FBA
Amazon Updates
Pan-European FBA Now Needs a Netherlands Offer
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11 min read
Pan-European FBA is usually explained as a storage decision: let Amazon spread your stock across Europe and pay local fulfilment fees instead of cross-border ones. That is half of it. The other half is a listing decision, and Amazon has just tightened it. Since 3 September 2026 every Pan-EU product, new and existing, needs an active Netherlands offer to keep its benefits, and Belgium joins the requirement on 26 February 2027. The twist is that neither country is somewhere Amazon will actually store your inventory.
Pan-European FBA lets Amazon store your inventory in several European countries so that orders are fulfilled locally and charged the local fulfilment fee instead of the higher cross-border fee. Since September 2026 you also need an active offer in the Netherlands for your products to stay in the programme, and Belgium will be required from February 2027. The two-country placement minimum can only be met in Germany, France, Italy, Spain or Poland, and stock sent directly to Sweden, Ireland or the Netherlands is never redistributed.
What changed on 3 September 2026?
A country was added to the required list, and the wording covers stock you already have in the programme. Amazon's Pan-European FBA help page states it in one sentence: "Starting on 3 September 2026, all Pan‑EU FBA products (new and existing) must have an active Netherlands offer to enrol and to continue receiving Pan‑EU benefits." The phrase that matters is and to continue receiving. This is not a rule for new enrolments only. A product that has been enrolled for three years and has no Amazon.nl offer is in scope, and Amazon does not spell out the consequence beyond the loss of Pan-EU benefits, and the benefit at stake here is the local fulfilment fee, so the practical effect is the higher cross-border charge on stores you are not storing in.
Belgium is the same rule with a later date
The same paragraph continues: "Additionally, starting on 26 February 2027, all Pan‑EU FBA products must also have an active offer in Belgium at enrolment. We'll notify you at least 30 days before this takes effect." Two things are worth reading precisely. The Belgium sentence says at enrolment, where the Netherlands sentence says to enrol and to continue receiving, so on the published wording Belgium is stated as an enrolment condition rather than a continuing one. And the promised 30 days of notice is notice, not an extension: the date in the text is still 26 February 2027.
Which countries store your stock, and which only sell it?
Offer countries and placement countries are two different lists, and almost every confusion about Pan-EU dissolves once you separate them. Amazon gives the activation conditions as a pair: "You have created an active FBA offer in all of the Amazon European stores listed as required on Pan-European FBA inventory and enrol the ASIN in Pan-European FBA" and "You have sent your products to an EU fulfilment centre and enabled inventory placement in at least two countries among Germany, France, Italy, Spain or Poland." Then, immediately: "Belgium and the Netherlands are currently not options for Pan-European FBA inventory placement." So Amazon has made an offer mandatory in a country that cannot count toward the placement minimum.
| Store | Offer required? | Counts toward the two-country minimum? | How you get the local fee |
|---|---|---|---|
| Germany | Yes | Yes | Enable placement in Germany |
| France | Yes | Yes | Enable placement in France |
| Italy | Yes | Yes | Enable placement in Italy |
| Spain | Yes | Yes | Enable placement in Spain |
| Netherlands | Yes, since 3 September 2026 | No | Enable placement in Germany |
| Belgium | At enrolment from 26 February 2027 | No | Enable placement in Germany or France |
| Poland | Optional | Yes | Enable placement in Poland |
| Sweden | Optional | No | Enable placement in Germany |
| Ireland | Optional | No | Not stated on the help page |
Read the last column downwards and Germany stops looking like one country among five. Amazon writes: "You will only pay the local fulfilment fee for the fulfilment of a Pan‑European FBA offer on Amazon.nl and Amazon.se when you enable inventory placement in Germany. You will only pay the local fulfilment fee for the fulfilment of a Pan‑European FBA offer on Amazon.com.be when you enable inventory placement in Germany or France." Three of the nine stores get their local rate from a German warehouse. A seller who enables Italy and Spain has satisfied the two-country minimum and will still pay cross-border fees into the Netherlands, Sweden and Belgium, including the Netherlands store that is now compulsory to list in.
