Three European fulfilment setups, and one variable decides all of them: where Amazon is allowed to keep your stock. Pan-European FBA spreads your inventory across the countries you enable, and Amazon states plainly that “a VAT number is required for each country where goods are stored” (sell.amazon.de, data checked 2026-08-16). The European Fulfilment Network keeps stock in one country and ships across borders from there, so storage triggers no new registration — Amazon’s own comparison says “a VAT number is generally not required in the destination shop” (same page, checked 2026-08-16). Country-specific FBA sits between the two: you choose the countries, and you register in each one you choose.
This article is not tax advice. It maps programme mechanics to the registration questions they raise. Your actual obligations depend on your establishment, your goods and your volumes, and are determined by each national tax authority and your own adviser.
The Three Setups, Defined by Where Your Stock Sits
Amazon groups its European options in one sentence: “Amazon offers multiple fulfilment solutions all across Europe: Pan-European FBA, European Fulfilment Network and Multi-Country Inventory” (sell.amazon.co.uk, data checked 2026-08-16).
Pan-European FBA — Amazon moves the stock. You enable a set of storage countries, and placement is then out of your hands: “Amazon distributes and stores your products across Europe in the EU countries you have enabled for storage” (sell.amazon.de, checked 2026-08-16). You do not approve each transfer. Whatever list you enable is the list you must support with registrations.
European Fulfilment Network — one pool, cross-border shipping. Under EFN, “Amazon stores products locally only, ready for local delivery or to dispatch to other countries” (sell.amazon.de, checked 2026-08-16). Your units never leave the country you sent them to until a customer order pulls one across a border, and that is what keeps EFN’s registration footprint small.
Country-specific FBA — you pick the countries. The middle setting: you inbound stock to two or three national FBA networks without handing Amazon a blanket redistribution permission. For tax purposes each country you stock behaves exactly like a Pan-EU storage country, because the trigger is the stock, not the programme name.
A fourth option exists only across the UK–EU customs border. “Remote Fulfillment allows you to sell across the UK-EU customs border without having to store inventory in the destination marketplace or register for VAT there” (sell.amazon.co.uk, data checked 2026-08-16). Pan-EU no longer spans that border at all: “As of 1 January 2021, the UK is no longer part of Pan-European FBA” (sell.amazon.de, checked 2026-08-16).
What Each Setup Costs You in Fulfilment Fees
The fee logic is the reason anyone tolerates the registration work. Amazon’s own description: “Through Pan-European FBA, you will pay local fulfillment fees in all the EU countries enabled for storage, and Cross-border fulfilment (EFN) fees in the rest of the EU countries” (sell.amazon.co.uk, data checked 2026-08-16). EFN fees are the cross-border rate; local fees are the domestic rate; Pan-EU simply converts more of your order mix from the first to the second.
Amazon markets the gap as “up to 53% savings* in fulfilment fees and increase your FBA sales by up to 24%**” — and both asterisks matter. The fee figure is “calculated as the highest achievable savings comparing the EFN fulfilment fees with the local fulfilment fees for each size/weight”: a best case per size band, not an average. The sales figure rests on “a Aug 2023 study analyzing 1.9 million Pan-European FBA offers” (both sell.amazon.co.uk, checked 2026-08-16), which Amazon itself calls “a general reference point.”
One 2026 change applies to every setup on this page: “Starting from April 17, 2026, a 1.5% fuel and logistics-related surcharge will be applied to fulfilment fees across Fulfilment by Amazon (FBA) in the UK, France, Germany, Italy, Spain, Poland, Sweden, Netherlands, Ireland and Belgium stores” (sell.amazon.co.uk, checked 2026-08-16). Rebuild your unit economics on current rate cards before you use any percentage from a comparison article, including this one — the method is in our FBA fees and profit guide.
The VAT Registrations Each Setup Forces on You
The rule underneath all three setups is not an Amazon rule. Under Article 17 of the VAT Directive, “a business (taxable person) shall treat the transfer of its business assets to another EU country as a supply of goods” when it dispatches its own movable property there for business purposes and none of the Article 17(2) exceptions apply (European Commission, data checked 2026-08-16). Moving your own stock across an EU border is a taxable event before a customer buys anything.
