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Russia proposes VAT on cross-border online orders. The EU is preparing a handling fee

Andrey Eduardovich BernevLawyer handling commercial court disputes and international trade
Russia proposes VAT on cross-border online orders. The EU is preparing a handling fee

Even if an order is returned to the seller, the cost of customs clearance may remain. That is how Dutch Customs describes the forthcoming European fee on online purchases: the €2 charge per declaration line will not be refunded to the declarant if a parcel is refused, delivery fails or the goods are returned. This is set out in guidance updated on 24 September.

For the buyer, the distinction between money paid to customs and the amount refunded by the shop matters. The fact that the fee is non-refundable does not, in itself, give the shop the right to deduct it from the customer's refund. But the cost of processing the order still exists, and a customs rule alone does not settle who ultimately bears it.

On the same day, Russia's Finance Ministry announced its proposals: 22% VAT on goods sold through cross-border e-commerce, and a separate customs fee of 100 roubles per postal parcel containing goods for personal consumption worth up to €200. These remain proposals in a budget package submitted to the government. They, too, raise questions about the future price of an order from abroad.

Both developments may matter to someone who lives in Germany and helps relatives in Russia with their shopping. Ordering goods from outside the EU for delivery to a home in Germany and buying from a European shop for delivery to Russia involve different directions of trade. The European €2 fee concerns imports into the EU; it cannot be added to Russian charges when goods are sent directly from Germany to Russia. What the two situations share is the wish to know the full cost of an order before paying.

Under the Russian proposal, online marketplaces would remit VAT as tax agents. However, the Finance Ministry's announcement does not set out all the conditions, exceptions or dates from which the new measures would apply. The full text of the amendments is needed to establish whether a particular seller and purchase would be affected. For now, the announcement does not provide a universal calculation of “22% plus 100 roubles” for every order from abroad.

The Russian proposals also connect with developments in the Eurasian Economic Union, or EAEU, which is preparing a separate customs regime for external e-commerce. Union customs rules and national taxes remain distinct levels of regulation. The Eurasian Economic Commission explicitly distinguishes customs duty from VAT set by individual states. Russia's proposed 22% therefore cannot be treated as a uniform tax across the EAEU, nor can the duty-free threshold be taken to mean exemption from every charge.

On 7 August, the Commission reported an instruction to ensure readiness for the new regime by 1 January 2027. In the EAEU status table as at 17 September, Russia was still listed among the countries that had not completed the necessary procedures. The protocol's entry into force depends on the depositary receiving the last written notification from the Union's member states. An instruction to prepare for January does not, in itself, replace that condition.

In the EU, the amount of the fee has already been set by a European Commission act dated 21 September: €2 per item. Dutch Customs' guidance describes the charging unit as a declaration line. A single parcel can contain several such lines, so this is not a flat €2 charge for every box. The fee is intended for distance sales involving imports into the European Union, including purchases worth more than €150.

The Dutch government announced that collection would begin on 1 November 2026. The act itself provides for application from the tenth day following publication in the Official Journal of the EU. As at 27 September, it had not been possible to independently confirm final publication or the calendar date from which the act would apply. The date of adoption alone does not determine when collection of the fee begins.

The authorities have their own explanations for the new costs. The Finance Ministry wants to equalise trading conditions in Russia's domestic market. The European Commission points to the cost of checking data, analysing risks and carrying out customs controls. The Dutch government also hopes to encourage bulk shipments, which are easier to check than large numbers of individual parcels. For a buyer who chose a small order because it was cheaper, this could mean a reduction in the saving.

Discussing prices in EU–Russia trade makes sense where the sale and movement of the goods are themselves permitted: paying a tax or fee does not authorise a shipment. An online order sent directly to a recipient in Russia and an item first received by a relative in Germany and then forwarded as a private parcel also require different assessments. Using a relative's address does not, by itself, make the transactions equivalent.

Neither a buyer in Russia nor someone ordering for delivery to their home in Germany yet has a universal answer to how their savings might change. A marketplace's or declarant's obligation to pay does not, in itself, determine the customer's final cost. The seller may build the expense into the price or absorb it; if the purchase is returned, the terms of sale and consumer protection rules matter. A new payment obligation therefore does not mean an identical extra charge on every order. Its effect on the buyer depends on which rules apply to the transaction and how much of the cost is reflected in the final price.