Amazon has added two listing requirements to Pan-EU FBA. Every Pan-EU product needs an active offer on Amazon.nl by 3 September 2026, and on Amazon.com.be by 26 February 2027. Miss either deadline for a product and it drops out of the programme, which means paying cross-border fulfilment fees on every EU order for that product instead of local rates.
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What has changed

Pan-EU FBA lets Amazon position your stock across its European warehouses so each order ships at the local fulfilment rate. Qualifying used to mean keeping active offers for the same SKU on four marketplaces: France, Germany, Italy and Spain. Amazon has now added the Netherlands to that list, with Belgium to follow in February 2027.

The offer must be live, for the same SKU, on each required marketplace. A product that meets four of the five is not partly enrolled. It is out.
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What losing Pan-EU status costs

Without Pan-EU status, EU orders for that product are fulfilled through the European Fulfilment Network, where Amazon charges a cross-border fee for each unit shipped from a warehouse in one country to a customer in another. Amazon puts the saving from local fulfilment at up to 53% per unit, so the reverse is what falling out of the programme costs you.

Small per-unit differences add up faster than they look. A product doing 300 EU orders a month at 60p more per unit costs an extra £180 a month, or £2,160 a year. Multiply that across a catalogue and the two missing listings become one of the more expensive admin oversights an FBA business can make.
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What to do before the deadlines

Open the Pan-EU dashboard in Seller Central, which lists any SKUs missing a required offer. Create the missing Netherlands offers first, since that deadline is days away, then diarise the Belgium requirement for early 2027 rather than leaving it to the last week. Amazon translates listing content for you in most categories, although it is worth checking the translated titles and bullets read sensibly before the offer goes live.

If a product has dropped out, creating the missing offers is also the route back in. Check the dashboard afterwards to confirm each SKU shows as enrolled again.
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The VAT side, before you change anything

“The trigger for registration is stock, not sales. The moment Amazon moves inventory into a Dutch or Belgian fulfilment centre there is a local VAT registration obligation from day one, with no threshold to fall back on. Listing on a marketplace does not create that obligation on its own, but enabling a storage country does. Dutch registration typically takes around 4-6 weeks, so it needs starting before the stock moves, not after.

The most common and most expensive mistake is treating Pan-EU as all or nothing. Sellers either sign up for all seven countries and take on registrations they never needed, or they enrol without checking where their stock can be redistributed and discover months later that they have been non-compliant in a country they have never visited. You can choose your storage countries and only need to register where the stock sits.”
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- Jayce Zidel, Head of Partnerships, Yonda Tax

Sales to EU consumers are a separate question from storage, and UK sellers typically report them through a combination of local returns and the One Stop Shop depending on where stock sits. The right structure depends on your volumes and warehouse locations, so take advice before turning on a new storage country rather than after the first pallet arrives.
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Frequently asked questions

Do I need a Dutch VAT number to list on Amazon.nl?

Not for the listing itself. A Dutch VAT registration is generally required once stock is stored in the Netherlands, so the answer depends on your Pan-EU storage settings rather than on the listing.
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What happens if I miss the 3 September deadline?

Products without an active Amazon.nl offer lose Pan-EU FBA status and their EU orders move to cross-border EFN fees. Creating the missing offer is the route to requalifying; confirm the SKU's status in the Pan-EU dashboard once it is live.
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Does this change my UK VAT position?

No. These requirements affect your EU obligations only. UK sales and UK VAT returns carry on as before.
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Is Belgium urgent too?

The Belgium requirement takes effect on 26 February 2027, so there is time, although it is the same job as the Netherlands one and doing both together is less work than coming back to it.
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Next Steps

We are Amazon accountants that regularly work with UK sellers operating Pan-EU FBA and beyond. We keep your business compliant in the UK, while working alongside key partners for EU VAT support. If you need EU VAT assistance, get in touch with our friends at Yonda Tax who can help you with registrations and filings.

If you need a specialist accountant for your UK Amazon business, get in touch with us today.