Amazon’s own page does not fully agree with itself here
The redistribution rule is clear enough: "To benefit from Pan-European FBA redistribution, you must send your inventory to at least one of the following countries: Germany, Italy, Spain, France, or Poland. Sending inventory directly to Sweden, Ireland, or the Netherlands does not support inventory placement redistribution", and such stock "will remain in those fulfilment centres and will not be redistributed". But the next sentence complicates the picture: "However, inventory movement to these three countries from the eligible ones is still supported", and Amazon’s worked example enables placement in "Germany, France, Poland, Sweden, Ireland, and the Netherlands" and redistributes stock into all of them. That example enables the very country the activation conditions call unavailable. Read together, what is safe to act on is narrower than either half alone: the two-country minimum must be met in Germany, France, Italy, Spain or Poland, and anything you ship directly to Sweden, Ireland or the Netherlands stays where it lands.
What does Pan-European FBA actually save?
The gap between a local fee and a cross-border one, on every unit you ship into a country you have enabled. Amazon's own help page puts a number on one lane: with Germany enabled, "you will pay local fulfilment fees for your orders in the Netherlands, which are on average 45% lower than FBA cross‑border fulfilment fees of the European Fulfilment Network (EFN)". Amazon's public Pan-European FBA page advertises "up to 53% savings". That is an upper bound across size and weight bands rather than an average. The same page claims sellers can lift sales by "up to 24%", attributing it to an August 2023 study of 1.9 million offers and qualifying it by noting that actual results may vary significantly. The 45% figure is the one stated as an average, so it is the one worth planning against.
- The fee follows the store, not the shelf. "Regardless of the country in which your inventory resides, you will pay the local fulfilment fee in each country where inventory placement is enabled."
- Running out locally does not cost you the local rate. "When your inventory is out of stock in one store, Amazon will fulfil orders from your inventory in other stores. You will continue to pay the local fulfilment fee for the store where the order was placed as long as the store's country is enabled for inventory placement."
- Anything you did not enable is billed cross-border. You are "charged the cross-border fulfilment fee applicable to European fulfilment Network for remote fulfilment" of orders in countries you have not enabled.
- You do not control the movement. "You cannot initiate movement between fulfilment centres for Pan-European FBA inventory, Amazon will take care of that for you." The Cross-Border Inventory Movement, Daily Inventory History and Amazon Fulfilled Shipments reports are how you see what happened.
- Removals price off your home store. Amazon charges "local removal fees applicable to your home store notwithstanding where the inventory is located at the time of the removal order".
Three recent fee changes sit on top of all this, and the last one pulls against the first two. Amazon's European fee announcement of 2 December 2025 cut fees by "an average of £0.15/€0.17 per unit sold across Europe", including a parcel fulfilment cut averaging "£0.26/€0.32" in the UK, Germany, France, Italy and Spain from 15 December 2025, and extended its "reduced Low-price FBA rates in most categories" to products "priced at or below £20/€20" from 5 January 2026. Then, from 17 April 2026, a 1.5% fuel and logistics-related surcharge began applying to FBA fulfilment fees in ten European stores, worth "£0.05/€0.05 per unit for EU FBA" on average. Both numbers are averages on different bases, so they cannot simply be netted off against one another; the honest summary is that European fulfilment got cheaper in December and January and then gave a little back in April.
What does it cost you in VAT?
A registration in every country you let Amazon store in, and nothing automatic for the countries where you merely sell. Amazon is unusually direct about the trigger: "Storing goods in a country outside your home store country will trigger additional VAT registration and reporting obligations for your business, as well as Intrastat and other reporting requirements", and it closes the loophole a seller might hope for by adding that storage "includes you or Amazon on your behalf, storing and moving your inventory between fulfilment centres in different EU countries". Being enrolled in Pan-EU "falls under 'storing goods' and triggers your requirement to be VAT registered in the respective countries of storage".
That makes the Netherlands requirement less alarming than it first reads, and Amazon says so directly rather than leaving it to inference. Its own FAQ answers the question: "Expanding your Pan-EU listings to the Netherlands may not require obtaining a VAT registration number specific to the Netherlands." A non-EU established seller has "no obligation to register for VAT in respect of your sales delivered to the Netherlands under pan-EU FBA" because Amazon accounts for that VAT. An EU-established seller already on the Union One Stop Shop accounts for Dutch consumer sales through UOSS. An EU-established seller with no UOSS registration may account for the VAT at home only while they "only fulfil from your country of establishment" and their EU distance sales stay below €10,000 a year; above that they must "account for VAT in the Netherlands either through a Netherlands VAT registration number or through enrolling for UOSS". Note the first of those conditions: a Pan-EU seller is fulfilling from more than one country by definition, so the home-country treatment is the narrower option it looks.
