EU Regulatory
Changes 2026

What it is

• Directive (EU) 2024/825 rewrites EU consumer law on green and ethical claims.
• Covers everything a shopper sees: product copy, titles, images, badges, emails, social, packaging, landing pages.
• Applies to anyone selling to EU consumers, wherever they are based. For widespread breaches, maximum fines must be at least 4% of turnover in the member states concerned.

What is banned from 27 September

• Generic claims ("eco-friendly", "sustainable", "green", "natural") unless the specific basis sits on the same page.
• Sustainability badges not backed by an independent certification scheme.
• Whole-range claims ("all our merch is sustainable") where only one aspect qualifies.
• Neutrality claims ("carbon neutral", "climate neutral") based on offsetting.
• Future promises ("a tree for every order", "net zero by 2030") without a public, dated, verified plan.

Still fine: "100% GOTS-certified organic cotton", "pressed on 100% recycled PET", "FSC-certified board", with the certificate on file.

Who carries the risk

• BSI, wherever it is merchant of record. Where a client runs its own store, the claims and the risk are the client's.
• UK stores too: the CMA applies the same tests and can fine up to 10% of global turnover (DMCC Act, since April 2025).
• Artist-run social and email are caught in the same way; the risk sits with whoever publishes the claim.

What BSI is doing

• Auditing every live store and updating wording where needed.
• Building an evidence file of certificates and supplier data behind every specific claim that stays live.

Key dates

Words that now need evidence

Do not use without a specific, evidenced statement alongside: eco-friendly · sustainable · green · natural · environmentally friendly · planet-friendly · climate neutral · carbon neutral · net zero · biodegradable · compostable · recyclable · ethically made · ethically sourced

EPR is a different rule

Easily confused, deliberately separate. This directive polices what a store says; EPR polices what a seller ships, with registration and fees in every country of sale so products and packaging are paid for at end of life. A store can be word-perfect and still unregistered, or fully registered and still fined for one stray "eco-friendly". BSI runs both. Where we are registered is in section 02.

What it is

• Extended Producer Responsibility (EPR): register in each country, report packaging weights by material, pay fees to a national scheme.
• EU PPWR applies from 12 August 2026 and harmonises the rules; registration and fees stay national. The UK runs its own scheme (pEPR).

Who is responsible

What BSI is doing

• UK: registered with the regulator via the Report Packaging Data system and reporting packaging data.
• Germany: Backstreet International Merchandise Limited and BSI Merch GmbH each hold their own LUCID registration, with dual system contracts in place. LUCID registration numbers are available on request.
• Rest of the EU: registered in all main EU territories, with textile EPR where national schemes run. Further markets are added as sales volumes require.
• Fulfilment clients: despatch packaging data by material and market on request; registration numbers verified where the law requires.

If you are a fulfilment client

• Register in each country you sell into or appoint an authorised representative there.
• Send BSI your registration numbers. Without a LUCID number BSI cannot legally fulfil German orders for you.
• Ask BSI Operations for despatch packaging data to support your reporting.

Where BSI is registered

EPR registrations held by BSI as merchant of record:

Key dates

NOT TO BE CONFUSED WITH: Green claims (section 01) are a separate rule. Textile EPR (France, the Netherlands, Hungary and Latvia now, EU-wide by 2028) is not covered by a packaging registration.

What is changing

• €3 flat duty per item, since 1 July 2026. On every consignment up to €150, whatever the product or origin. An item is goods in the parcel sharing the same commodity code and origin, so five identical T-shirts count once. BSI pays it under IOSS DDP; not refunded on returns. Runs to 1 July 2028.
• Three product identifiers per item, 1 November 2026. BSI SKU (existing, must now flow into the customs data), the manufacturer's own product reference for each size and colour (new data for most merch), and EAN/GTIN where one exists. Missing data means held, rejected or surcharged parcels.
• EU handling fee, 1 November 2026. €2 per item (same definition as the duty) on every parcel to an EU consumer, at any order value, including over €150. Set by Delegated Regulation (EU) 2026/2152, paid by whoever pays the duty, and not refunded on returns.
• EUDR, 30 December 2026. Due diligence for imported wood, paper and other covered commodities. Printed matter and packaging are out of scope, and leather and some rubber products were removed from scope in 2026.
• IOSS right to use, expected January 2027. The IOSS number on a declaration must belong to the seller of the goods; anyone else's is rejected.
• New Union Customs Code, 2027 to 2028. Regulation (EU) 2026/2108 mostly applies from 21 September 2027, making the seller the importer for distance sales. From 1 July 2028 the flat duty ends and e-commerce imports move to the EU Customs Data Hub. The duty treatment for low-value parcels after that is still to be confirmed; clothing and recorded music could pay more than today.

What it means for BSI

• Cost: €3 duty per item up to €150, plus €2 per item at any value, inside the DDP price and unrecoverable on returns. Baskets with several different products cost the most. 2028 needs re-modelling for apparel and music.
• Data: SKU and origin already held. Barcodes we hold are pre-filled. Manufacturer references are being collected from clients through pre-filled product data spreadsheets, issued October 2026.
• Scope check: wood, notebook and paper lines need EUDR evidence from the supplier before import from December.
• IOSS: BSI's registration is unaffected; clients who are merchant of record need their own.

Being confirmed

Testing SKU, barcode and manufacturer reference in the carrier data; EUDR scope screen; the duty treatment of low-value parcels from 2028. Positions to follow in a further update.

Key dates

Who is affected

Affected: UK warehouse orders to EU consumers; client stock imported into the EU under the client's own name; any seller using an IOSS number that is not its own.

Not affected: Berlin warehouse orders to EU consumers; UK domestic orders; B2B shipments to VAT-registered EU businesses (identifier rule does not apply).

Product data we need from clients

• Manufacturer reference: the maker's own code for each size and colour, such as a style code or model number. If you had the product made, your own product code works. For records, the label's catalogue number.
• Barcode: genuine GS1 barcodes only, where the product has one. We pre-fill the ones we hold.
• Country of origin: where the product was made. For printed clothing, where the blank garment was made.

Identifiers are only needed for products we ship from our UK warehouse to EU customers. Your BSI contact will send a pre-filled spreadsheet of your products.

Other product details for EU listings

EU product safety and textile labelling rules also require the manufacturer's name and contact details on EU listings and, for clothing and textiles, the fibre composition. BSI has an appointed EU representative and is collecting these details alongside the customs data.

For clients

If you are merchant of record and ship into the EU, these are yours: the duty and handling fee sit in your landed cost, the identifiers must be on your product data, and you need your own IOSS registration. BSI can provide despatch data.