Product identifiers go mandatory on 1 November and they ride on the H1: what goes on a warehouse release?

The real issue here is not your records. The declaration asks the lodging party for a fact minted elsewhere. The order date is the seller's, the identifier theirs by definition, and you touched neither sale nor customer. That is a data element on the wrong party. There are three ways out.

First, the fact travels with the goods. Nothing obliges a seller to pass its codes down the chain, so make it a condition of the release instruction you already get. That one is yours and costs nothing: two fields on a form that comes from the only party holding them, dated when it comes back empty.

Second, the obligation moves. The reformed code already names the party selling or facilitating the sale as the importer, but it lands long after November and is not yours to shift.

Third, somebody warrants it, and you must ask for that one: the code reaches an information provider only where false data costs duty, and an identifier is not a duty line. A depositor agreement should have carried a data schedule all along.

Strictly speaking those passages do not conflict; they are two halves of one line. The retail sale condition is raised only against the other case, goods sold while in stock. Yours closed before the goods arrived, so nothing is retailed at your facility and the authorisation is not in play.

Where it does bite, the guidance strains, not the Delegated Act. The closing situation in Article 201 is retail remotely, including via the Internet, and the only one not tied to relief from import duty, which was no accident. Hence an amendment to put into that text a limitation it does not yet carry.

You are right the H1 is in scope, and Marcus has the identifier question. Which limb you are on, your receiving bay can answer: the indicator given the authorities is whether what arrived was individual parcels labelled to different destinations, which no stock record sees.