Amazon FBA Europe: what has to be finished before your goods land

Why Amazon FBA Europe is harder than Amazon US

In the US, a Vietnamese factory can open an account, send stock to FBA and start selling within weeks. Sales tax on marketplace sales is collected and remitted by Amazon under each state's marketplace facilitator law, though that does not by itself remove every state registration or income-tax obligation. Customs is a single federal system. The label is in one language. Europe does not work that way, and that is why Amazon FBA Europe is one of the hardest routes a Vietnamese manufacturer can choose.

That does not mean the US route carries no compliance stack. For food, FDA requires food facility registration, prior notice for each shipment and a US agent, and the importer has to operate an FSVP programme; tariff conditions on Vietnamese goods also change over time. The US is lighter on tax and language, not on product safety. We treat that route separately in Amazon FBA for the Americas.

The EU is a single market for goods but still twenty-seven tax systems and twenty-seven enforcement authorities. VAT is registered country by country, wherever your stock physically sits. EPR, extended producer responsibility for packaging, is registered separately in each country, with its own authority, its own number and its own reporting cycle. Product law is harmonised at EU level, but the label has to be in a language the consumer in that country understands. And Amazon is the first inspector, not the state: the platform collects EPR numbers for a growing list of countries, checks them against the public registers, and blocks listings when a number does not validate.

The most common failure is not failing to sell. It is selling well for three months and then losing your German listings in November over a missing LUCID number, with inventory already sitting in German FBA warehouses and ad spend already committed. Both VAT and EPR obligations run from the first sale, not from the date you register. Registering late does not reset the clock: expect back-dated VAT with interest and penalties, back-dated EPR fees where the scheme allows retroactive licensing, and fines plus removed listings where it does not. The exact treatment varies by member state and by scheme. Fixing it usually costs more than doing it in order.

EORI, VAT and OSS: the numbers you need before the first shipment

The first two numbers below have to exist before the goods land, not after. The third depends on how you sell.

The point most people get wrong is the EU-wide distance selling threshold. It is only available to a supplier established, or permanently resident, in a single member state. A Vietnamese-established seller falls outside it entirely, so there is no threshold to fall under: the registration obligation arises as soon as the stock arrives. The small-business scheme in force since 1 January 2025 is likewise open only to EU-established businesses.

Another point few people know: since 1 July 2021, for sellers not established in the EU, Amazon is the deemed supplier for B2C sales made from stock already inside the EU, meaning Amazon collects and remits the output VAT on your behalf. That does not remove your obligations, and it does not merge two different numbers into one. EORI is the customs identifier that lets you act as importer of record. Your VAT registration in the country of storage is what lets you recover the import VAT, use any deferment or postponed-accounting mechanism, report intra-community movements of your own goods, and file the periodic returns. Many of those returns will show no output VAT, because Amazon has already accounted for it, but they still have to be filed.

Paired with this is the Incoterm decision. Under DDP the seller carries import duty, import VAT and clearance; under DAP those fall to the consignee. But Incoterms allocate cost and risk contractually between the parties. Who is the legal importer of record, and who may recover import VAT, is a separate question decided by customs and VAT law. In FBA there is no buyer to clear the goods: Amazon's stated policy is that it will not act as importer of record or declared consignee for FBA inbound shipments, so the seller or its agent has to be the importer whichever term you choose. Verify the current policy in Seller Central before you book freight.

The recovery side needs stating plainly, because this is where real money goes. Import VAT is recoverable only by the party that imports the goods in its own name, owns them, uses them for its own taxable business, and is VAT registered in the country of import. A freight forwarder, a customs broker or an "IOR service" that never owns the goods generally cannot deduct the import VAT; the amount does not disappear, it is recharged to you. So do not let the first shipment move ahead of the VAT number. If it has to move first, put the import VAT on that shipment into your landed cost as a cost, not as something you plan to recover.

• EORI: your business identifier with EU customs, required to act as importer of record, issued by one member state but valid across the whole EU.
• A VAT number in the country of storage: if your stock sits in a German FBA warehouse, you register for VAT in Germany. There is no exemption threshold for businesses not established in the EU. This is also the number that lets you recover import VAT — the EORI does not.
• OSS: one single return covering VAT on cross-border B2C sales within the EU. It matters only where you are the supplier for VAT: sales off Amazon, your own webshop, or cases where the deemed-supplier rule does not apply. If Amazon is the deemed supplier for all your orders, there may be nothing to declare through OSS at all. And OSS never replaces local VAT registration in the country where the stock is held.

