After one and a half months of this wonderfulness, it appears that not even the French customs know what to do about it.
The 2€ customs processing fee is per item, not per HS code. 8€ per item is for low value consignments without IOSS number. The upcoming EU wide 3€ customs duty is per HS code.
Couriers are now clearing IOSS parcels centrally in other countries, and those that clear in France such as DPD and Asendia, are using H1 clearance instead of H1 again avoiding the fee. This has left French customs very little to do and French government with no income from this silly thing.
Postal is always cleared at destination, they are the only shipments you can be sure are cleared in France. In order to be applicable to pay the 2€ directly to the French customs, you are expected to register your non-France registered IOSS number with the customs again. The registration worked for a week or so, but now they require a far heavier Siren registration to proceed with this registration.
PDDP will also avoid the 2€ fee as it must use the H1 declaration. Note that any orders over IOSS will also be handled via the system with VATs and duties to be paid to French customs. If you have not calculated and collected them, this will dig into your margins. Since PDDP covers only 7 EU countries, you should not activate the calculation for all EU countries. One way to handle it would be to make France it’s own market and then apply the DDP calculation. Happy to hear about other ways to handle it!
Also, for most countries, they expect merchants to appoint a fiscal representative to handle the TPC. The challenge is, the fiscal rep has exactly as much information on where the parcel is cleared as the merchant if it is postal. So in reality such service does not seem to exist.
Since the French Post is not having anything to do with the collection of the fee, the collection is left to the customs. And our last information from French customs was that they will start sending out penalties OR invoices OR reminders one day. What that is going to be based on and who they will bother, seems to be as unclear to them as it is to us.
So, if shipping postal, you should add for example 2€ multiplied by average number of items to your French shipping rate if you can. And then you might be sent a penalty or an invoice or a reminder one day.
We are always happy to assist at EAS Project: EAS EU & UK Compliance - Automate your EU & UK Compliance (IOSS, GPSR, OSS and... | Shopify App Store .