The EU Is Scrapping Its Duty Free Threshold. Here’s What It Means in Practice
See how the EU’s new €3 duty works for parcels under €150, including mixed carts, IOSS, VAT, the €2 handling fee, and merchant pricing.
By border.bot team, , 22 min read

The EU’s duty-free threshold for imported consignments up to €150 ended on July 1, 2026, and a temporary €3 customs duty now applies per tariff category. The charge is not €3 per parcel or per item, and a separate €2 Union handling fee is scheduled to begin on November 1, 2026.
Rules as of October 14, 2026.
The common merchant mistake is treating the old €150 rule as a complete tax exemption. It wasn't. Since July 1, 2021, import VAT has generally been due on commercial goods from outside the EU regardless of value. The old threshold mainly removed customs duty. Merchants that still price low-value orders around the old rule can understate landed cost, especially when a cart contains products in several tariff categories.
The cost is not limited to duty. A wrong calculation can produce an underpriced checkout, a delivery bill the customer did not expect, a marketplace margin shortfall, or a declaration that does not match the goods.
The practical answer
- The EU’s former €150 customs-duty relief ended on July 1, 2026, but the replacement transitional rule is a €3 duty per tariff category for qualifying consignments through July 1, 2028.
- Five T-shirts under one tariff subheading generally create one €3 duty charge, while a T-shirt and a watch under two tariff subheadings create €6.
- Import VAT is separate from the €3 customs duty, and IOSS can still collect the sale VAT at checkout for consignments up to €150.
- A Union handling fee of €2 is scheduled to apply from November 1, 2026, separate from customs duty and generally imposed on the business side.
- Merchants should classify every product, count tariff categories at consignment level, update pricing, and pass accurate product data into customs systems.
What changed on July 1, 2026?#
The EU changed the customs treatment of low-value commercial imports on July 1, 2026. Council Regulation (EU) 2026/382 abolished the historical customs-duty relief for consignments with an intrinsic value of no more than €150. During the transition, qualifying consignments receive a flat €3 customs duty for each tariff subheading or item category.
De minimis is the value below which a shipment receives a specified customs or tax relief. In the EU rule discussed here, the €150 figure was a customs-duty threshold, not a general exemption from import VAT.
The transitional €3 measure applies from July 1, 2026 through July 1, 2028. It covers goods sold through distance sales and goods in postal consignments with an intrinsic value of no more than €150, subject to legal exclusions and certain preferential or Customs Union treatments. The Council Regulation is the legal basis.
The charge is calculated by tariff category in the consignment. Five T-shirts classified under one tariff subheading create one €3 duty charge. One T-shirt and one watch classified under two tariff subheadings create two charges, or €6. Physical unit count does not control the result.
The rule is non-discriminatory. The €3 duty applies regardless of the goods’ country of origin or logistics operator, within the scope of the transitional measure. A parcel from China and one from the United States are not assigned different versions of the charge simply because of origin.
The European Commission’s guidance says the measure applies whether import VAT is handled through IOSS, special arrangements, or the standard VAT procedure. IOSS changes when and how VAT is collected. It does not remove the €3 customs duty.
The EU low-value import timeline
July 1, 2021
Import VAT becomes due regardless of value
Commercial goods imported from third countries are generally subject to EU import VAT. The €150 customs-duty threshold was not a general VAT exemption.
July 1, 2026
The old customs-duty relief ends
The EU introduces a temporary €3 customs duty per tariff category for qualifying consignments with an intrinsic value of no more than €150.
November 1, 2026
Union handling fee begins
The European Commission’s current reform guidance states that a separate €2 Union handling fee will apply to small parcels.
July 1, 2028
Planned replacement by normal tariff treatment
Once the EU Customs Data Hub is operational for e-commerce, the temporary €3 system is intended to be replaced by the normal customs tariff applicable to the product and origin.
European Commission and Council of the European Union, 2026
The timeline separates the end of the customs-duty relief, the temporary duty, and the later handling fee. Each affects the import process differently.
How is the €3 EU duty calculated?#
The €3 EU duty is calculated by counting the tariff subheadings or item categories represented in a qualifying consignment, then multiplying that count by €3. The calculation is not based on physical units, parcel count, or a percentage of customs value.