Packaging EPR: LUCID in Germany, the ADEME number in France, Ecoembes in Spain

Packaging EPR is a financial obligation on every piece of packaging you place on the market: cartons, bags, labels, shrink film, retail boxes. Each country runs its own system.

Amazon collects and validates EPR numbers before it will let a listing run, and the set of countries keeps growing: it started with Germany, then France, and now covers further stores including Spain, Austria and the Netherlands. Do not assume it stops at Germany and France — check the current country and category list in Seller Central. If your product is electrical equipment or contains batteries, Germany adds two more regimes: ElektroG, with registration at stiftung ear, and BattG for batteries, also handled through stiftung ear. Both must be complete before the product is placed on the German market, and a producer without a German establishment generally has to appoint an authorised representative established in Germany in order to register at all.

Running alongside EPR is product conformity. CE marking is mandatory only for categories covered by EU harmonised legislation such as toys, electrical equipment, personal protective equipment and machinery; tea and food are not CE marked. Since 13 December 2024 the General Product Safety Regulation (EU) 2023/988, GPSR, applies to consumer products not covered by sector-specific rules, and requires an economic operator established in the EU to be responsible for the product, with its name and address travelling with the product. Food and feed are outside GPSR; for food the equivalent requirement is a food business operator established in the EU. Either way, this is the point a non-EU seller cannot solve with Vietnamese paperwork.

One more date belongs in your plan. The Packaging and Packaging Waste Regulation (EU) 2025/40, PPWR, starts to apply from 12 August 2026 and progressively replaces the directive framework that VerpackG and Royal Decree 1055/2022 were built on. The part that matters most for a Vietnamese seller: a producer not established in the member state where it first makes packaging available has to designate an authorised representative for EPR in that member state, and the reliefs being discussed for EU-established producers do not extend to non-EU producers. The implementing detail and national transposition are still settling; confirm the current position before you rely on any description of it, including this one.

• Germany, under VerpackG: you must register in the LUCID register operated by the Zentrale Stelle Verpackungsregister and, separately, hold a contract with a dual system. Two steps, not one.
• France: you need a unique identification number (identifiant unique) issued by ADEME for each waste stream, together with a contract with an approved compliance scheme.
• Spain: under Royal Decree 1055/2022, packaging producers must register in the producer register. For household packaging you must join a collective scheme, most commonly Ecoembes, though others exist. Commercial and industrial packaging follows a separate route and can in principle be met through an individual system.

Food is twice the work: FBO registration, EU labelling and HS codes, the Matelier case

Matelier is our own matcha and tea brand, selling in the EU. It runs the heaviest compliance stack a Vietnamese manufacturer is likely to meet: VAT in Germany, France and Spain with OSS, packaging EPR with LUCID in Germany and Ecoembes in Spain, food business registration, EU food labelling, EORI, HS classification and DDP import.

Food adds two layers. First, under Regulation (EC) 852/2004, a food business operator must be registered with the competent authority of the member state. Second, the label has to comply with Regulation (EU) 1169/2011: product name, ingredient list, allergens emphasised within that list, quantitative ingredient declaration (QUID) where it applies, net quantity, date of minimum durability, storage conditions, nutrition declaration, and the name and address of the responsible food business operator established in the EU, written in a language easily understood by consumers in the country of sale. The operator named on the label is the one under whose name the food is marketed, or the importer where that operator is not established in the EU. Selling in three countries means three language versions, and those three can sit on a single multilingual label.

HS classification decides the rest. The EU uses the eight-digit Combined Nomenclature, and the ten-digit TARIC code on import; that code sets the customs duty and affects whether the product qualifies for a reduced VAT rate. Germany's reduced VAT rate is currently 7% and tea generally falls within the reduced-rate list, but blending, added flavourings, added ingredients and ready-to-drink formats can all move the product to a different code and to the standard rate. Both the rate and the classification can change. Confirm the code and the rate for your specific SKU with a binding tariff ruling or a German tax adviser, before you print labels and before you fix retail pricing.

The operational lesson from Matelier is simple: the label is the bottleneck. Redesigning packaging after the container has reached the FBA warehouse can easily cost more than the shipment itself, because you have to over-label or destroy stock while the listing sits idle.

