Amazon FBA Germany, Japan and the Netherlands: The Gates Each One Makes You Clear First

Germany and the Netherlands are two doors into the same building. Japan is a different building. One EU EORI number covers both European countries — “at any point in time, a person can be assigned only one valid EORI number” — but each still wants its own tax registration and its own packaging register, and the PPWR that has applied EU-wide since 12 August 2026 harmonised who counts as a producer without merging those registers. Japan asks for no EORI and no packaging register at all, and instead imposes the hardest blocker here: a person living abroad cannot lodge a Japanese import declaration without first appointing a Customs Procedure Agent resident in Japan. Germany owns the second blocker, and it is not tax — a producer with no German subsidiary cannot register batteries or electricals itself at all. Every rule below is quoted from a government, EU or Amazon page, checked 2026-09-04.

This is a market-entry orientation guide, not tax, customs or legal advice. What applies to you turns on where your entity is established and who is named as importer — confirm with the relevant authority or a licensed adviser before you commit freight.

The Gate Map: Which Country Wants What

Read the table by column, not by row. Germany and the Netherlands share exactly one thing — the EORI — and diverge on everything else that costs money. Japan shares nothing with either.

What Each Gate Costs You in Time

None of the official pages checked on 2026-09-04 publishes a processing time for these registrations. The bands below are therefore not official service levels and not measured results — they are planning bands derived from the dependency chain, which is the documented part. Treat any timeline a provider quotes you as that provider’s estimate.

The dependency column is what schedules your launch. Start the German representative mandate first: it is the only item whose duration depends on a third party agreeing to carry legal liability for you.

Gate 1: Tax Registration — Two VAT Numbers and One JCT Decision

Amazon puts the obligation on you: “If you store or sell goods to customers in an EU country, you may be required to register for VAT in that country” (Amazon, Sell in Europe, data checked 2026-09-04). Storing stock in a German or Dutch fulfilment centre is exactly that.

Germany. Two numbers, two offices, in order. “Foreign businesses must be registered in Germany before applying for a German VAT number. To do so, you can check here which tax office is responsible for your country of origin” (BZSt, data checked 2026-09-04) — local Finanzamt first, VAT-ID from BZSt second.

Netherlands. “There are three VAT rates: 0%, 9% and the standard VAT rate of 21%” (business.gov.nl, data checked 2026-09-04), and this is a separate Dutch registration, not an extension of the German one. Where the obligation starts for a seller established outside the EU is the VAT threshold map; if you are hiring the work out, the provider vetting guide covers what to put in the quote.

Japan is structurally different. Consumption Tax runs at “a standard rate of 10% (comprised of 7.8% national and 2.2% local),” and the taxable-person test is “taxable sales amounting to more than 10million yen during the Base Period” (National Tax Agency, data checked 2026-09-04). Below that, a new entrant is normally not a taxable person.

The invoice system is where the decision sits. A seller must be “registered as a ‘business issuer of qualified invoice’ by the District Director of the tax office of jurisdiction,” and the trade-off is stated plainly: “Even if the amount of taxable sales during the base period is below ¥10,000,000, unless the registry becomes invalid, consumption tax must be filed” (NTA, data checked 2026-09-04). Registering to serve business buyers who want a deductible invoice converts you into a filer regardless of size — a decision about buyer mix, not a compliance box.

One more is easy to miss: a corporation with no office in Japan “needs to designate a resident(Tax Agent)” for tax procedures (NTA, data checked 2026-09-04) — a second resident appointment, distinct from the customs one below.

Gate 2: Customs Identity — One EU EORI, Japan’s Agent Rule

For Germany and the Netherlands the requirement is blanket: an EORI number “is mandatory for the clearance of all types of customs operations in the customs territory of the EU,” and you get exactly one. The place of registration is not a choice of convenience — “For economic operators with no establishment in EU customs territory, this is the EU country in which they intend to carry out their first customs operation, i.e. lodge a declaration or apply for a decision” (European Commission, data checked 2026-09-04). Your freight routing decides your EORI member state. Full mechanics, including the separate UK register, are in the EORI number guide.

Japan runs no equivalent register and instead regulates who may act: “the person living abroad shall designate a person in Japan as a Customs Procedure Agent and notify it in advance to the customs office where the customs procedure is to be carried out.” The qualification is territorial — the agent “must have an address or residence in Japan (head office or principal office in the case of a corporation)” (Japan Customs, FAQ 9601, data checked 2026-09-04).

Read that as a sequencing rule. In the EU you register yourself and ship; in Japan you must first find a resident willing to be named, then file, then ship. A Japanese plan with no named agent has no import in it either.

Gate 3: EPR — Where Germany Locks You Out

Packaging first. Germany’s rule has no size exemption and is stated as a precondition of distribution: “If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register” (Zentrale Stelle Verpackungsregister, data checked 2026-09-04).

The Netherlands sets a levy threshold instead: “Do you bring 50,000 kilograms or more of packaging material onto the Dutch market in a calendar year? Then you must pay the packaging waste management contribution to Verpact,” reported “every year before 1 August.” Foreign sellers are covered explicitly — “Manufacturers and importers are responsible for the waste from packaging and packed products they bring onto the Dutch market from abroad” (business.gov.nl, checked 25 Mar 2026, data checked 2026-09-04). Japan has no counterpart registration here.

