Advice on Proposal to Introduce National Handling Fee for E-commerce Shipments

Background and Content

The government’s draft decision aims to introduce a national handling fee of €2 per so-called declaration line for packages valued up to €150 imported from outside the European Union. A declaration line consists of a goods code. A package can have multiple goods codes if it contains different products. The national handling fee currently proposed by the government anticipates a handling fee from the European Union that may be introduced by the end of 2026. The Netherlands will only implement the national fee if France and Belgium also introduce a national fee. These are the member states that also have a large flow of e-commerce shipments. They are likely to introduce the fee at the beginning of 2026. The Netherlands wants to align with this to prevent a waterbed effect, meaning to avoid the Dutch Customs having to process an extra flow of packages that would otherwise enter through France and Belgium.

Urgent Problem

The Advisory Division understands that handling the now very large flow of individual e-commerce shipments is an urgent problem for Customs that requires a solution, and that the government is exploring unconventional solutions. If other member states with significant e-commerce introduce a national fee and this leads to a large influx of these shipments to the Netherlands, the Advisory Division understands the necessity of action.

European Developments

Preparations for a national measure cannot be viewed separately from developments in the EU context. This is especially true for the recent agreement to abolish the current exemption from import duties for shipments valued up to €150. The letter from the European Commission dated November 28, 2025, is also important. It sets conditions that a national fee must meet. The short-term abolition of this exemption seems to affect the scale of the problem and the urgency of action. The main incentive for the current approach is that e-commerce goods are shipped individually rather than in bulk shipments. This incentive will disappear with the short-term abolition of the exemption.

Legally Vulnerable

The Advisory Division notes that introducing a national handling fee is legally vulnerable in light of European and national legislation on customs and international trade agreements. It advises the government to further examine these vulnerabilities due to the significant interests at stake and the legal procedures expected. Procedures regarding legal vulnerability could also lead to the fee or part of it having to be refunded afterward, leading to budgetary risks.

Handling Fee Amount Should Reflect Actual Costs

To impose a handling fee as a cost reimbursement, insight must be provided into the nature and amount of the costs to be charged. However, the explanatory notes to the draft decision do not seem to take into account the effects of the abolition of the exemption. The government also appears not to consider the existing, regular control flow and the portion of the fee that member states may keep to compensate for incurred costs (the so-called perception costs). The Advisory Division finds that the cost calculation contains uncertainties and is insufficiently transparent. Thus, the government has not convincingly demonstrated that the handling fee amount closely approximates the actual costs.

Tight Schedule

The timeline for the expected introduction is very tight. This applies not only to the careful legal embedding of the measure but also to the adequate execution of the measure by both Customs and the declarants.

Conclusion

Although the Advisory Division recognizes the situation, it advises the government to pause for thought. Preparing for the introduction of the measure is understandable, but actually implementing it requires further consideration in its view. The advice to the government is to first examine the effects of abolishing the exemption on the e-commerce flow before introducing a national fee. Furthermore, the Advisory Division advises reviewing the fee in light of European and national legal conditions and, if introduced, convincingly substantiating the fee amount in light of those conditions.

The Advisory Division advises the government not to adopt this decision unless it is amended.