Legal text checked: 6 August 2026 · Next review: October 2026, when the Commission publishes its first assessment
Since 1 July 2026 the EU applies a €3 customs duty per item on consignments worth up to €150. An "item" is legally defined as goods sharing the same tariff classification — not as a unit. Ten identical rolls of Portra 400 in one parcel are one item: €3 total, or €0.30 a roll. The €3-per-roll figure circulating in forums is wrong, and it is wrong by a factor of ten.
Since the beginning of July, every European film forum has run the same thread. Someone posts that the EU now charges €3 per item on small parcels, someone else multiplies it by the number of rolls in their last order, and the conclusion is that importing film from the UK or Japan has become unaffordable.
The arithmetic is wrong. Not the direction — the duty is real and it does raise the cost of importing — but the magnitude, and the error comes from a reasonable misreading of one word.
The whole question turns on what "item" means. Everyone assumed it means "thing you can hold". The regulation says it means "tariff classification".
What Actually Changed on 1 July
Council Regulation (EU) 2026/382 was adopted on 11 February 2026 and published in the Official Journal on 18 February. Its Article 1 is one sentence long:
Chapter V of Title II of Regulation (EC) No 1186/2009 is deleted.
That chapter contained the €150 customs-duty relief — the rule that let low-value parcels enter the EU without customs duty. It is not suspended or narrowed. It is deleted.
Article 2 then puts a transitional charge in its place:
From 1 July 2026 until 1 July 2028, a customs duty of EUR 3 per item in a consignment the intrinsic value of which does not exceed a total of EUR 150 shall apply instead.
Two dates matter there. It started on 1 July 2026, and it is written to expire on 1 July 2028. Article 3 also obliges the Commission to assess trade-flow diversion by 1 October 2026 — so the first official read on whether this is working arrives in under two months.
The Word That Changes The Bill
Commission Delegated Regulation (EU) 2026/1022 supplies the definition the Council regulation leaves open:
"item" means one or more goods in a consignment sharing the same tariff classification, description and, if provided in accordance with the data requirements applicable to the declaration, the same characteristics.
The Commission's own guidance says the same thing twice over: the duty is "a fixed duty applied per item (not per parcel)" and it is applied "based on tariff classification (not quantity)".
Baker McKenzie's customs team put the consequence in one line that has nothing to do with film and explains it perfectly:
5 T-shirts attract EUR 3 (1 item), while 1 T-shirt plus 1 watch attracts EUR 6 (2 items).
Five of the same thing is one item. Two different things is two items. Quantity is irrelevant; classification is everything.
So What Does A Real Order Cost
Photographic film in rolls sits under heading 3702 of the Combined Nomenclature. Colour film in rolls falls under subheading 3702 54; black-and-white sits under different subheadings of the same heading.
| Order | Items | Duty | Per roll |
|---|---|---|---|
| 10 × Portra 400, 35mm | 1 | €3 | €0.30 |
| 5 × Portra 400 + 5 × Portra 800 | 1–2 | €3–6 | €0.30–0.60 |
| 5 × colour + 5 × black-and-white | 2 | €6 | €0.60 |
| 10 rolls + a changing bag | 2 | €6 | — |
| 1 roll, on its own | 1 | €3 | €3.00 |
The pattern is the opposite of what the panic assumed. The duty punishes small mixed orders and barely touches large single-stock ones. One roll on its own costs €3 in duty. Ten identical rolls cost the same €3.
One honest caveat on that middle row. Whether two speeds of the same colour negative film count as one item or two depends on the declaration type and on how granular the seller's classification is. An H7 declaration — the reduced dataset used for most low-value consignments — classifies at six-digit HS level, which is coarser than the full eight-digit CN code. At six digits, two Portra speeds land together. With a fuller declaration they may not. We are not going to pretend to know which your seller files.
The Part Nobody Is Talking About
Because Article 1 deletes the relief outright rather than replacing it, there is a gap underneath the €3.
The €3 charge applies to goods that are either VAT-exempt on import under the IOSS scheme, or in a postal consignment as defined in the customs rules. A sub-€150 shipment that falls outside both of those categories no longer has any relief to fall back on. It reverts to the normal duty rate for its classification, plus the normal declaration.
For most film orders from a normal retailer this will not bite — they ship IOSS or by post. But a private sale, an unusual courier arrangement, or a seller who has not registered for IOSS can put a small parcel into full customs treatment where previously it went through free. That is a bigger change than the €3, and almost nobody has written about it.
What This Means Depending On Where You Buy
From an EU-established seller: nothing changes at all. No import, no customs declaration, no €3. This is worth saying plainly because the reflex response to customs news is to assume everything got worse. If you buy from a shop or lab inside the EU, this regulation does not touch you.
From the UK or Japan, in bulk, one stock at a time: €3 on the order, which on ten rolls is €0.30 each — well inside the price gap that made you order abroad in the first place.
From the UK or Japan, one or two mixed rolls at a time: this is the ordering habit the change actually penalises. A €25 two-roll order picking up €6 of duty is a 24% surcharge. Consolidating four such orders into one, single-stock where you can, removes most of it.
The practical rule is short: buy fewer, bigger, more uniform parcels. That was already good advice for shipping cost. It is now good advice for duty as well.
What We Could Not Verify
We could not confirm the exact CN and TARIC subheading for 35mm black-and-white film, nor the erga omnes duty rates that apply to the 3702 subheadings. Those rates matter for the gap case above, and we are not going to print a number we have not read in TARIC. If your order falls outside IOSS and outside postal, check the current rate before assuming.
We have also seen it claimed that the regulation entered into force on 9 June 2026. It did not. It was adopted on 11 February, published on 18 February, and entered into force twenty days after publication; the €3 charge itself applies from 1 July. Dates in circulation on this are unreliable, which is part of why the arithmetic went wrong.
The Cost Per Frame Is Still The Number That Matters
Thirty cents of duty on a roll is noise next to what film and developing cost — our film price guide puts a 36-exposure colour roll at $9–18 before you develop it, and the regional price divide shows EU prices rose 5.7% in six months, which is roughly twenty times the duty's effect on a bulk order.
Which is the useful reframe here. The €3 is small and predictable. What is neither is how many frames you waste, which stocks you keep buying without checking whether they work for you, and what your lab charges. Pellica's film roll tracker records the stock, the settings and the lab for every frame you shoot, so your real cost per usable frame comes from your own rolls rather than from a headline about customs.