Amazon FBAUK VATEU SellersBrexitTax Compliance

Selling on Amazon UK from Europe: FBA VAT Guide

Q: What is the £135 rule for EU sellers shipping to the UK?

When you sell goods on Amazon.co.uk, Amazon acts as the deemed supplier and collects 20% UK VAT at checkout on all B2C orders stored in the UK (regardless of value) and on orders under £135 shipped from the EU. However, if you sell directly via your own Shopify store from the EU to UK consumers, orders of £135 or less require you to register for UK VAT from your very first sale and collect 20% VAT at checkout.

Brexit cut Amazon.co.uk off from Pan-European FBA. Here is how EU Amazon sellers expand to the UK using dual EORI numbers, UK VAT, PVA, and MTD filings.

GoodVat Team

October 22, 2026·8 min read

Before 2021, selling on Amazon.co.uk from Germany, France, Poland, or the Netherlands took roughly four clicks. You ticked the UK box inside Pan-European FBA, Amazon trucked your pallets under the English Channel while you slept, and your British sales rolled neatly into your European workflow.

Then Brexit erected a hard customs wall across the Channel—and half of your European competitors quietly abandoned the UK market.

Their laziness is your margin opportunity. Because thousands of EU sellers gave up on Amazon.co.uk rather than learn HMRC’s post-Brexit rules, UK CPCs are softer and Prime shoppers are underserved across dozens of niches.

The short answer: expanding from Europe to Amazon UK requires treating the UK like a separate country, not an EU member state. Your EU OSS and EU EORI do not work there. To win the UK Buy Box, you register your EU company directly with HMRC for a GB VAT number (no fiscal rep required), grab a GB EORI, use Postponed VAT Accounting (PVA) at the border, and file four quarterly Making Tax Digital (MTD) returns a year.

Here is the step-by-step playbook for European Amazon FBA sellers expanding to the UK in 2026.

Remote Fulfillment (EFN) vs. Local UK FBA: Which Should You Use?

Because the UK is cut off from the Pan-European FBA pool, EU sellers have two ways to fulfill Amazon.co.uk orders:

Fulfillment Route	How It Works	UK VAT Registration Required?	Customs & Fees	Verdict
Remote Fulfillment with FBA (EFN EU → UK)	Inventory stays in your EU warehouse (e.g., Germany). Amazon ships individual B2C orders across the border to UK buyers	No (if strictly B2C orders under £135 on Amazon and zero stock stored in the UK)	Steep EFN cross-border fulfillment surcharge; slower delivery times; £135 consignment cap	Fine for a 30-day test, terrible for unit economics
Local UK FBA (Dual Inventory Split)	You ship pallets into a UK Amazon fulfillment center (`BHX4`, `EMA1`, etc.)	Yes — £0 threshold from the day your stock lands in the UK	Lowest local UK FBA fees, full next-day Prime badge, no £135 order cap	The only way to scale profitably on Amazon.co.uk

If you only sell a dozen units a month in Britain, leave EFN switched on from Germany. The moment you want real rank and healthy margins on Amazon.co.uk, you must store stock inside a UK fulfillment center.

The 4 Post-Brexit UK VAT Rules Every EU Seller Must Know

1. There is no £90,000 threshold—and EU OSS doesn’t cover the UK

UK domestic businesses get a generous £90,000 turnover threshold before registering for VAT. European sellers storing inventory in a UK FBA warehouse get £0.

Nor does your EU One-Stop Shop (OSS) registration help. OSS stops at the English Channel. The day your inventory touches a UK warehouse—or the day your own Shopify store ships a parcel worth £135 or less to a buyer in London—you fall under HMRC jurisdiction.

2. You need two EORI numbers (EU + GB)

Moving 1,000 units of your product from your warehouse in Hamburg or Poznań to an Amazon fulfillment center in Coventry is two customs events:

An export out of the European Union: Requires your EU EORI number (e.g., DE..., NL..., PL...) so you can report a zero-rated export supply on your domestic EU VAT return.
An import into Great Britain: Requires a separate GB EORI number (GB + your 9-digit UK VAT number + 000) to clear UK customs on HMRC’s Customs Declaration Service (CDS).

3. Good news: HMRC does not require a Fiscal Representative

When a British or American seller registers for VAT in France, Italy, Spain, or Poland, those governments force them to hire an expensive, jointly liable Fiscal Representative.

The UK does not play that game. HMRC allows your existing European company (GmbH, SARL, SAS, BV, SL, Sp. z o.o.) to register directly as a Non-Established Taxable Person (NETP). You don’t pay a penny in bank guarantees or fiscal representation markups.

4. Deemed Supplier on Amazon B2C vs. Your Own Filings

Just like the EU’s 2021 e-commerce rules, the UK treats Amazon as the deemed supplier when a non-UK business sells UK-stored FBA stock to a UK consumer (B2C). Amazon collects the 20% UK VAT at checkout and sends it straight to HMRC.

Why do you still need to register and file quarterly UK VAT returns?

To avoid Amazon account suspension: Amazon UK gives non-resident sellers a strict window after first FBA inbound shipment to upload a verified GB VAT number matching their legal entity.
To recover 20% UK Import VAT via PVA: Without a GB VAT number, the 20% VAT charged at the UK border becomes a permanent 20% hit to your cost of goods sold.
To pay VAT on UK B2B sales: When a VAT-registered British company buys your product on Amazon Business, Amazon does not act as deemed supplier. You must charge 20% UK VAT (and issue a compliant VAT invoice) and remit that tax to HMRC.

