Short answer
The €150 limit is tested per consignment, on the intrinsic value of the goods — not per item, and not on the amount the customer paid at checkout.
Three consequences follow for a multi-item order:
- If the whole order ships as one consignment, add the intrinsic values of all the goods in it. A basket of four items at €45 each is €180 and falls outside IOSS, even though no single item approaches the limit.
- If the order is genuinely fulfilled as separate consignments — different warehouses, different shipments — each consignment is tested on its own.
- Transport and insurance costs are normally excluded from intrinsic value, so shipping charges do not push an order over the line, provided they are separately indicated on the invoice.
Excise goods are excluded from the scheme entirely, whatever their value.
Separately, and importantly since 1 July 2026: staying under €150 no longer means no customs duty. The duty relief for consignments of negligible value has been abolished.
The statutory limit
Article 369l of the VAT Directive sets the scope of the import scheme:
"For the purposes of this Section, distance sales of goods imported from third territories or third countries shall only cover goods, except products subject to excise duty, in consignments of an intrinsic value not exceeding EUR 150." —
Two operative terms: consignment and intrinsic value.
The same €150 figure appears in Article 14a(1), which deems an electronic interface facilitating distance sales of imported goods in consignments not exceeding that value to have received and supplied the goods itself. A marketplace and a direct seller are therefore testing the same threshold on the same basis.
Intrinsic value is defined in customs law
The VAT Directive does not define intrinsic value. The Union Customs Code delegated legislation does:
"'intrinsic value' means (a) for commercial goods: the price of the goods themselves when sold for export to the customs territory of the Union, excluding transport and insurance costs, unless they are included in the price and not separately indicated on the invoice, and any other taxes and charges as ascertainable by the customs authorities from any relevant document(s)" —
Reading that carefully:
- Goods price only. The starting point is the price of the goods themselves.
- Transport and insurance are excluded — but only if separately indicated. A "free shipping" price that silently bundles carriage into the item price does not get to strip it out again. If you want shipping excluded, itemise it.
- Other taxes and charges ascertainable from the documents are excluded.
So a basket of goods priced at €140 with €20 shipping shown separately has an intrinsic value of €140 and is within the limit. The same basket sold at €160 "delivery included", with no separate shipping line, is at €160 and is outside it.
Discounts reduce the price actually charged and so reduce intrinsic value. Gift wrapping and similar service charges should be itemised if you do not want them counted.
Consignment is a shipping concept, not an order concept
The limit attaches to the consignment presented to customs, not to the commercial order. One order can become several consignments, and several orders can be consolidated into one.
That creates a genuine planning question and a genuine anti-abuse risk.
Splitting a single order into artificial consignments purely to stay under €150 is the obvious abuse case, and customs authorities look for it: same seller, same buyer, same address, same despatch date, sequential tracking numbers. Where goods that were ordered together are split only on paper, expect the consignments to be aggregated.
Genuine operational splits are different. Goods dispatched from two fulfilment centres, or an in-stock item shipped now and a backordered item shipped in three weeks, are naturally separate consignments. Document the operational reason.
The practical instruction for a checkout is that you cannot reliably decide IOSS eligibility at the basket stage if fulfilment may split the order. Decide it at dispatch, when the consignment is known.
What happens above €150
IOSS is unavailable. The import falls back to ordinary rules:
- Import VAT is due at importation in the Member State of import, under that state's procedures.
- Customs duty applies according to tariff classification and origin.
- The special arrangements in Articles 369y to 369zb of the VAT Directive allow the person presenting the goods to customs — typically the carrier — to collect import VAT from the customer and pay it monthly. This is the mechanism behind the "handling fee" consumers often meet on delivery.
None of that is a penalty. It is simply the standard import route without the simplification.
The customs-duty position changed on 1 July 2026
This is the part most guidance has not caught up with, and it is the single most important current point for anyone selling low-value goods into the EU.
Until mid-2026, Articles 23 and 24 of Council Regulation (EC) No 1186/2009 granted relief from import duty for consignments of goods of negligible value, defined as an intrinsic value not exceeding €150. Council Regulation (EU) 2026/382 deleted those Articles with effect from 1 July 2026.
The Commission's implementing delegated regulation records the consequence directly:
"Council Regulation (EU) 2026/382 amends Regulation (EC) No 1186/2009 by deleting Articles 23 and 24 thereof with effect from 1 July 2026. As a consequence, goods of an intrinsic value not exceeding EUR 150 per consignment are now subject to customs duties, and customs authorities are to collect customs duties on goods in such a consignment irrespective of their declared value." —
In its place, Regulation (EU) 2026/382 introduced a temporary customs duty of EUR 3 per item in consignments whose intrinsic value does not exceed €150, where the importation is VAT-exempt under Article 143(1)(ca) of the VAT Directive or the goods are in a postal consignment.
The charge is per item, and the delegated regulation added a formal definition of "item" precisely so that this is unambiguous — where goods are declared as separate items, the €3 applies to each of them, including where identical items are declared on separate lines.
So a €150 consignment containing ten items now attracts €30 of temporary duty that would have been nil before July 2026.
Two things did not change. The €150 VAT threshold in Article 369l is unchanged, and IOSS remains available on the same terms. And Article 143(1)(ca) still exempts the importation from VAT where the IOSS identification number is provided to customs at the latest on lodging the import declaration.
Because this duty is expressly temporary and sits inside a wider customs reform, check the position in force on the date of import rather than relying on any summary, including this one.
Operational checklist
- Test the €150 limit per consignment at dispatch, not per order at checkout.
- Sum the intrinsic value of all goods in the consignment.
- Itemise shipping and insurance separately so they can be excluded.
- Exclude excise goods from IOSS entirely.
- Document the operational reason for any split shipment.
- Provide the IOSS identification number to customs by the time the import declaration is lodged.
- Budget for the temporary €3-per-item duty on low-value consignments from 1 July 2026.
- Record the intrinsic value used, and the basis for it, in your Article 369x records.
Conclusion
The €150 test is mechanical once the two defined terms are respected: intrinsic value of the goods, aggregated across the consignment, excluding separately stated transport and insurance. Most errors come from testing the basket rather than the shipment, or from failing to itemise shipping.
The strategic point for 2026 is different. The €150 figure now marks the boundary of a VAT simplification only. The customs-duty relief that used to accompany it has been repealed, and a temporary per-item duty applies in its place. Sellers who priced low-value EU imports on the assumption of duty-free entry should reprice.
Sources
This article provides general legal information, not advice for a specific matter. Laws, facts and procedural deadlines may change the result. Follow the linked primary sources and obtain local advice before acting.