EU makes the seller or marketplace liable for import VAT on low-value distance sales from 1 July 2028

What changed in detail

Council Directive (EU) 2025/1539 of 18 July 2025 amends the VAT Directive (2006/112/EC) “as regards VAT rules relating to taxable persons who facilitate distance sales of imported goods and the application of the special scheme for distance sales of goods imported from third territories or third countries”. It was published on 25 July 2025 (OJ L, 2025/1539). Member States must transpose it by 30 June 2028 and apply it from 1 July 2028 (Article 2).

• Liability for import VAT (new Article 201(2)). For distance sales of imported goods that would be eligible for the Import One-Stop Shop (IOSS), the supplier, or the marketplace acting as deemed supplier under Article 14a(1), is the person liable to pay the import VAT.
• Tax representative (Article 201(3) and 204). A supplier established in a third country with no mutual-assistance agreement with the EU or the importing Member State must appoint a tax representative there, unless the import is exempt under the IOSS (Article 201(4)).
• Fallbacks. Member States may let the customer pay if the liable person defaults (Article 201a) and may make another person jointly and severally liable (Article 205).
• Special arrangements removed. Title XII, Chapter 7, the special arrangements for declaring and paying import VAT, is deleted.
• The Commission reports on the functioning of the new rules by 31 March 2032 (Article 205a).

What it means

Enacted, not yet applying. From mid-2028 the seller or marketplace, not the customer or the carrier, owes import VAT on low-value e-commerce imports, whether or not it registers for the IOSS. Scope is tied to IOSS eligibility, currently consignments up to EUR 150. A separate draft directive that would delete that limit reached a Council general approach on 9 November 2026 but is not yet law: see the EUR 150 IOSS proposal. Article 14a, which this directive relies on, is replaced from 1 January 2027 by Directive (EU) 2025/516, which keeps the EUR 150 limit for imports in paragraph 1.