H
Holdwise
E-commerce & United States

Selling to the EU from the US, after the €150 exemption

Since 1 July 2026 the EU's €150 customs exemption has been history: customs duty now applies from the first euro on every parcel entering the Union, with a temporary handling fee of €3 per declaration line bridging the years until the new customs framework arrives in 2028.

For an American brand shipping parcels directly to European customers, the arithmetic has shifted decisively: duty and handling on every single order, product identification requirements arriving on 1 November 2026, and a customer experience shaped by border friction. The brands winning in this environment have moved the border upstream — one bulk shipment into Rotterdam through their own Dutch entity, then domestic-speed fulfilment across all 27 Member States.

€0duty-free threshold since 1 July 2026
€3temporary fee per declaration line
21%import VAT, deferrable via Article 23

The bulk-import flip

Direct parcel shipping puts every order through customs individually: duty from the first euro, the €3 handling line, and the delivery-time lottery that follows. Importing in bulk through your own Dutch BV puts one consignment through customs instead — and the Article 23 licence moves the 21% import VAT into the periodic VAT return, where the same filing deducts it. On a €180,000 container that is roughly €38,800 in VAT that stays in the business rather than waiting at the border.

From Rotterdam the parcels travel as domestic EU shipments: faster, friction-free for the customer, and invoiced by a European entity under EU VAT rules — which is precisely what European marketplaces, payment providers and business buyers prefer to see.

What a US brand gains beyond customs

The same BV carries the registrations that direct shippers keep outsourcing: EPR for packaging in each Member State where required, the EU responsible person for product compliance, and the contracts European retail partners want signed with a European counterparty.

Between the US and the Netherlands sits one of the world's oldest trade relationships and a full double tax treaty; English is the working language of Dutch business.

Structuring the ownership chain

A Delaware or other US parent holds the Dutch BV directly in most structures, with the treaty governing dividends. We map the chain before the notarial deed is drafted — ownership, transfer pricing basics and profit repatriation — so the structure is correct from day one.

Setting up in the Netherlands

A Dutch BV is incorporated by notarial deed and registered with the Chamber of Commerce (KvK). Incorporation runs remotely by power of attorney. After registration the BV obtains its VAT number and EORI number and applies for the Article 23 licence. The same entity carries your EPR registrations under the Packaging Regulation, your product-compliance file and your European contracts — the full route is mapped on EU market entry.

Further reading: e-commerce through the Netherlands, the 2026 customs reform, bulk import versus direct shipping and fiscal representation and Article 23.

Frequently asked questions

What replaced the €150 duty-free threshold?

Since 1 July 2026 customs duty applies from the first euro on parcels entering the EU, with a temporary handling fee of €3 per declaration line until the new customs framework arrives in 2028. Product identification requirements follow on 1 November 2026.

How does a Dutch BV change the customs picture for a US brand?

One bulk consignment clears customs instead of thousands of parcels, and the BV's Article 23 licence moves import VAT to the periodic VAT return where the same filing deducts it. Fulfilment then runs as domestic EU shipping from the Netherlands.

Does the US brand need an EU establishment for product compliance too?

Product rules such as GPSR require an EU responsible person, and packaging rules require EPR registration per Member State. A single Dutch BV carries all of these roles alongside the customs and VAT position.

Does the Netherlands have a tax treaty with the United States?

Yes, a full double tax treaty governs the structure, and the Netherlands is the standard European base for American companies — English-speaking, with Rotterdam and Schiphol as the logistics gateway.

Bring your EU sales position in-house

Holdwise incorporates Dutch BVs for American brands and arranges the VAT, EORI and Article 23 registrations that follow. Fully remote, entirely in writing.

Start your Dutch BV

Sources

  1. European Commission, EU customs reform (Taxation and Customs Union).
  2. Council of the European Union, decisions on the removal of the €150 duty relief, 2026.
  3. Government of the Netherlands, Tax treaty countries.

Last reviewed 13 August 2026.