If you send your own inventory into Amazon’s EU fulfillment centers, you are the importer of record for that freight — not Amazon. Amazon warehouses are delivery addresses; they do not lodge customs declarations or pay import VAT on your stock. The marketplace’s VAT role is different: for sellers established outside the EU, Amazon’s EU marketplaces handle the VAT on the customer’s purchase under the deemed-supplier rules, and IOSS only applies to parcels worth €150 or less imported directly to consumers — never to goods already inside an EU fulfillment center. Three things only you can set up before the first shipment: an EORI number in the right country, a VAT registration in the country of import with postponed VAT accounting where available, and a customs broker clearing in your name. This guide orders the steps a first shipment needs.
Am I the Importer of Record for FBA Inbound Freight, or Is Amazon?
Every consignment crossing the EU border needs a party named on the customs declaration — the declarant — who answers for the accuracy of the entry, the customs duty, and the import VAT. When freight arrives at an EU port or airport destined for an Amazon fulfillment center, Amazon is not that party. Its warehouses receive pallets; they do not import third-party sellers’ inventory. In practice the declaration is either lodged by your customs broker acting in your name, quoting your EORI and VAT numbers — which makes you the importer of record — or by someone else in their own name, which has consequences for what you can reclaim later. So a seller shipping from the US, or directly from a manufacturer such as Amara Jeweiry’s Shenzhen factory, should assume the import is theirs: ordering barang kemas moissanite borong for EU resale leaves the customs paperwork on the buyer’s side of the table.
Where Do I Apply for an EORI Number — and in Which EU Country?
An EORI number is not optional for this trade. The European Commission states an EORI number “is mandatory for the clearance of all types of customs operations in the customs territory of the EU.” Companies established inside the EU register with the customs authority of the country where they are established. A business established outside the EU — a US seller, for example — applies “in the EU country in which they intend to carry out their first customs operation.” For an FBA importer that means the country where your consignment will clear customs: usually the member state hosting your first fulfillment center, or the entry port your freight forwarder routes through. Only one EORI number can be assigned to you at any time, and it is valid EU-wide, so it follows you even after you store stock in other member states. Apply before you book freight — no declaration can be lodged without it — and note an EORI is a customs identity, not a VAT registration; FBA importers need both.
Do I Owe Import VAT, and How Does Postponed VAT Accounting Work?
Yes — on the freight, not on the FBA customer order. Since the 2021 EU e-commerce VAT rules, all goods imported into the EU are subject to VAT regardless of value, while distance sales moved to the One Stop Shop schemes. You need a VAT registration in the country of importation — the number your broker quotes on the declaration — and import VAT is assessed on the customs value plus duty and transport to the EU border. Amazon will not appear on that assessment.
Setting Up Postponed VAT Accounting in Practice
Several member states let a registered importer postpone import VAT: instead of paying at the border, the VAT is self-assessed on the periodic return — declared and recovered in the same filing, so it never leaves your bank account. The setup sequence is the part most checklists skip. Register for VAT in the import country first, because postponement only works through a valid local registration. Then ask your VAT agent or the national tax authority whether a seller not established in the EU qualifies — eligibility differs by member state, so settle it in writing. Next, instruct your customs broker in writing to apply the postponement facility and to quote your VAT number in the correct box of the declaration. Finally, confirm the first entry appears on your first return. Where postponement is unavailable, plan to fund the VAT at the border and reclaim it on the return — a cash-flow cost that grows with every shipment.
How Do I Choose a Fiscal Representative?
Some member states require a seller with no EU establishment to register through a fiscal representative; others permit direct registration. A representative registers in their jurisdiction, files returns in your name, and is often jointly and severally liable for your VAT. Compare candidates on the scope in writing (which filings and languages, whether Intrastat is included if you cross thresholds), whether you keep access to the tax portals and your own VAT number, response time during your first clearance, fee structure, and exit terms, including transfer of the registration without losing filing history. Ask for references from marketplace sellers importing through the same member state.
Should My Inbound Shipment Ship DDP, and Who Clears Customs?
DDP — delivered duty paid — means the shipper’s side handles clearance and duties, which sounds like less work. The catch is who ends up as importer of record. If your supplier’s forwarder clears the freight under its own EORI and VAT numbers, the import documents carry their name: you may receive inventory inside Amazon’s network with no import VAT assessed to you, nothing to reclaim, and a customs history that is not yours to evidence. Amazon cannot fill the role either — a fulfillment center will not be named on a declaration for your goods. The setup most importers settle on is the reverse: you as importer of record, your broker acting as your direct representative, and an Incoterm that keeps you in control — FOB or FCA with your own broker, or DDP only where the forwarder expressly declares as your representative using your numbers. Indirect representation, where the broker takes the liability onto itself, exists but is frequently declined for first-time importers.
What Does the Marketplace Actually Handle — Deemed Supplier, OSS, IOSS?