Now the part that stops launches. If your product contains a battery or is electrical, Germany does not merely require registration — it forbids you from doing it yourself: “If you as a foreign company would like to place electrical and electronic equipment on the market in Germany, you cannot register yourself. You need an authorised representative that is located in Germany to take over your legal obligations as a producer” (stiftung ear, WEEE, data checked 2026-09-04). The battery guidance repeats it and adds a hard gate on shipping: “Only once you have received your registration order are you allowed to place batteries on the German market” (stiftung ear, batteries, data checked 2026-09-04).

The Dutch position is permissive by comparison: “A foreign producer or importer can authorize a legal entity in the Netherlands to be an authorized representative … to fulfill the obligations arising from the regulation on its behalf” (Nationaal (W)EEE Register, data checked 2026-09-04). Can authorise, where Germany’s is cannot register yourself — the difference between a form and a contract negotiation. Country-by-country detail is in the EU EPR compliance guide.

Gate 4: PPWR — What Changed and What Did Not

The Packaging and Packaging Waste Regulation is “Packaging and Packaging Waste Regulation 2025/40,” which “entered into force on 11 February 2025” and “applies generally from 12 August 2026” (European Commission, Environment, data checked 2026-09-04). Being a regulation rather than a directive, it applies directly in both Germany and the Netherlands and not at all in Japan.

What it did not do is replace LUCID or Verpact with one EU register. The Dutch government’s packaging page carries the 12 August 2026 amendment note alongside the existing national duties, and Germany’s LUCID wording is unchanged. Plan for two national registrations plus one EU rulebook.

Gate 5: Listing Language

Amazon leaves the check with you: “You should also review specific requirements for product compliance, safety, and listing in for each country you plan to sell in” (Amazon Global Selling, data checked 2026-09-04). On accounts, “create a regional Europe account” covers Germany and the Netherlands together, while Japan is separate — “create a Japan account” — and “you can use the Build International Listings tool to cross-list your products in our Japan store” (Amazon, Sell in Japan, data checked 2026-09-04).

Cross-listing moves the offer; it does not make the copy good. German, Dutch and Japanese are three separate localisation jobs. Budget them as content work, not as a toggle.

The Decision Path

1. Does your product contain a battery or count as electrical equipment? If yes, Germany moves to the back of the queue or to the front of your calendar — you cannot start until a German authorised representative signs. There is no self-service path.
2. Where does your first EU container land? That answer, not tax planning, sets your EORI member state. Decide freight routing before you apply.
3. Germany or the Netherlands first? Both need their own VAT and packaging registrations. The Netherlands has a stated 50,000 kg levy threshold; Germany has none, so a small first shipment carries a lighter Dutch packaging cost profile — separate from where demand is, and from whether you pool stock across the EU (Pan-EU FBA vs. EFN).
4. Japan? Answer one question first: who is your resident Customs Procedure Agent? Until that name exists, nothing else in the Japanese plan is actionable. Then decide the JCT invoice-registration question on buyer mix, not on size.
5. Sequence, don’t parallelise blindly. A first-time expander may find Canada a cheaper rehearsal for multi-country operations than any of these three.

Common Mistakes

• Assuming one EORI is one EU registration set. It is one customs identity for the whole EU customs territory. It buys you nothing on VAT, and nothing on EPR.
• Treating EPR as a tax threshold. German packaging registration has no tonnage floor; the Dutch 50,000 kg figure is a levy and reporting threshold, not a licence to sell unregistered.
• Booking freight to Japan before appointing an agent. The appointment is a prerequisite for the declaration, and the agent must be resident.
• Registering for JCT reflexively. It converts you into a filer below the ¥10 million base-period line. Do it because business buyers need deductible invoices, not because it feels compliant.
• Forgetting the second Japanese appointment. The Tax Agent for NTA procedures and the Customs Procedure Agent for Japan Customs are separate requirements.

Frequently Asked Questions

Do I need a separate EORI number for Germany and the Netherlands?

No. The European Commission states that “at any point in time, a person can be assigned only one valid EORI number,” valid across the EU customs territory. With no EU establishment you register in “the EU country in which they intend to carry out their first customs operation” (data checked 2026-09-04).

Can I sell battery-powered products on Amazon.de as a US company?

Not on your own registration. Stiftung EAR states that a producer “without a subsidiary in Germany” cannot register itself and needs “an authorised representative that is located in Germany” (data checked 2026-09-04).

Do I have to register for Japanese Consumption Tax before I sell?

Not automatically. The NTA’s taxable-person test is “taxable sales amounting to more than 10million yen during the Base Period.” Qualified-invoice registration is a separate, voluntary step — but once registered, “Even if the amount of taxable sales during the base period is below ¥10,000,000 … consumption tax must be filed” (data checked 2026-09-04).

Does the PPWR replace German and Dutch packaging registration?

No. It “applies generally from 12 August 2026” as a directly applicable EU regulation, but LUCID and Verpact remain separate national registrations with their own numbers and reporting calendars (data checked 2026-09-04).

Conclusion

Germany and the Netherlands split one customs identity and share nothing else, so budget two VAT registrations and two packaging registrations. Japan replaces the whole EU apparatus with two resident appointments — a Tax Agent and a Customs Procedure Agent — plus one optional invoice-registration decision that carries a filing consequence. And if your product has a battery in it, the German authorised-representative mandate is the longest pole: start it first, because it is the only gate here that a form cannot open.