The second rule is what the One Stop Shop does and does not absorb. OSS covers intra-Community distance sales, where “the place of supply of intra-Community distance sales of goods is in the Member State in which the dispatch/transport of the goods ends.” It does not cover a sale from local stock to a local customer: in that situation “the supplies will be domestic supplies and cannot be declared” in the OSS (European Commission, data checked 2026-08-16).
| Setup | Where stock sits | Registration the storage itself raises | What OSS can absorb |
|---|---|---|---|
| Pan-European FBA | Every country you enable, at Amazon’s discretion | Amazon: “a VAT number is required for each country where goods are stored” | Cross-border B2C sales into countries where you hold no stock |
| Country-specific FBA | Only the countries you inbound to | The same rule, applied to your shorter list | Cross-border B2C sales from those countries |
| EFN | One country only | Amazon: “a VAT number is generally not required in the destination shop” | Your cross-border B2C sales, subject to the threshold below |
| Remote Fulfilment (UK↔EU) | Home region only | Amazon: sell across the border “without having to store inventory in the destination marketplace or register for VAT there” | Handled by Amazon on those orders |
Table quotes: sell.amazon.de and sell.amazon.co.uk, data checked 2026-08-16.
For an EFN-only seller, the live number is the EU-wide threshold, and it is smaller than most sellers assume. “As from 1 July 2021, this threshold also covers intra-Community distance sales of goods whose transport/dispatch has started in the Member State in which the supplier is established,” and it is a shared total: the sum of those sales and cross-border B2C digital services “must not exceed EUR 10 000 for the threshold to apply” (European Commission, checked 2026-08-16). Above it, VAT is due where the goods arrive, and OSS lets you file that in one return instead of registering country by country.
Its conditions cut most cross-border sellers out entirely. It requires that “the supplier is established or, in the absence of an establishment, has his permanent address or usually resides in only one Member State” (European Commission, checked 2026-08-16). If you are a US, UK or Chinese seller, plan on registering where you create a taxable presence — the country-by-country picture is in our VAT threshold map.
VAT is also not the only registration that follows stock into a country. Packaging EPR attaches separately, and Amazon blocks listings on missing numbers in several stores — see the EU EPR compliance guide. Importing the stock needs an EORI number, a customs identifier rather than a VAT number.
Pan-EU Enrolment: What Amazon’s Own Pages Actually Require
This is where third-party articles and Amazon’s pages diverge most sharply, so read the primary source. On 2026-08-16, Amazon’s UK page states: “To sell your FBA products in Amazon’s EU stores, you must have access to seller central accounts in the following EU stores: France, Germany, Italy, Spain and the Netherlands*. You must enable placement in at least two of these stores and send your inventory to an Amazon Fulfilment Centre.” The German page frames storage the same way: “Enable storage in at least two of the following EU countries: Germany, France, Italy, Spain or Poland*.”
Amazon states the VAT consequence of that minimum directly: “You can start with just two VAT numbers, which means you won’t need to register for VAT in every country where you sell” (sell.amazon.co.uk, checked 2026-08-16). Note the wording — two is the floor for entry, not a cap. Enabling a third or fourth storage country later adds the corresponding registrations.
Three details on the same pages are easy to miss:
- Listing reach is wider than storage. “Pan-European FBA is available in the following Amazon stores: Germany, France, Italy, Spain, the Netherlands, Poland, Sweden, Belgium and Ireland” — nine stores, while storage enablement is offered across five countries.
- A Netherlands offer is now mandatory for new products. “A Netherlands offer is now required for new PanEU FBA products,” and Amazon says existing offers will follow, with “at least 30-days’ notice before this requirement takes effect.”
- Some stores only get domestic rates via a specific enablement. “To enjoy domestic FBA Fulfilment fees for orders in Sweden and the Netherlands, you must enable placement in Germany. For orders in Belgium, you must enable placement in either Germany or France.”
One inconsistency sits on Amazon’s own UK page: the “How does Pan-European FBA work?” section names the required stores as “France, Germany, Italy, Spain and the Netherlands,” while the numbered enrolment steps lower down say “This includes Germany, France, Italy, Spain, and Poland” (both checked 2026-08-16). The offer requirement and the storage list are not the same list, and the page does not label them clearly. The operative list for your account is the one under Pan-EU eligibility inside your own Seller Central.
Choosing: Four Decision Gates
Gate 1 — Can you carry the compliance load? Each country brings filing calendars, deadlines and a local penalty regime. If two registrations already stretch you, Pan-EU’s open-ended storage permission is the wrong shape of commitment. Sellers outsourcing this step should read our VAT services selection framework first; a worked single-country example is in the Italy VAT guide.