The formula is:
Temporary customs duty = number of tariff categories in the consignment × €3
Products that fall under the same relevant tariff subheading are grouped for this charge. Products requiring different classifications create separate categories.
Five identical T-shirts classified under one tariff subheading create €3 in duty. Ten units under that same subheading still create €3, not €30. Add a watch classified under another subheading, and the consignment has two categories. The duty becomes €6.
This creates a pricing problem for mixed carts. A customer sees one order, while customs sees several categories. The catalog therefore needs classification data, not only a product title and selling price.
A product’s commercial name is not enough to determine its tariff category. Material, construction, intended use, gender or age category, composition, and technical characteristics can affect classification. “Shirt,” “case,” or “charger” may not provide enough information.
The relevant EU tariff subheading may depend on classification levels beyond the six-digit Harmonized System code. Merchants should preserve the classification used for the declaration and avoid assuming that similar retail descriptions receive identical customs treatment.
The €150 limit still matters. A €149 consignment with one tariff category receives €3. The duty does not rise because the order is close to €150. The threshold determines whether the transitional rule applies; category count determines the duty amount.
If the consignment exceeds €150, the temporary low-value formula is not the applicable calculation. Normal customs tariff treatment applies instead, including the product’s classification and origin rules.
Is the €3 charge per item, parcel, or tariff code?#
The €3 charge is per tariff category, not per physical item and not per parcel. A parcel can contain many units and generate one €3 duty if all goods fall under one relevant tariff subheading. A small parcel can generate several €3 charges if its contents require several classifications.
The practical question is: how many tariff categories are represented in the declared consignment?
This is different from counting stock keeping units. Four SKUs may still contain one tariff category if the products share a classification. Two SKUs may require several categories if they differ in material, function, or other classification characteristics.
A gift set does not automatically have one classification because it has one retail SKU. Customs treatment can depend on the set’s composition and presentation. The merchant’s customs team or broker must establish how the bundle is declared.
Marketplaces face the same issue. A marketplace may know that a customer bought three listings, but the declaration needs product descriptions, values, quantities, and classifications. A single marketplace category is not a substitute for customs classification.
Merchants should store an EU-relevant classification for each product that may enter an EU member state. They should also retain the evidence used to support that classification. The classification should flow to the order, parcel, declaration, and landed-cost calculation.
Product identifiers may be declared voluntarily from July 1, 2026 and become mandatory for relevant low-value e-commerce imports from November 1, 2026, according to the European Commission’s guidance.

A useful internal data model should distinguish:
Product SKU
Product description
Country of origin
Intrinsic value
EU customs classification
Quantity
Unit value
Consignment identifier
VAT collection method
Declarant or indirect representative
Count categories after the order is assembled into a consignment. Counting independently at the SKU level can overstate the charge. Counting only the main product can understate it.
Does IOSS remove the €3 duty?#
IOSS does not remove the €3 customs duty. The Import One-Stop Shop lets a seller or marketplace collect and remit import VAT at checkout for eligible consignments up to €150, while the temporary customs duty remains separate. IOSS solves VAT collection timing, not the customs-duty charge.
Before IOSS, a buyer could pay the seller and then encounter import VAT and carrier collection charges when the parcel arrived. IOSS lets the seller or marketplace collect the VAT on the distance sale and report it through the scheme.
The European Commission’s low-value consignment guidance explains IOSS for eligible goods. When IOSS is used, the importation is exempt from additional import VAT because the VAT was collected on the sale.
That exemption does not turn the €3 duty into VAT. The Commission’s October 2026 VAT addendum treats the customs duty and VAT as separate items.
A merchant using IOSS therefore needs two calculations:
VAT on the underlying distance sale, collected at checkout under the destination rate.
The €3 customs duty, calculated from the number of tariff categories.
The customer may see neither charge as a separate import bill. The seller may include the cost in the product price. A marketplace may include it in seller fees. A carrier may account for it in shipping or customs service charges.
IOSS also does not remove the need for accurate classification. A generic description such as “merchandise” cannot support a mixed consignment declaration.
Who is responsible for paying the duty?#
The business side of the transaction is generally responsible for the €3 duty. The declarant may be the seller, importer, IOSS holder, special-arrangements user, or indirect representative, depending on the import setup. Consumers are responsible only in residual cases involving a member-state web-based declaration system.
