A customs deficit. A tax deficit. A jobs deficit.

Chancellor, stop the duty-free sell-off of German retail.

Every order from Temu, Shein or AliExpress is turnover that no German company makes – with everything that depends on it: profit, trade tax, corporation tax, wage tax, social contributions and jobs. The €3 flat charge is no answer to that. On 15 and 16 October the European Council deals with the EU budget from 2028.^[16][17] Push three things through there:

First: real duty on the real value. The regular customs rate on goods plus freight at the market price, immediately and permanently.

Second: the money follows the consumer. Collection costs and fees go to the country where the goods arrive, not to the port.

Third: platforms are liable. For the value of the goods, for VAT and for product safety, with real checks instead of 65 checks per million goods.^[8]

The €3 flat charge is no answer to that.

The volume: from 1.4 to 5.9 billion consignments in three years

Until 30 June 2026 consignments up to 150 euros were duty-free throughout the EU. In 2022, 1.4 billion such consignments arrived, and in 2025 it was 5.9 billion.^[1] In 2024, 91 per cent came from China.^[2] From 2022 to 2025 a total of around 14.4 billion consignments entered the EU duty-free. Including the first half of 2026 it is likely to be over 17 billion; official figures for 2026 do not yet exist.

Most of these consignments are not cleared in Germany. In 2025 almost a quarter ran through Belgium, with Hungary, the Netherlands and France on top. In Germany itself 8 per cent were cleared.^[1] How many consignments end up with customers in Germany nobody publishes.

The deficit balance for Germany – per year

The statistics record where clearance takes place, not where consumption takes place. The paper therefore calculates with a documented lower bound and a scenario in which 30 to 35 per cent of all EU consignments arrive in Germany. The basis is 2025 with 5.88 billion consignments at an average declared value of 8.82 euros.^[1]

Assumptions by the author: Germany’s share 30 to 35 per cent; 65 per cent of consignments declared 30 to 50 per cent too low (the 65 per cent was estimated by a study from 2016, while the 30 to 50 per cent is not documented^[9]); air freight of 4 to 7 euros per consignment counted fully in the customs value; a customs rate of 10 per cent, with the duty one fifth lower at 8 per cent. VAT on freight at the market price is not payable under the law as it stands; that is a demand of the paper. For scale: 1.76 to 2.06 billion consignments would correspond to 40 to 47 per cent of all 4.37 billion courier, express and parcel items in Germany.^[28]

Three freight prices – and the smallest one reaches customs

Which parcel flies from China to Germany for 8.82 euros including freight? None. A single express parcel with goods up to one kilogram costs 88.10 euros at DHL in the zone that includes China, in the opposite direction.^[22] Temu bundles millions of consignments: industry analyses estimate 4 to 7 euros of air freight per consignment and a good 3 euros for delivery within Europe.^[23][24] At customs the freight is not visible in the 8.82 euros.^[1]

Customs law counts the freight up to the EU border in the customs value; for air freight from China that is 70 per cent.^[18] The platforms’ trick is called “shipping included”: the price paid then counts as the customs value, and freight is not added.^[19] On top of this, according to an estimate from 2016 about 65 per cent of consignments in online retail were declared too low.^[9] So goods pay duty and VAT on a value at which no European retailer could bring them to Germany.

What a real duty of 10 per cent would have brought – across the EU

For textile clothing the customs administration gives a standard duty of 8 to 12 per cent, and for shoes of plastic or textile almost 17 per cent.^[20] Germany also benefits indirectly from EU-wide customs duties: 75 per cent goes into the EU budget and reduces the member states’ contributions.^[12] At 10 per cent duty on the value in the scenario, that would correspond to relief of 1.4 to 1.9 billion euros a year on Germany’s EU contribution; Germany bore around 21.5 per cent of the payments in 2025.^[25]

The €3 solution: too late, blind to value, wrongly distributed

Since 1 July 2026 a duty of 3 euros per item of goods has applied to consignments up to 150 euros, limited until 1 July 2028.^[10] An item of goods is everything with the same tariff number: five T-shirts cost 3 euros, a T-shirt and a watch 6 euros. From 1 November a processing fee of 2 euros per item of goods is to be added.^[11]

Three years too late. The Commission proposed ending duty-free treatment in May 2023.^[9] In 2024 and 2025 alone, over 10 billion consignments arrived duty-free after that.^[1]

Blind to the value of the goods. 3 euros per item of goods, whether the goods cost 5 euros or 140 euros. Anyone packing a lot of identical goods into one parcel pays only once.

The money lands in the wrong place. Duty and fee count among the EU’s own resources; 25 per cent of the duty is kept by the country that clears it.^[12] In the first seven weeks Belgian customs collected 223.7 million euros.^[15] The Bundesbank calls these high collection costs a “hidden rebate” from which Belgium and the Netherlands benefit above all.^[14] The Commission proposes cutting the share to 10 per cent from 2028.^[13]

Freight and undervaluation remain unchecked. VAT still hangs on the declared value. The European Court of Auditors considers the checks in this procedure inadequate.^[29]

It works – and proves the failure. In the third quarter of 2026 the turnover of Temu, Shein and AliExpress in Germany fell by 35.5 per cent to 566 million euros.^[7] A real, value-based duty would have achieved that years earlier.

The higher the true value of the parcel, the larger the gift – precisely with clothing and shoes, where German retail suffers most.

What a German retailer would bring instead

If the same goods are sold in Germany, the value added stays here: wages, profits, rents, logistics and the taxes on them. In German retail in 2024, 13.4 cents of every euro of turnover went on staff costs.^[26] VAT is secured through bookkeeping and tax audits rather than through a declared parcel value. With platforms from China, wages and profits arise predominantly outside Germany.

Demands on the federal government

Real duty on the real value: the regular customs rate on goods plus freight, immediately and without a time limit. The 3 euros remain as a minimum duty; the higher amount is levied.

Freight at the market price: with “shipping included” or “free shipping”, a fixed freight rate per kilogram is included in the customs value and in VAT.

The money follows the consumer: collection costs and the processing fee go to the country of destination; the data for this is available through the IOSS VAT procedure. In the new EU budget from 2028 the collection costs fall to the actual costs.

Platforms are liable: as importer for value, VAT and product safety, with noticeable inspection rates and sanctions.

Transparency: the federal government publishes annually how many low-value consignments arrive in Germany, where they were cleared and what they cost.

Andreas W. HerbCEO MBG Group, Paderborn