Executive Summary
- Getting into Europe: land stock in one EU country. That takes customs setup (an EORI number), import VAT at the border, an importer of record, and a VAT registration in that country. That country becomes your base.
- Selling across Europe from that base: one extra registration – OSS – covers consumer sales into all other EU countries. You charge each buyer’s local VAT rate and remit everything through one quarterly filing.
- Storing in more countries (what Pan-EU FBA does) adds a full local VAT registration per country. That is the real price of “faster delivery,” and Amazon’s enrollment page does not lead with it.
- Two systems ride on top of VAT: EPR – packaging fees owed in every country your buyers are in, with mandatory in-country representatives from 12 August 2026 – and GPSR – one EU-based Responsible Person for product safety, named on your packaging and listings.
- Real overhead: VAT + EPR about €2,700/year per storage country, GPSR about €270/year, full Pan-EU around €12,000/year, single-storage-country setup around €5,000/year.
Amazon makes selling across Europe look like a checkbox. Open Seller Central, tick five marketplaces, let the tool translate your listings, collect “up to 30% more sales.”
Full disclosure: we’re a UK company whose Amazon business runs in the US marketplace. We priced this whole apparatus, and we stayed out. Europe is the second-biggest Amazon region on earth, but the overhead below is paid before the first extra unit sells, and for us the math didn’t clear. What follows is the system explained properly, so you can run your own math instead of ours.
Three Systems, Attached to Three Different Things
Everything below gets simpler once you see that Europe runs three separate compliance systems, each attached to a different part of your business:
- VAT attaches to your stock. Where inventory sits determines where you must be registered. Cross-border sales are handled separately, through OSS.
- EPR attaches to your buyers. Packaging fees are owed wherever your parcels get opened, regardless of where they shipped from.
- GPSR attaches once, EU-wide. One Responsible Person covers all 27 countries.
Every Amazon program – EFN, Pan-EU, MCI – is just a different arrangement of the first item. Keep the three attachments straight and none of it is confusing.
Part One: Selling Into Europe
If your company sits outside the EU – US or, post-Brexit, UK – nothing else in this article is available to you until stock is physically and legally inside the union. UK FBA and EU FBA are separate stock pools; Pan-EU does not touch the UK.
Getting stock in means four things:
- An EORI number – your customs identity for imports into the EU.
- Import VAT and duties paid at the border, with an importer of record named on the shipment. Amazon will not be your importer of record; you or your agent must be.
- A VAT registration in your entry country – the country where your stock lands and sits. Several countries require non-EU companies to appoint a fiscal representative before issuing a VAT number, which adds cost and lead time.
- An OSS registration in that same country (details in part two), which unlocks selling to the other 26.
The entry country is a real decision. For most sellers it’s Germany: the largest Amazon marketplace in Europe by a wide margin – roughly France, Italy, and Spain combined – with deep fulfillment infrastructure. Land there, register there, and you have a base from which every other marketplace is reachable.
Part Two: Selling Across Europe
Once your stock is in, one rule decides almost everything. It’s worth reading twice:
Selling into a country means you owe that country’s VAT – handled through one registration, OSS. Storing stock in a country means a real local VAT registration on top.
Worked example: your stock sits in Germany and a buyer in France orders. You charge French VAT at the French rate, and France gets the money. But you don’t need a French VAT number – since July 2021, cross-border consumer sales are declared through the OSS (One-Stop Shop), a single quarterly return filed in your base country that remits each destination country’s VAT for you. One filing, all 27 countries covered.
Two things to be clear about. First, OSS is a registration you must actually obtain – miss it and you’re back in the pre-2021 world, where every destination country demanded its own VAT number. Second, “one filing covers everything” has three exceptions, and they’re exactly where sellers get hurt:
- Domestic sales aren’t cross-border. A sale from a German warehouse to a German buyer goes on a German VAT return, which requires a German VAT number. Store in a country and a chunk of your sales become domestic there.
- Storage forces registration even at zero sales. Stock sitting in a country means registration and ongoing filings there – including nil returns for months that sold nothing.
- Amazon’s stock movements are reportable. Every time Amazon shifts your units between countries, that’s an intra-community transfer between your own VAT numbers. OSS doesn’t cover it; your accountant reconciles it monthly.
Amazon won’t stop you from selling before you’re registered. But Amazon shares data with European tax authorities, and marketplaces are increasingly liable for their sellers’ VAT – so the platform’s tolerance for non-compliance ends abruptly, usually as a blocked account with stock stranded in five countries.
The Three Fulfillment Models
With the rule above in hand, Amazon’s three European fulfillment programs are easy to decode. Each one is a stock-placement decision, which makes it a VAT decision.
EFN – European Fulfilment Network. Stock stays in your entry country; Amazon ships cross-border to buyers elsewhere and charges a per-unit surcharge, typically 30–60% above local fees, with slower delivery promises that cost conversion and Buy Box share. In exchange, your VAT footprint stays put: one registration plus OSS. This is the demand-testing tool.