The customer is not normally the party asked to make a separate customs-duty payment under the ordinary ecommerce flow. That does not mean the customer bears no economic cost. The seller can recover the amount through prices, shipping charges, or checkout fees, and a marketplace can recover it through seller charges.
This distinction matters when choosing delivery terms. Under delivered duty paid, the seller or logistics partner generally handles the import cost and presents an all-in price. Under delivered at place, the customer may face import charges or carrier fees. The DDP versus DAP guide covers that commercial choice separately.
A marketplace may collect VAT while the seller supplies product data and a carrier files the declaration. Contracts and workflows should state who supplies the classification, who pays the duty, and who handles corrections.
A seller should also check whether its logistics provider charges an administrative fee in addition to the legal customs duty. The €3 duty is not the same as a carrier’s clearance or brokerage fee.
What is the Union handling fee, and when does it start?#
The Union handling fee is a separate charge intended to cover customs-processing costs for small parcels. The European Commission’s current customs-reform guidance says the fee will be €2 from November 1, 2026. The fee is not the €3 customs duty and should be modeled separately.
Customs duty is a charge on imported goods under the tariff system. The handling fee supports processing costs. Both affect landed cost, but they have different purposes.
The Council’s September 2026 reform update describes the broader reform. The Commission’s EU Customs Reform page currently states the €2 amount and November 1, 2026 start date.
The handling fee is imposed on the business side rather than directly on consumers. Sellers, marketplaces, and carriers may pass it through in prices, shipping charges, or checkout fees. A customer should not be assumed to see a separate €2 line.
The €2 fee is also separate from any carrier handling or brokerage charge. Merchants should check the invoice and import arrangement before labeling a post-arrival charge as the Union handling fee.
A cost model used before November 1, 2026 may need a second fixed charge afterward. It must also account for the €3 duty’s category count rather than applying one flat amount to every order.
How does import VAT fit into the calculation?#
Import VAT is separate from the €3 customs duty and the Union handling fee. Since July 1, 2021, commercial goods imported from third countries have generally been subject to import VAT regardless of value. For consignments up to €150, IOSS can collect VAT at checkout instead of requiring additional import VAT at the border.
A merchant should keep the calculation order clear:
Determine whether the shipment qualifies for the low-value transitional customs rule.
Determine the number of tariff categories.
Calculate the €3 customs duty.
Determine how VAT is collected.
Add the applicable Union handling fee from November 1, 2026.
Add shipping and carrier or customs-service fees.
The customs duty can affect the taxable base under applicable VAT rules. Merchants should not hard-code a universal formula that treats VAT as a percentage of the product price alone. The calculation depends on the destination, taxable value, import arrangement, and whether VAT was collected through IOSS.
Germany’s standard VAT rate is 19%. France’s standard VAT rate is 20%. The border.bot Germany page and border.bot France page record those live country data points, along with the €150 low-value duty threshold and €3 duty per tariff classification.
The VAT rate does not change the €3 charge. A one-category €149 shipment to Germany and one to France each have €3 in temporary customs duty, although their VAT calculations differ.
| France | VAT | 20% | ec.europa.eu | |
| Germany | VAT | 19% | ec.europa.eu |
border.bot live data from each country's official publications, updated 2026-10-11
The live country data keeps destination VAT rates current while the temporary customs measure remains date-bound. Use the destination country, not the warehouse country, when selecting VAT treatment.
- Low-value threshold
- €150intrinsic value Transitional customs rule through July 1, 2028
- Temporary customs duty
- €3per tariff categ Applies from July 1, 2026 through July 1, 2028
- Union handling fee
- €2from November 1, Separate from customs duty, according to current Commission guidance
- Germany standard VAT
- 19% Destination VAT rate recorded by border.bot
European Commission, Council of the European Union, and border.bot, accessed October 14, 2026
What does the change look like in a real order?#
A €20 order from China to Germany containing three differently classified product categories pays €9 in temporary customs duty before VAT, shipping charges, carrier fees, or any Union handling fee. The amount comes from three categories multiplied by €3, not from the order’s low value.
Suppose the order contains one cotton T-shirt, one watch, and one phone charger. The exact classifications must be verified from the product facts, but assume the declaration uses three different tariff categories. The intrinsic value is €20, so the order remains within the no-more-than-€150 transitional scope.