Pan-EU or one warehouse: this decision sets how many tax registrations you carry

Amazon gives you two ways to cover Europe. EFN keeps your stock in one country and ships to the others: you only register for VAT where the stock sits, and cross-border sales are reported through OSS where you are the supplier for VAT. If Amazon is the deemed supplier for those sales, Amazon accounts for the VAT and you may not need an OSS registration at all — check before you open one. In exchange you pay a higher per-order fee and deliver more slowly.

Pan-EU is the opposite. Amazon places your inventory in the participating storage countries, and every country it stores in is another VAT registration. At the time of writing the storage countries are Germany, France, Italy, Spain and Poland; Amazon also requires a Netherlands offer for Pan-EU products, and storage in the Czech Republic and Poland against German-held inventory runs through a separate programme. That set changes, so confirm the current list in Seller Central before you budget registrations. Every movement of your own goods between member states is a reportable transaction: it goes on the VAT return, on the recapitulative statement (EC Sales List) in the country of dispatch, and on Intrastat once that country's threshold is exceeded. In exchange, per-order FBA fees are lower and delivery speed is much better.

The practical advice: open one country first, usually Germany, because it is Amazon's largest marketplace in the EU by net sales and also among the strictest on compliance. If you can operate in Germany, the others are lighter. Only switch on Pan-EU when volume is high enough that the FBA fee saving exceeds the annual compliance cost of however many storage countries the current programme actually involves, rather than a guessed number. The line-by-line breakdown is in the cost of selling on Amazon FBA. Turning on Pan-EU early is the fastest way to create tax obligations in countries where you have barely sold anything.

The order of operations: the part most sellers do backwards

This is where sellers get it wrong most often. They open the account, build the listings, run ads, and deal with paperwork whenever the platform demands it. The correct order is almost the reverse.

The order matters because each step depends on data from the one before it. The HS code sets your landed cost, and landed cost decides whether that market is worth entering at all. Some EPR registers and some import declarations ask for your tax identifiers, so sequence accordingly for each scheme rather than assuming a VAT number is always needed before EPR. A food label needs the name and address of the EU legal entity, which means the entity has to exist before packaging is printed. Do it backwards and you reprint labels, reprice the product, or stop selling.

Timing is the other reason. VAT numbers in EU countries are issued in weeks, not days, and an incomplete file restarts the process. If you start the registration chain at the same time as the production order, the goods arrive before the paperwork does. We always start the registration chain before the first production run is confirmed.

• Fix the selling entity and decide who acts as importer of record.
• Classify HS and CN codes for every SKU, so you know duty and VAT rate before you price.
• Apply for the EORI number.
• Register for VAT in the country that will hold the stock, and register for OSS if you are the supplier on cross-border sales.
• Register packaging EPR, plus electrical or battery EPR where relevant, with a local authorised representative where one is required; for food, register the food business operator and finalise the label.
• Fix the Incoterm with your freight forwarder and run a small trial shipment before the large production run.
• Open the Amazon account, complete verification, and enter every registration number in Seller Central.
• Only once every number has been accepted by the platform do you send stock into FBA and switch on advertising.

What a Vietnamese manufacturer can do, and where an EU entity is unavoidable

Some parts a Vietnamese factory should keep, because it does them better than anyone: product specification, quality, cost structure, packaging design, imagery and working capital. HS classification should also involve you alongside the forwarder, because you are the one who knows the composition and the process.

Some parts genuinely cannot be run from Vietnam. The German dual system contract and the packaging volume reporting are handled in German. A food label must carry the name and address of a food business operator established in the EU, so without an EU entity there is no compliant label. Some member states require non-EU businesses to appoint a fiscal representative, and which ones do changes, so it has to be checked country by country. Periodic VAT filing in Germany, France and Spain needs a local filing agent. And verifying an Amazon Europe account with Vietnamese documents is its own process, easily stalled if the documents are submitted in the wrong order; we cover that part in selling on Amazon from Vietnam.

Tacke Infotech operates exactly those parts. We are not a consultancy that hands over recommendations and leaves you to it. We run our own brands on the same infrastructure: Hoasipho, Matelier, NANANA Golf, Pomte. For Matelier, the regimes we have run ourselves are: VAT in Germany, France and Spain with OSS, LUCID and VerpackG in Germany, Ecoembes in Spain, food business registration, EU food labelling, EORI, HS classification and DDP import. The other regimes described in this article, such as ElektroG, BattG and French packaging EPR, are described from the rules, not from a file we have run for Matelier.