The Italian 2026 Budget Law (Law no. 199/2025) introduced, as of 1 January 2026, a €2 Handling Fee designed as a contribution to cover administrative customs costs for low-value shipments (art. 1, par. 126–128 of Law no. 199/2025). The 2026 Budget Law expressly provides that the Handling Fee shall apply in consistency with the EU Customs Code (Regulation (EU) No. 952/2013).
Scope of Application
The 2026 Budget Law expressly limits its scope to shipments:
(a) originating from countries outside the European Union; and
(b) having a declared value not exceeding €150.
The contribution is collected by the Customs and Monopolies Agency (ADM) upon final importation.
Clarifications from ADM Circular Letter No. 37/2025
ADM Circular Letter No. 37 of 30 December 2025 provides important application details:
- The Handling Fee is due for all importations with declared value ≤ €150 made as of 1 January 2026, regardless of the underlying business model (i.e., B2C, B2B, or private-to-private);
- The Handling Fee becomes payable upon final importation of the shipments;
- The final importation is considered the release in free circulation (“immissione in libera pratica”);
- For standard (H1) declarations, the relevant threshold is checked against the customs value as determined under arts. 69–76 of the EU Customs Code;
- For simplified (H7) declarations, the threshold is checked against the intrinsic value, and the Circular sets out periodic accounting/payment rules pending IT adjustments.
Transitional Arrangements
Pursuant to Circular Letter no. 1/D/2026 dated 7 January 2026, the ADM has updated its previous guidance from Circular Letter no. 37/D/2025. In light of a transitional period extending through 28 February 2026, payment of the Handling Fee for the first two months of the year is now deferred to the 15th of the following month, specifically 15 March 2026.
The Critical Importance of Business Model Review
Given the broad application of this new Handling Fee across all business models—whether B2C, B2B, or private-to-private transactions—it is essential for businesses engaged in cross-border e-commerce and logistics to conduct a thorough review of their operational structures and business models. This review should focus on identifying which aspects of their operations fall within the scope of the new legislation and assessing the potential financial and administrative impact.
Different business models may be affected in varying ways. For instance, e-commerce platforms facilitating direct-to-consumer sales from non-EU countries, logistics providers handling low-value shipments, marketplace operators, and businesses utilising drop-shipping arrangements all need to evaluate their exposure to this new fee. The cumulative effect of a €2 charge per shipment can be significant for high-volume operations, potentially affecting pricing strategies, margin calculations, and competitive positioning.
Preventing Issues with Tax Authorities
Proactive compliance is crucial to prevent potential disputes or penalties from the Italian tax and customs authorities. The ADM has made clear that the Handling Fee applies universally to qualifying shipments, and businesses must ensure they have appropriate systems and processes in place to:
- Accurately identify shipments falling within the €150 threshold;
- Properly classify transactions under the correct declaration type (H1 or H7);
- Calculate and account for the Handling Fee in accordance with the applicable rules;
- Maintain adequate documentation and records for audit purposes;
- Implement the transitional payment arrangements correctly during the initial period.
Failure to comply with these requirements could result in administrative sanctions, interest charges, and potential reputational damage. Moreover, as customs authorities increasingly share information across jurisdictions and enhance their monitoring capabilities, non-compliance risks are heightened.
For further information, please contact:
Giuliana Polacco, Partner, Bird & Bird
giuliana.polacco@twobirds.com