The duty calculation is:
Category one: €3
Category two: €3
Category three: €3
Temporary customs duty: €9
If the seller uses IOSS, the seller collects applicable German VAT at checkout on the distance sale. The import is exempt from additional import VAT because sale VAT was collected upfront. IOSS does not remove the €9 customs duty.
From November 1, 2026, current Commission guidance says the separate Union handling fee is €2. The business-side import cost would then include €9 in temporary duty and €2 in handling fees, before shipping or other carrier charges. The customer may see those costs embedded in the price.
Now change the order to five T-shirts classified under one tariff subheading. The intrinsic value is still €20, but the temporary duty becomes €3. The number of units increased, but the category count fell from three to one.
A €149 order with one tariff category also creates €3 in temporary duty. The €149 value does not cause a larger charge than the €20 order with one category. The threshold decides whether the transitional rule applies, while category count decides the number of charges.
On a €20 order, €3 equals 15% of goods value before VAT and shipping. On a three-category order, €9 equals 45%. The seller may absorb or pass through the cost, so these are not necessarily customer-facing percentages.
Run your own low-value mixed order to estimate duty, VAT, fees, and landed cost using live destination data.
The breakdown will appear here
Every duty, fee and tax line with the rate used, the de minimis check, any conditional measures, and the total your customer pays to receive the parcel.
- Duties
- Customs duty and any additional duties for this origin
- Fees
- Government processing fees where they apply
- Taxes
- Import VAT or GST, charged on value plus duty
The landed-cost calculator is useful when the product mix, destination, and VAT method are known. Run each distinct classification pattern, not only one average order value.
Why are low-value parcels the focus of the reform?#
Low-value parcels became a large customs and product-compliance workload because ecommerce volume grew rapidly. The European Commission reports that almost 5.9 billion low-value items were shipped directly from third countries to EU consumers in 2025, and that imported low-value ecommerce items grew 26% between 2024 and 2025.
The Commission says low-value consignments represented 97% of EU import volume but only 2% of import value in 2025. That means customs handles a very large number of relatively small entries.
Origin concentration is also significant. The Council reported that 91% of ecommerce shipments valued below €150 came from China in 2024. A September 2026 Council update said more than 90% of ecommerce parcels arriving in the EU came from China in 2025. Those figures explain the policy focus, but they do not create a China-specific duty. The €3 rule is non-discriminatory.
Product safety is another concern. Targeted inspections across member states in 2025 found that more than 60% of checked products in categories including cosmetics, personal protective equipment, food supplements, toys, and electronics failed EU standards because of missing labels, prohibited ingredients, or absent safety documentation, according to the European Commission’s guidance.
A correct tariff code does not make an unsafe product compliant. Sellers need required labels, safety documents, ingredient information, and product records for the destination market.

The charges may encourage sellers to consolidate goods, adjust prices, or move inventory into EU fulfillment locations. Each choice has tradeoffs. Consolidation can reduce import events but may change category count. EU inventory can improve delivery speed but creates a different import and VAT structure when stock enters the EU.
What should merchants change in checkout and pricing?#
Merchants should update the landed-cost model, product classification data, customer disclosures, and margin rules. The key change is replacing “under €150 means no duty” with a category-based calculation that applies through July 1, 2028.
Each product that may ship into the EU needs a verified customs classification and country of origin. Origin is not automatically the ship-from country. The country-of-origin guide explains that distinction.
Calculate category count after cart assembly. Checkout can group products by customs category and apply the transitional duty once for each group. The seller need not show tariff codes to customers, but the internal calculation must be auditable.
Pricing options include:
Include the expected cost in product prices.
Add a clearly described import or delivery charge.
Use DDP shipping and quote an all-in landed price.
Keep the duty in the margin model while presenting one delivered price.
Charge a marketplace or fulfillment fee to the seller.
No single presentation is mandatory for every seller. The legal responsibility and customer experience should match the contract, delivery term, and customs process.
A flat “EU import fee” can be inaccurate for mixed carts. Calculate dynamically or use a conservative margin assumption. A single average can lose money on multi-category orders.
Merchants selling through marketplaces should confirm who handles IOSS, who acts as declarant, and who supplies customs data. VAT collection does not necessarily mean the marketplace absorbs customs duty or handling fees.