Step-by-Step: How to Expand from Amazon EU to Amazon UK

Step 1: Register your EU company for UK VAT & a GB EORI

Do not wait until your pallets are sitting at Calais. Apply for your UK VAT number 6 to 8 weeks before your planned inventory transfer. Make sure your EU trade register extract (Handelsregisterauszug, Kbis, KVK uittreksel, or KRS) matches your Amazon Seller Central legal name and address character-for-character.

Step 2: Appoint an Indirect Customs Agent for the Channel crossing

Because your company is established in the EU and not in the UK, freight forwarders cannot clear goods into Great Britain for you as a “Direct Representative.” Confirm upfront that your carrier (or Amazon’s Partnered Carrier / ATS program if eligible) acts as an Indirect Customs Representative in the UK, or use a dedicated cross-Channel freight broker.

Step 3: Turn on Postponed VAT Accounting (PVA)

Never pay 20% import VAT in cash at the UK port. Instruct your customs broker to tick Postponed VAT Accounting (PVA) on your import declaration using your GB VAT and GB EORI numbers.

Each month, you log into HMRC’s Customs Declaration Service (CDS), download your monthly Postponed Import VAT Statement (MPIVS), and simultaneously declare and reclaim the 20% import VAT on your quarterly return. Cash outflow at the border: £0.

Step 4: Check your UK product VAT rate

The UK standard VAT rate is 20%, similar to France (20%) and Germany (19%). However, the UK has a massive competitive perk for certain categories: Zero-Rated (0%) Goods.

While Germany charges 19% VAT on children’s clothes and 7% on most foods, the UK charges 0% VAT on most children’s clothing and footwear, printed books, and many food items (see our UK VAT guide). If you sell in a zero-rated category, you keep the full retail price while still reclaiming 100% of your UK input and import VAT.

Step 5: Automate EU OSS + UK MTD Filings in GoodVat

If you read r/FulfillmentByAmazon, you already know the nightmare of signing a 12-month contract with a rigid VAT agency like AVASK or SimplyVAT—where every extra question, EORI application, or Shopify integration costs extra, and leaving means months of deregistration delays (see our intermediary comparison).

GoodVat keeps your EU and UK compliance under one clean roof:

Automatic separation of EU vs. UK transactions: Connect your Amazon, Shopify, and WooCommerce stores. GoodVat separates your 27-country EU OSS and Pan-EU FBA sales from your UK HMRC transactions automatically.
Handles the £135 D2C rule at checkout: Also shipping directly from your EU warehouse to British buyers via your own website? GoodVat calculates the right UK VAT on orders under and over £135 and generates compliant GBP invoices.
Vetted UK partner accountants for registration & MTD filing: Our local UK tax partners get your EU company registered with HMRC, set up your GB EORI, reconcile your monthly PVA import statements, and file your quarterly Making Tax Digital (MTD) returns on time—quoted transparently per country, with software plans starting at $0/month (up to 50 transactions) and flat $20–$100/month tiers.

FAQ

Does Pan-European FBA still cover the UK for EU Amazon sellers?

No. Since Brexit took effect on 1 January 2021, the UK is no longer part of Amazon’s Pan-European FBA inventory pool. To get local Prime delivery and domestic UK FBA fees, you must ship a separate split of inventory across the UK border into UK fulfillment centers and hold a UK VAT registration.

Does my EU OSS (One-Stop Shop) registration cover UK VAT?

No. Union OSS only covers the 27 EU member states. Sales to customers in Great Britain (England, Scotland, and Wales) fall under HMRC’s UK VAT rules and are never reported on an EU OSS return.

Do EU companies need a Fiscal Representative to register for UK VAT?

No. Unlike several EU countries that force foreign sellers to pay for a jointly liable fiscal representative, HMRC allows EU companies (such as a German GmbH, French SAS, or Dutch BV) to register directly for UK VAT as a Non-Established Taxable Person (NETP).

Why do EU sellers need two EORI numbers to use Amazon FBA UK?

Moving inventory from an EU warehouse to a UK Amazon fulfillment center is both an EU export and a UK import. You need an EU EORI number to clear export customs out of the EU (so you can zero-rate the export) and a separate GB EORI number to clear import customs into the UK.

What is the £135 rule for EU sellers shipping to the UK?

When you sell goods on Amazon.co.uk, Amazon acts as the deemed supplier and collects 20% UK VAT at checkout on all B2C orders stored in the UK (regardless of value) and on orders under £135 shipped from the EU. However, if you sell directly via your own Shopify store from the EU to UK consumers, orders of £135 or less require you to register for UK VAT from your very first sale and collect 20% VAT at checkout.

How does GoodVat help EU Amazon FBA sellers expand to the UK?

GoodVat separates your EU OSS and Pan-EU VAT transactions from your UK HMRC obligations, tracks B2C deemed-supplier sales vs. B2B orders, and connects you with vetted UK partner accountants who handle your GB VAT registration, GB EORI, and quarterly Making Tax Digital (MTD) filings.

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