The EU’s One Stop Shop portal summarizes the rules in force since 2021: marketplaces are treated as deemed suppliers in certain circumstances, the Import One Stop Shop (IOSS) covers distance sales of imported goods worth up to €150, and the Union One Stop Shop (OSS) reports distance sales of goods within the EU through a single registration. For a seller established outside the EU: on Amazon’s EU marketplaces, the platform charges and remits the VAT on the business-to-consumer sale under the deemed-supplier rules; your own VAT registrations are still required for every storage country and for the business-to-business leg the deemed-supplier treatment creates; and the Union OSS becomes relevant only when you sell through channels where no marketplace steps in, such as your own webshop.
When Would IOSS Ever Apply to My Amazon EU Business?
Only when a customer order triggers an actual import — for example merchant-fulfilled parcels posted from the US, each worth €150 or less. Under the IOSS scheme, a business not established in the EU cannot register directly; official gov.uk guidance confirms such businesses “must ask an intermediary to register and act on their behalf,” and the intermediary and seller are jointly and severally liable for the IOSS VAT. For orders placed on Amazon’s marketplaces, confirm in Seller Central how the platform applies IOSS collection at checkout before registering anywhere yourself — IOSS is voluntary; without it, the import VAT is collected from the customer at or after the border.
What Changed on 1 July 2026 — the €150 Exemption, the €3 Flat Duty, and What Still Needs Checking
The duty side caught up in 2026, and the details are now official. Under Council Regulation (EU) 2026/382, the EU abolished the customs duty exemption that had applied to low-value consignments up to 30 June 2026 and, from 1 July 2026, imposed a temporary €3 customs duty per item on low-value consignments (up to €150) imported from outside the EU, applicable until 1 July 2028, according to the Commission’s June 2026 guidance. Three details matter for jewelry sellers. The €3 is charged per item based on tariff classification — not per parcel or per quantity: the Commission’s examples price five T-shirts of one classification at €3, and a T-shirt plus a watch at €6. It applies to distance sales of imported goods regardless of the VAT scheme used — IOSS, special arrangements, or standard VAT — and the declarant is the seller or importer of the good. And it is temporary: from 1 July 2028, when the EU Customs Data Hub becomes mandatory for e-commerce, normal customs duties apply under each classification. On top of the duty, an EU handling fee of €2 per distinct item applies from 1 November 2026 — separate from and in addition to the €3 duty, and per Ireland’s Revenue not refundable even where goods prove faulty. The customs reform in force since 21 September 2026 also shifts responsibility for customs formalities on distance sales toward the platforms and sellers selling into the EU. Still needing confirmation in official texts: the normal duty rates for specific jewelry classifications after 1 July 2028, and member-state implementation choices — verify against the Commission’s guidance rather than AI summaries, which circulated unsourced figures before June 2026.
Your First-FBA-Shipment Checklist, in Order
Run this sequence for the first inbound consignment, and repeat the middle steps for every entry afterwards — under staged shipment arrangements, each factory release repeats the import loop.
- Six to eight weeks out: choose the member state of first entry and storage; apply for your EORI there; engage a VAT agent or fiscal representative and confirm in writing whether postponed VAT accounting will be available.
- Four weeks out: appoint a customs broker and agree the representation type and Incoterm; agree tariff classifications for your S925 moissanite lines and check the applicable rates in the official EU tariff rather than copying codes from forums; assemble the document pack — commercial invoice with realistic values, EORI and VAT numbers, packing list, transport documents, and supplier test reports. Sterling silver buyers also keep hallmarking in mind; Amara Jeweiry’s guide to UK and EU hallmarking for S925 silver explains the marks European buyers expect.
- Two weeks out: build the shipment plan in Seller Central, book the fulfillment center delivery, label cartons to Amazon’s specification, and confirm the invoice Incoterm matches whoever is declaring.
- At import: the broker lodges the declaration under your numbers; afterwards, confirm from the entry documents whether import VAT was postponed or paid, because that determines what your return must show.
- First weeks after arrival: check the import line lands on your VAT return; upload and validate your VAT numbers in Seller Central; decide whether non-Amazon channels need a Union OSS registration; and calendar the 2026–2028 duty-side changes.
FAQ
Does Amazon collect import VAT on my FBA inbound shipment?
No. Import VAT on your freight is owed by the importer of record — you, or a representative clearing in your name. Amazon’s collection applies to the customer’s purchase, not to the inventory you import.
Do I need IOSS if I only sell FBA?
No. IOSS covers imported consignments of €150 or less sold directly to consumers. FBA orders ship from inside the EU after one bulk import, so there is no per-order import for IOSS to handle.
Can my supplier or freight forwarder be the importer of record instead of me?
They can clear the goods in their own name, but then the import is theirs: no import VAT document in your name, nothing to reclaim, and a compliance history you cannot inspect. Amazon will not act as importer for your freight either.
Is the €3 per-item duty charged on my bulk shipment to the warehouse?
No. The €3 temporary duty targets distance sales of imported goods in consignments up to €150. A bulk commercial import pays normal third-country duty on the customs value under its tariff classification — confirm the rate in the official EU tariff.