EU low-value import readiness checklist
0/10What paperwork and product data matter most?#
Customs paperwork needs to identify the goods well enough for classification and valuation. A declaration should not rely on vague descriptions such as “accessories,” “gift,” or “sample.” It needs a product description, value, quantity, origin, and classification.
For each item, retain the commercial description used in the declaration, relevant material or function, unit price, quantity, and classification. The order record should show the relationship between the SKU and the customs category used to calculate duty.
Product identifiers may be declared voluntarily from July 1, 2026 and become mandatory for relevant low-value ecommerce imports from November 1, 2026. Ask the marketplace or carrier which identifiers it expects and how they map to catalog records.
The identifier requirement does not replace classification. It helps match products to data and risk systems, while classification still determines customs treatment.
Country of origin needs evidence. Supplier invoices, manufacturing records, bills of materials, and production steps can support the analysis. “Ships from China” is not always the same as “made in China,” and an EU fulfillment center does not automatically create EU origin.
Merchants should preserve the VAT method used for each order. If IOSS is used, its information must be handled through the approved declaration process. Under the standard procedure, import VAT may be collected at import instead.
The best setup has one controlled source of truth for classification and origin. When materials, function, packaging, or manufacturing location changes, the product should trigger a classification and origin review.
What happens after July 1, 2028?#
The temporary €3 system is intended to end when the EU Customs Data Hub becomes operational for ecommerce, currently scheduled for July 1, 2028. Normal customs tariff treatment applicable to the product and origin is then intended to replace the category-based charge.
That system may be more precise than a flat €3 per category, but it may also be more complex. Ordinary tariffs can depend on classification and origin. Preferential-origin treatment may matter in some cases, while Customs Union arrangements can have their own treatment.
Merchants should not build a permanent pricing rule around €3. Store the classification and origin data needed for the normal tariff, not only a temporary category count.
The Commission must assess whether trade-flow diversion has occurred by October 1, 2026 and monthly thereafter. It may propose extending the €3 measure to all consignments up to €150. It must also assess by December 1, 2027 whether the central customs infrastructure will be operational by July 1, 2028, according to Regulation (EU) 2026/382.
These review dates mean further legal or operational guidance may follow. Merchants should monitor official updates and avoid hard-coding an unchangeable end date into customer messaging.
For developers, rules should be versioned by effective date. An order created before July 1, 2026, shipped after that date, or arriving after November 1, 2026 may need different fee treatment depending on the declaration facts.
How should merchants test their implementation?#
Merchants should test by category count, value boundary, VAT method, destination, and fee date. A single test order will not expose errors created by mixed carts or the Union handling fee.
At minimum, test:
€20 with one tariff category.
€20 with three tariff categories.
€149 with one tariff category.
€150 with one tariff category.
A consignment over €150.
Five units in one category.
Two products in two categories.
An IOSS order.
A non-IOSS order.
A shipment before and after November 1, 2026.
Missing classification data.
A ship-from country different from origin.
The boundary test should use the legal value definition applied by the customs process. Do not assume the merchandise subtotal always equals intrinsic value. Shipping, insurance, discounts, and other components may be treated differently under applicable rules.
The system should log why it assigned a duty amount. A useful audit record states that the consignment qualified for the transitional rule, contained three categories, received €3 for each, and used the selected VAT method.
If checkout calculates duty and the carrier calculates it again, compare the systems regularly. Differences can come from classification, category grouping, value definitions, or timing. An unexplained difference should not be solved by adding a generic buffer to every order.
border.bot can help with the two data questions behind the calculation: which classification best fits the product and what the destination landed cost looks like. Use the HS code classifier for classification and the landed-cost calculator for duties, taxes, fees, and landed cost.
For high-volume flows, developers can use the border.bot API documentation to classify products and calculate landed cost programmatically. The result remains an estimate until the seller confirms classification and declaration facts.

If the code is uncertain, product data is incomplete, or destination rules cannot be retrieved, the system should not quietly show zero duty. Flag the order, use a documented fallback, or prevent a misleading all-in promise.
What should shoppers and merchants understand about the customer price?#
The customer may pay more after the rule change, but the legal charges may not appear as separate lines. A seller can absorb the cost, include it in the item price, add it to shipping, or pass it through a marketplace or carrier charge.
For a low-value item, the fixed duty is large relative to the order. A €3 charge on a €20 one-category order is 15% of goods value before VAT and shipping. A €9 charge on a €20 three-category order is 45%. Those percentages describe the duty’s scale, not necessarily the customer’s final bill.
