individual in a third country to a private individual in the EU, and only where the importation is "not of a commercial nature". Article 25(2) then defines what that means. All three conditions have to hold at once.

Article 25(2)(a)The consignments "are of an occasional nature".

A shop fails this. Fulfilling orders is the opposite of occasional — it is the business.

Article 25(2)(b)They "contain goods exclusively for the personal use of the consignee or his family, which do not, by their nature or quantity, reflect any commercial intent".

A shop fails this. Stock shipped from inventory reflects commercial intent by definition.

Article 25(2)(c)They "are sent to the consignee by the consignor free of payment of any kind".

A shop fails this, and fails it hardest. The customer paid. There is a payment record, an order and usually a platform trail.

Condition (c) is the one worth dwelling on, because it is the one no amount of care with the paperwork can satisfy. The other two are arguable at the margins — a one-off, a genuine personal favour. Payment is a fact, recorded in at least two systems neither of which you control.

Note what the test is about. It asks about the transaction, not the label. Nothing in Articles 25 to 27 turns on what is written on the CN22, which means the customs form is not the thing being assessed — it is only the thing that would be wrong.

Article 26(1) sets the ceiling at €45 per consignment, and Article 27 caps tobacco, alcohol and perfume regardless of value. Both are worth knowing if you are sending an actual gift; neither rescues a commercial shipment.

What gift relief would actually save you

Suppose, for the sake of the argument, that the declaration went unchallenged. Here is what it would and would not buy.

Gift relief is relief from customs duty. That is its whole scope. It does nothing to two costs that are larger.

So the trade is this: a false customs declaration, made on every order, to avoid €3 per item — while the VAT stays due and the compliance bill, which starts around €139 a year and runs into the thousands, stays exactly where it was. The risk is permanent and the saving is the smallest number on the page.

That is the argument we would make even to someone entirely untroubled by the honesty of it. The workaround does not fail because it is dishonest. It fails because it is aimed at the wrong cost.

The people who genuinely lost something

There is a real casualty in this change, and it is not sellers. It is ordinary private gifts worth between €45 and €150.

Chapter VI has always capped gift relief at €45. A genuine gift above that — a birthday present from a relative abroad, say — used to arrive duty-free anyway, because Chapter V's €150 relief never asked whether a consignment was commercial. It applied to consignments of negligible value, full stop.

Chapter V is now deleted. That band lost its cover as collateral damage of a measure aimed at e-commerce.

ConsignmentBefore 1 Jul 2026Now
Genuine private gift, ≤ €45Duty-free (Ch. VI)Duty-free (Ch. VI, unchanged)
Genuine private gift, €45–€150Duty-free (Ch. V)Relief gone
Commercial, ≤ €150Duty-free (Ch. V)€3 per item

What is now owed on the middle row is our reading of the two regulations, not settled guidance — see below.

Marked as unsettled on purpose. Article 2 of 2026/382 applies the €3 fee to postal consignments worth €150 or less, which a gift parcel plainly is. But the same article frames the fee as applying "instead of the relief eliminated pursuant to Article 1", which points at commercial consignments. We have found no guidance either way, so we are not going to tell you which it is.

The question underneath this one

Nobody looks up gift relief for fun. The real question is whether the EU is still worth shipping to once the duty and the paperwork are counted — and that one has an arithmetic answer.

Run the numbers

If they work out and it is the paperwork that is stopping you, that is what the Compliance Pack is. If you are wondering whether your existing stock is exempt, that is a separate question with a worse answer than most people expect.

Genuinely unresolved

Sources

  1. Council Regulation (EC) No 1186/2009 setting up a Community system of reliefs from customs duty — Chapter V of Title II (Articles 23–24, consignments of negligible value) and Chapter VI (Articles 25–27, consignments sent by one private individual to another). Article 25(2) conditions, Article 26(1) €45 limit, Article 27 quantitative limits.
    eur-lex.europa.eu
  2. Council Regulation (EU) 2026/382 of 11 February 2026 amending Regulation (EC) No 1186/2009 as regards the elimination of the threshold-based customs duty relief. Article 1 deletes Chapter V of Title II of Regulation (EC) No 1186/2009; Article 2 introduces the €3-per-item duty for consignments of €150 or less from 1 July 2026 to 1 July 2028; Article 4 sets application from 1 July 2026. Checked in full: the regulation does not refer to Chapter VI or to Articles 25, 26 or 27.
    eur-lex.europa.eu
  3. European Commission, Taxation and Customs Union — Guidance and legal text on the temporary flat fee on low-value imports which will apply until 1 July 2028, published 8 June 2026.
    taxation-customs.ec.europa.eu