Gate 2 — Is your cross-border volume above or below EUR 10,000 a year? Below it, and dispatching from a single Member State where you are established, EFN plus your home registration is the cheapest legal setup. Above it, the fee argument for local stock starts to bite.
Gate 3 — Where is the demand, actually? Pan-EU’s savings only land on orders that would otherwise have shipped cross-border. If 85% of your units go to one country, you are buying registrations to optimise 15% of your volume. Check marketplace-level sales before enabling storage.
Gate 4 — Is your catalogue stable? Pan-EU requires the same SKU across the required stores: translations, compliance documentation and pricing maintained in parallel. A catalogue that churns monthly pays that cost repeatedly.
Country-specific FBA is the answer when Gates 2 and 3 say yes but Gate 1 says no: stock the countries that carry your volume, register there, and leave the rest on cross-border fees.
Common Mistakes
- Treating OSS as a substitute for local registration. It cannot declare a sale of German-stored stock to a German buyer — the Commission’s wording is that such supplies “cannot be declared” in the OSS.
- Assuming EFN means no VAT obligations anywhere. It means storage does not create them. Cross-border sales above the EUR 10,000 total still create a liability, filed via OSS or locally.
- Reading “two VAT numbers” as a permanent ceiling. It is the entry minimum. Your obligation tracks the storage countries you enable.
- Taking country counts from VAT agencies’ blog posts. Most top results here are written by firms selling registration services. Check the count against an Amazon-owned page and your own Seller Central before budgeting.
- Forgetting EPR and customs. VAT registration in a storage country does not cover packaging EPR, and neither covers the EORI you need to import.
What We Could Not Confirm on 2026-08-16
- An Amazon-owned definition of Multi-Country Inventory. Amazon names it as one of three European fulfilment solutions, but the Seller Central help hub returns a shell page to crawlers and the archived snapshots we checked did the same. The description of country-specific FBA above is built from the storage rule, not from an MCI page.
- A published Pan-EU registration count above two. Third-party guides circulate minimums of four or five EU VAT numbers, and some add the Czech Republic to the storage list. We found neither on any Amazon-owned page on 2026-08-16; what we found was the “at least two” wording quoted above.
- Current EFN rate cards per size band. Amazon links these from a fees guide behind its rate-card downloads; we did not retrieve per-band figures, so no fee table appears here.
Frequently Asked Questions
Does Pan-EU FBA require VAT registration in every country?
In every country where your stock is stored, yes. Amazon’s wording is “a VAT number is required for each country where goods are stored” (sell.amazon.de, checked 2026-08-16). Countries you sell into without holding stock are a different question, normally handled through OSS.
How many VAT numbers do I need to start Pan-EU FBA?
Amazon’s page states “you can start with just two VAT numbers,” matching the requirement to “enable placement in at least two” of the eligible stores (sell.amazon.co.uk, checked 2026-08-16). That is a floor, not a limit — each additional storage country adds a registration.
Does EFN create a VAT registration in the destination country?
Not through storage. Amazon’s comparison states “a VAT number is generally not required in the destination shop” for EFN (sell.amazon.de, checked 2026-08-16), because your stock never sits there. Your cross-border sales are still taxable once you pass the EUR 10,000 EU-wide total.
Is the EUR 10,000 threshold per country?
No. It is a single EU-wide annual total, and it is shared: “the threshold of EUR 10 000 is not counted separately for supplies of cross-border TBE services and intra-Community distance sales” (European Commission, checked 2026-08-16).
Can I use Pan-EU FBA between the UK and the EU?
No. “As of 1 January 2021, the UK is no longer part of Pan-European FBA” (sell.amazon.de, checked 2026-08-16). Amazon’s cross-border options there are Remote Fulfilment, which avoids destination storage and registration, and Local Inbounding, which “means shipping your inventory to both your primary (e.g. UK) and secondary (e.g. EU) FBA networks” (sell.amazon.co.uk, checked 2026-08-16).
Conclusion
Pick the setup by the registrations you can actually maintain, not by the headline saving. EFN costs more per unit and almost nothing in compliance. Pan-EU inverts that, and the commitment is open-ended because Amazon decides where units land within the set you enable. Country-specific FBA is the deliberate middle: local fees where your volume already is, no obligation to countries that take a handful of orders. Whichever you choose, confirm the current country lists inside your own Seller Central and your obligations with a qualified adviser in each country — the programme rules here were checked on 2026-08-16 and Amazon changes them without much warning.