The €150 threshold no longer supports a blanket claim that an order is duty-free. Import VAT already applied to commercial goods from third countries, and the temporary customs duty now applies to qualifying consignments. IOSS improves VAT predictability but does not remove customs duty.
A DDP merchant should decide whether the displayed price includes temporary duty and expected handling fees. A DAP merchant should explain that local import or delivery charges may apply. The wording should match the actual carrier and customs process.
Returns also need review. A returned item may have generated import and handling costs. Refunds, re-imports, and duty recovery may not reverse through the same system as the original sale VAT.
What is the bottom line for EU sellers?#
The EU did not replace the old €150 rule with a universal €3 charge per parcel. The old customs-duty relief ended, and the temporary replacement charges €3 for each tariff category in a qualifying low-value consignment. That distinction controls the calculation.
Merchants should update product classification, origin data, consignment-level category counting, VAT treatment, pricing, and product identifiers. They should also prepare for the separate €2 Union handling fee from November 1, 2026.
A €20 order with one category creates €3 in temporary duty. A €20 order with three categories creates €9. A €149 order with one category still creates €3. Order value alone is no longer enough.
IOSS remains useful for collecting and remitting VAT at checkout. It does not remove the €3 duty. Build the rule as a changeable calculation path, keep classification and origin data, and make the customer promise match the actual import arrangement.
Sources#
Council Regulation (EU) 2026/382, EUR-Lex and Official Journal of the European Union, February 18, 2026.
Guidance and legal text on temporary flat fee on low-value imports, European Commission, June 8, 2026, updated July 20, 2026.
Council gives final green light to new customs duty rules for small parcels, Council of the European Union, February 11, 2026.
EU customs: Council greenlights landmark reform, Council of the European Union, September 3, 2026.
EU Customs Reform, European Commission, accessed October 14, 2026.
Goods bought online, European Commission, accessed October 14, 2026.
Customs formalities for low value consignments, European Commission, accessed October 14, 2026.
VAT treatment of the €3 customs duty and announced Union handling fee, European Commission, October 6, 2026.
VAT e-commerce explanatory notes, European Commission, September 30, 2020.
Germany import taxes and de minimis data, border.bot, live data October 11, 2026.
France import taxes and de minimis data, border.bot, live data October 11, 2026.
Midday press briefing: New e-commerce duty for small packages, European Commission Audiovisual Service, July 1, 2026.
Customs: Council takes action to tackle the influx of small parcels, Council of the European Union, November 13, 2025, reviewed February 5, 2026.
EU €150 duty threshold FAQ
Is the EU €150 duty-free threshold gone?
Yes. The historical customs-duty relief for consignments with an intrinsic value of no more than €150 ended on July 1, 2026. A temporary €3 duty now applies per tariff category for qualifying consignments through July 1, 2028.
Is the €3 EU duty charged per parcel?
No. The temporary duty is charged per tariff subheading or item category. Five T-shirts under one tariff subheading generally create €3 in duty, while products under three tariff categories create €9.
Does IOSS remove the EU €3 customs duty?
No. IOSS collects and remits VAT on eligible distance sales up to €150. The €3 customs duty remains separate and still applies when the consignment falls within the transitional rule.
Who pays the new EU small-parcel duty?
The seller, importer, IOSS holder, special-arrangements user, or indirect representative is generally responsible as declarant. Consumers are responsible only in residual cases involving a member-state web-based declaration system.
When does the EU €2 handling fee start?
The European Commission’s current customs-reform guidance states that a separate €2 Union handling fee starts on November 1, 2026. The fee is separate from the €3 customs duty.
Does the customer always see a separate €3 or €2 charge?
No. The business may absorb the cost or pass it through in product prices, shipping charges, marketplace fees, or checkout charges. The rules do not require every customer to see a separate line.
Does the €150 threshold include import VAT?
The former €150 threshold concerned customs duty, not a general VAT exemption. Import VAT has generally applied to commercial goods from third countries since July 1, 2021, regardless of value.
What should a merchant change first?
Start with product classification, country-of-origin data, consignment-level category counting, VAT method, and customer pricing. Then test mixed carts and prepare product identifiers for the November 1, 2026 requirement.
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