Pan-European FBA or your own EU stock

Amazon’s Pan-European FBA lets Amazon hold a seller’s stock in several EU countries and move it between them at its discretion. Amazon states that a VAT number is required for each country where goods are stored, with storage enabled in at least two. A single EU stock base, by contrast, keeps stock in one member state, where the seller is registered for VAT. Cross-border consumer sales are then reported through the One Stop Shop. The choice is between delivery speed on Amazon and a smaller, fixed VAT footprint.

Neither model is right for every seller. The difference lies in who decides where stock sits, and what each location triggers.

How does Pan-European FBA work?

Amazon’s own programme page sets out the main conditions:

• Storage countries. The seller enables storage in at least two of France, Germany, Italy, Spain and Poland.
• Listings. Eligible FBA products are listed with the same SKU in the required Amazon EU stores: Germany, France, Italy, Spain and the Netherlands.
• Movement. “Amazon can then move your inventory between EU fulfilment centers free of charge at any time at its discretion.”
• Fees. The seller pays local fulfilment fees in the countries enabled for storage. In the remaining EU countries, it pays cross-border fulfilment fees, under the European Fulfilment Network or EFN.

The design puts stock close to buyers across Amazon’s main EU stores. The seller chooses which countries are enabled for storage. Within those, Amazon decides where each unit sits.

Is a VAT number needed in each country where Amazon stores stock?

Yes, for every country enabled for storage. Amazon’s page states: “A VAT number is required for each country where goods are stored.” Amazon’s EU VAT guidance adds that a seller planning to use Pan-European FBA will “need to register for VAT before you start selling to customers in Europe,” and may need to register “in multiple countries if you store, move, or sell goods in multiple countries.”

The legal reason sits in Article 17(1) of the VAT Directive, Directive 2006/112/EC. “The transfer by a taxable person of goods forming part of his business assets to another Member State shall be treated as a supply of goods for consideration.” When Amazon moves a seller’s units from a centre in one country to another, the seller’s own goods cross a border. Each such movement is a transaction the seller has to account for.

Amazon also recommends a tax adviser for sellers who store goods in more than one EU country. That advice is worth taking before storage countries are enabled, not after.

Does OSS cover stock moved between EU countries?

No. The Union scheme of the One Stop Shop is a way to declare certain supplies to consumers through one return. Those supplies include intra-Community distance sales of goods. The Commission’s OSS guidance describes supplies to customers. A seller moving its own stock between its own storage locations is not selling to a consumer, and that movement is not something OSS declares.

In practice, OSS simplifies the sales side. It does not remove the VAT registrations that storage in a country requires. OSS, IOSS, and what they do not cover sets out the wider limits of both schemes.

Can a non-EU seller use the EUR 10,000 distance-selling threshold?

No. The Commission’s OSS page explains that an annual EUR 10,000 threshold applies to intra-Community distance sales of goods and certain cross-border services combined. Below it, a supplier may charge the VAT of its own member state.

Under Article 59c of the VAT Directive, the threshold applies only to a supplier established in one member state. The Commission states that suppliers established outside the EU, even with one or more fixed establishments in the EU, cannot use it. For a seller based outside the EU, VAT on cross-border sales to EU consumers is due in the customer’s country from the first sale. The Union scheme is still available to report those sales. The Commission confirms that a taxable person not established in the EU can use it to declare certain supplies of goods.

The picture changes again where Amazon itself becomes the deemed supplier. That means the marketplace is treated as the seller that charges and accounts for the VAT. Marketplace deemed supplier rules in the EU covers when that happens.

What are the trade-offs between Pan-European FBA and a single stock base?

Question	Pan-European FBA	Single EU stock base
Who decides where stock sits	Amazon, within the storage countries the seller enables	The seller
VAT registrations for storage	One per storage country, at least two	One, in the storage country
Cross-border consumer sales	Reported in the seller’s VAT filings, with OSS where it applies	Reported through the OSS Union scheme
Delivery to Amazon customers	From centres in several countries	From one country, by parcel
Sales outside Amazon	Separate stock or a separate arrangement	Same stock pool serves all channels

A single stock base gives up some delivery speed on Amazon in exchange for control. The same units can serve Amazon orders, a brand’s own website, retailers and distributors. One EU stock pool for B2B and B2C buyers explains how that pooling works.

Some sellers combine the two: a single base for most channels, and a smaller quantity in Amazon’s network for the busiest store. The VAT consequences of each location still apply.

Worked example: four FBA countries or one base in Portugal

Suppose a brand from outside the EU sells small kitchen tools on Amazon in Germany, France, Italy and Spain, and on its own website. The details are hypothetical, for the mechanics only.

Option A: Pan-European FBA with four storage countries. It enables storage in Germany, France, Italy and Spain. It registers for VAT in all four before storage begins. Amazon moves units between those countries as demand shifts. Each movement of the brand’s own goods between two countries is a transfer the brand accounts for under Article 17. Its website orders need stock too, which it holds elsewhere.

Option B: one stock base in Portugal. It releases its goods for free circulation in Portugal and registers for VAT there. Website orders and Amazon orders it fulfils itself ship from the same stock. As a seller established outside the EU, it cannot use the EUR 10,000 threshold. On its website sales, it therefore charges the VAT of each customer’s country and reports it through the OSS Union scheme. Returns come back to one place.

Option C: both. It keeps its main stock in Portugal and sends a limited quantity into Amazon’s fulfilment network in Germany only, outside Pan-European FBA. It then holds VAT registrations in Portugal and Germany.

In each option, the brand’s adviser also checks whether Amazon is the deemed supplier for the Amazon sales. That affects who accounts for VAT on those sales. It does not change the registrations that storage in a country requires, according to Amazon’s own conditions.

The brand’s tax adviser compares the three on its actual volumes. The operational question is simpler: how many countries hold its stock, and who decides.

Which VAT registrations a given structure triggers is confirmed by the seller’s tax advisers, country by country. The comparison above frames the choice; it is not tax or legal advice.

What does a single stock base in Portugal involve with EFC?

A brand that chooses one base can hold its stock at EFC’s site in Portugal, run with its logistics partner. The brand can then ship orders from every channel out of the same pool, as described on marketplace. Goods usually arrive through release for free circulation. EFC offers fiscal representation where a seller needs it, and support with OSS filings. It does not give tax advice, and Amazon’s own programme terms remain between the seller and Amazon. Returned units come back to Portugal, as set out on returns.

Sources

Label	Value	Source
EU threshold	EUR 10,000 threshold for intra-EU distance sales, only for a supplier established in one member state	Directive 2006/112/EC, Article 59c, EUR-Lex, opened 2026-08-07
Pan-European FBA conditions	storage in at least two of FR, DE, IT, ES, PL; VAT number per storage country; same SKU in DE, FR, IT, ES, NL stores; movement at Amazon’s discretion; local and EFN fees	Amazon, successful selling with Pan-European FBA, opened 2026-08-07
Amazon VAT guidance	register before selling when using Pan-European FBA; registration may be needed in multiple countries where goods are stored, moved or sold	Amazon, getting started with European VAT, opened 2026-08-07
Transfer of own goods	treated as a supply of goods for consideration	Directive 2006/112/EC, Article 17, EU text on EUR-Lex, opened 2026-08-07
EUR 10,000 threshold and Union scheme	threshold only for suppliers established in one member state; not for suppliers established outside the EU; Union scheme open to non-EU taxable persons for certain supplies of goods	European Commission, One Stop Shop, opened 2026-08-07
Union scheme scope	intra-Community distance sales of goods declared in the scheme	European Commission, declare and pay in the OSS, opened 2026-08-07