Pan-EU FBA. Amazon distributes your stock across fulfillment centers in five-plus countries. Buyers get local delivery speeds, you pay local fees – genuinely better for everyone, which is why Amazon pushes it hardest. The cost is the rule above: the moment a single unit lands in a country, you owe that country a VAT registration and ongoing filings. Full Pan-EU means five to seven registrations running in parallel, forever. Sub-trap: the Central Europe discount for allowing storage in Poland and Czechia is a per-unit fee optimization that silently adds two VAT registrations. Run that math before ticking the box, not after the first letter from the Polish tax office.
MCI – Multi-Country Inventory. The middle path: you choose which countries hold stock. If Germany is 60% of your European volume, store in Germany, serve Italy and Spain via EFN, and run one storage registration instead of six. Often beats full Pan-EU on total cost. Underused.
EPR: Packaging Fees That Follow the Buyer
Extended Producer Responsibility makes you pay for the end-of-life of your packaging in each country where it becomes waste – meaning each country your buyers live in, regardless of where you store or ship from.
In practice today: France requires registration with an eco-organism and a unique identifier (the ADEME number) plus eco-contributions and sorting signage on packaging; Germany requires the LUCID packaging register under VerpackG, plus separate schemes for electronics and batteries if relevant. Amazon verifies these numbers and deactivates listings without them – sellers usually discover EPR the day their German listings go dark.
Until now, France and Germany (with Spain and Austria close behind) were the only ones enforcing this against foreign sellers, so many treated EPR as a two-country problem. That ends on 12 August 2026: the EU’s new packaging regulation (PPWR) requires non-EU sellers to appoint an authorised representative for EPR in every member state their parcels reach, triggered by the first sale, not by volume. Reps are service companies and multi-country bundles run a few hundred euros per country per year – not ruinous, but registrations take weeks, so it belongs at the start of your expansion checklist, not the end.
GPSR: One Safety Rep for the Whole EU
The General Product Safety Regulation, in force since December 2024, requires every consumer product placed on the EU market to have a Responsible Person established inside the EU – a real entity holding your compliance documentation, whose name and address appear on the product or packaging and in your listings. Add local-language safety warnings and traceability details (batch, type, serial numbers) to the same checklist.
Scope matters here: GPSR applies to the sale, not the stock. Fulfilling from a German warehouse or shipping FBM straight from your home country to a buyer in Munich – either way, it applies. One rep covers all 27 countries for around €270 a year, and Amazon’s enforcement is the usual: no Responsible Person on file, no listing.
“Translated” Is Not “Localized”
Amazon will auto-translate your listings for free. The grammar will be fine and the keywords will be wrong – German buyers don’t type the dictionary translation of your keywords; they search in their own patterns, compound nouns and all. Localization means keyword research done inside that marketplace, in that language, with real search volume data, then title, bullets, and backend terms rebuilt around it. A few hundred euros per marketplace, and the cheapest lever in the entire expansion. Skip it and you’ll conclude “Germany doesn’t work for our product” when the truth is your listing never entered the auction.
What It Costs, and When It’s Worth It
Real numbers, not agency-brochure numbers. VAT plus EPR runs about €2,700 a year in a country like Germany. GPSR adds roughly €270 for the whole EU. Full Pan-EU – five to seven VAT registrations, EPR reps everywhere, localization in four languages, and the monthly reconciliation of Amazon’s inter-country stock moves – settles around €12,000 a year before you sell a single extra unit. The single-storage-country version – stock in Germany, EFN for the rest – is about €5,000.
That buys a simple threshold: if your home marketplace isn’t consistently doing at least €15,000–20,000 a month with margins you trust, fix that first. Europe will still be there. When you do go, the order matters: Germany first – if the thesis doesn’t work there, it doesn’t work; France second – sizeable, less saturated in many categories, and heavy enough on compliance to keep out lazy competitors; Italy and Spain after, served by EFN long before they justify local storage.
And the sequencing that keeps you out of trouble: launch on EFN from your entry country, prove demand with real orders, then flip to MCI or Pan-EU when the EFN surcharges you’re paying exceed the compliance cost of storing locally. At 30–60 cents of surcharge per unit, that crossover typically sits in the hundreds of cross-border units per month, per country. Below that, EFN’s higher fees are what you pay to not run six VAT registrations for a market you haven’t proven.
Bottom Line
We looked at all of the above and chose not to expand into the EU. That’s a data point, not a recommendation – our margins, catalog, and appetite for paperwork are not yours, and plenty of sellers clear this bar and print money in Germany.
What is a recommendation: treat each European country as its own P&L, register before you store, get your EPR representatives in place before 12 August, and never mistake a checkbox in Seller Central for a compliance strategy. Amazon handles the logistics. The liabilities are yours.