The two-country minimum is also a two-registration minimum
Amazon's marketing page tells new sellers they need "just two VAT numbers, which means you won't need to register for VAT in every country where you sell". That is consistent with the help page rather than contrary to it, but only because the sentence is about the countries you store in. Enable the minimum two placement countries and you owe two registrations. Enable all five and you owe five, plus Intrastat where thresholds are met. The VAT bill scales with the storage map you draw, not with the nine stores your listings appear in.
How to check your Pan-European FBA setup
- Confirm every enrolled ASIN has a live Netherlands offer - The 3 September 2026 requirement covers new and existing products, so the risk is an old enrolment rather than a new one. Work from the Pan-European FBA inventory page, which is where Amazon lists the stores it currently treats as required, and look for enrolled ASINs with no active Amazon.nl offer. Every store’s offer has to sit on one and the same SKU, because a single inventory pool only works when "all offers are listed against the same SKU".
- Check which countries you actually enabled for placement - Enabling a store is not enabling placement. Confirm you have at least two of Germany, France, Italy, Spain or Poland switched on, and note whether Germany is one of them, because Germany is what buys you the local rate on Amazon.nl and Amazon.se, and Germany or France is what buys it on Amazon.com.be.
- Check where you are physically shipping stock - Redistribution only starts from Germany, Italy, Spain, France or Poland. If a supplier has been delivering into a Dutch, Swedish or Irish fulfilment centre, that inventory stays put. Re-point the inbound plan at one of the five before you conclude that Pan-EU is not moving your stock.
- Line up the VAT registrations against the placement map - Every country you enable for placement is a country your stock can sit in, and it is sitting there that triggers registration and Intrastat. Add Belgium to the diary rather than the registration list: the 26 February 2027 change is an offer requirement, and Belgium is not a placement option. Amazon also surfaces third-party VAT providers in the Pan-EU Portal for Spain, France, Germany, Italy, Sweden and Poland, though it states it "does not directly offer these services".
- Re-run the unit economics on the 2026 rates - December's and January's reductions and April's 1.5% surcharge are both already in your fee lines. Amazon says the Revenue Calculator, Profit Analytics and the Fee and Economics Preview report have been updated for the surcharge. If you sell in the UK as well, remember that Brexit ended Pan-EU transfers: "as of 1 January 2021, Pan‑European FBA inventory transfers have now stopped between the UK and EU", so UK stock is a separate plan.
The number that decides whether Pan-EU pays for you
Take the units you ship into each non-storage country over a year, multiply by the gap between that country's local and cross-border fee, and set the total against the annual cost of one more VAT registration and its filings. On Amazon's own average the Netherlands gap is 45% of a cross-border fee, which is real money at volume and close to nothing at ten units a month. Pan-EU is a volume argument, and the threshold is different for every catalogue.
Because the fee you are charged depends on a placement setting rather than on anything visible in the listing, Pan-EU errors are quiet ones: a country silently billed cross-border, or an ASIN that lost its benefits for want of a Dutch offer. Watching fulfilment fees and margin per ASIN per store in one place is what turns that into something you notice in a week rather than at the quarter's end. SellerMagnet's profit analytics break fees out per marketplace so a cross-border charge stands out against its local neighbours.
Do I have to register for VAT in the Netherlands now?
Not necessarily, because the Netherlands is not a storage country. Amazon says expanding Pan-EU listings there "may not require obtaining a VAT registration number specific to the Netherlands", and the answer depends on where you are established and whether you use the Union One Stop Shop.
What happens if a product has no Netherlands offer?
Amazon's wording is that an active Netherlands offer is needed "to enrol and to continue receiving Pan‑EU benefits". Losing those benefits means cross-border EFN fees where you would otherwise have been charged local ones.
Which countries count toward the two-country minimum?
Germany, France, Italy, Spain and Poland. Amazon states that Belgium and the Netherlands are "currently not options for Pan-European FBA inventory placement", although its own redistribution example enables the Netherlands, and stock sent directly to Sweden, Ireland or the Netherlands is not redistributed.
Is there a minimum number of countries?
Yes. You must enable inventory placement in at least two countries among Germany, France, Italy, Spain or Poland, and send your products to an EU fulfilment centre in one of those five.
Does the 1.5% surcharge apply to Pan-European FBA?
Yes. It applies to FBA fulfilment fees in ten European stores from 17 April 2026 and is calculated "on your fulfilment fees, not on the sale price of your items", averaging €0.05 per unit for EU FBA.
Can I still move stock between the UK and the EU?
Not through Pan-EU. Amazon states that Pan-European FBA inventory transfers between the UK and EU stopped on 1 January 2021, so UK and EU stock have to be replenished separately.
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