---
title: "Pan-EU FBA requirements: Netherlands now, Belgium from 2027"
description: "Pan-EU FBA requirements: an active offer on Amazon.nl since 3 September 2026, and on Amazon.com.be at enrolment from 26 February 2027. Exemptions, fees and VAT."
image: https://www.axholdinggroup.com/hubfs/blog/pan-eu-fba-netherlands-belgium.jpg
---

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[Blog](https://www.axholdinggroup.com/en/blog) · FBA logistics

# Pan-EU FBA requirements: Netherlands now, Belgium from 2027

8 October 2026 · Ax Holding Group™

![Pallet of cardboard boxes with the tags Amazon.nl · 3 Sep 2026 and Amazon.com.be · 26 Feb 2027, next to the title ‘Pan-EU FBA requirements’](https://www.axholdinggroup.com/hubfs/blog/pan-eu-fba-netherlands-belgium.jpg)

Quick answer

Since 3 September 2026, every Pan-EU FBA product, new or existing, needs an active offer on Amazon.nl as well as Amazon.de, Amazon.fr, Amazon.it and Amazon.es. From 26 February 2027 products will also need an active offer on Amazon.com.be at enrolment, and Amazon will give at least 30 days’ notice. You don’t have to store stock in the Netherlands or Belgium. The UK has not been part of Pan-EU FBA since 1 January 2021.

If you sell with Pan-EU FBA, the list of stores where each product needs an offer has changed: the Netherlands is now required for your whole enrolled catalogue, and Belgium follows in February 2027. Today, a product without a Netherlands offer stops meeting the enrolment requirements and can lose the local fulfilment fees that make Pan-EU worth it; from 26 February 2027 the same will apply to Belgium at enrolment. These are the dates, the exemptions, the effect on fees and VAT for sellers inside and outside the EU, and what to check in Seller Central.

## What has changed in the Pan-EU FBA requirements?

Amazon has added stores where a product must have an active offer to stay enrolled in Pan-European FBA. The Netherlands now applies to every enrolled product, new and existing, and Belgium follows at enrolment from 26 February 2027.

| Date | Requirement | Products affected |
| --- | --- | --- |
| Already in force | Active offer in Germany, France, Italy and Spain | All Pan-EU products |
| 3 September 2026 | Active offer in the Netherlands (Amazon.nl) as well | All Pan-EU products, new and existing |
| 26 February 2027 | Active offer in Belgium (Amazon.com.be) as well | Pan-EU products at enrolment; Amazon will give at least 30 days’ notice |

The requirement is about **offers**, not storage. Amazon states that you are not required to store inventory in the Netherlands or Belgium to take part in Pan-EU. According to Amazon’s Pan-EU page for Belgium, you need to enable storage in at least two of Germany, France, Italy and Spain; Poland is also available if you have a VAT registration number in each storage country.

## Is the UK part of Pan-EU FBA?

No. Pan-EU FBA covers nine EU stores: Germany, France, Italy, Spain, the Netherlands, Poland, Sweden, Belgium and Ireland. Amazon states that since 1 January 2021 the UK is no longer part of Pan-EU FBA. To sell with FBA in both the UK and the EU, you need stock in UK and EU fulfilment centres, or Remote Fulfilment between the UK and the EU.

## What happens if a product has no offer in the Netherlands?

Today, it no longer meets the enrolment requirements; from 26 February 2027 the same will apply to Belgium at enrolment. You can check each product’s enrolment status on the Pan-European FBA Inventory page in Seller Central.

Losing Pan-EU has a direct cost. The point of the programme is to pay the local fulfilment fee of the country where Amazon holds the stock instead of the cross-border fee of the European Fulfilment Network (EFN). Amazon puts the saving at up to 53%, which it describes as the maximum achievable saving when comparing EFN costs with local costs for each item’s size and weight.

## Are there exemptions?

Yes. Amazon allows exemptions from the listing requirement, for a limited or unlimited period, in these cases:

| Reason for the exemption | In practice |
| --- | --- |
| The product is restricted or can’t be sold in the Netherlands or Belgium | Categories with local legal restrictions |
| The product doesn’t meet local language requirements for labelling or packaging | Mandatory instructions or warnings that are only in one other language |
| Your account is temporarily deactivated in the Netherlands or Belgium store | A block or pending verification on Amazon.nl or Amazon.com.be |
| The product doesn’t have a detail page in that store yet | An ASIN that hasn’t been created in the Dutch or Belgian store |

Exemptions aren’t applied across the board: check in Seller Central which products have one and which simply have no offer.

## How does it affect fees and VAT?

On fees, Amazon charges local fees on orders from the Netherlands when inventory placement is active in Germany, and on orders from Belgium when it is active in Germany or France. If your Pan-EU set-up only has, for example, Spain and Italy enabled, check how those orders are charged.

On VAT, Amazon’s rule for Pan-EU is that you need a VAT number in each country where your goods are stored, and generally not in the store where you sell. Having an offer on Amazon.nl or Amazon.com.be doesn’t mean storing stock there. What changes is who handles VAT on the sale, depending on where your business is established:

- **Business established in the EU:** sales shipped from one EU country to a consumer in another are intra-EU distance sales, declared through the One Stop Shop (OSS) if you are registered; without OSS you generally need a VAT number in the destination country. Sales from stock in the customer’s own country go in that country’s VAT return.
- **Business established outside the EU (UK, US, China):** under Article 14a(2) of the EU VAT Directive, when a marketplace facilitates a sale to a consumer of goods already in the EU, the marketplace is treated as the supplier. Amazon charges and pays the VAT on those sales (business-to-consumer only; business-to-business sales stay with you), and Amazon notes that, for sales through Amazon, OSS registration only applies to sellers based in the EU. You still need a VAT number, and VAT returns, in each country where your stock is stored.

Check your case with your tax adviser before you activate offers in bulk.

## Checklist: what to review in Seller Central

1. Open the **Pan-European FBA Inventory** page and check the enrolment status of each product.
2. For each one, go to **Manage All Inventory**, select the offer, choose **Edit listing** and enable the Netherlands offer under **Manage offers in other marketplaces**.
3. If you manage many products, use a **Build International Listings (BIL)** connection to the Netherlands to create offers from your source store.
4. Review the Dutch listing itself: translated title, bullet points and attributes, not just an active offer.
5. Check labelling and packaging. If they don’t meet local language requirements, check whether an exemption applies instead of leaving the product without an offer.
6. Confirm which inventory locations you have enabled: Germany for local fees on Dutch orders; Germany or France for Belgian orders.
7. Get ready for Belgium: create offers on Amazon.com.be before 26 February 2027, with adapted listings.
8. Confirm your VAT set-up (and OSS, if you are based in the EU) with your tax adviser before you start selling in new countries.

If you are preparing for peak season, check the inbound deadlines and peak fees in our guide to [Amazon FBA storage and peak fees in Europe](https://www.axholdinggroup.com/en/blog/amazon-fba-storage-fees-europe?hsLang=en): a product that leaves Pan-EU in peak season makes every cross-border order more expensive.

## Frequently asked questions

### When did the Netherlands become mandatory for Pan-EU FBA?

On 3 September 2026. Since then, every Pan-EU FBA product, new or existing, must have an active offer on Amazon.nl as well as in Germany, France, Italy and Spain.

### When will Belgium be mandatory for Pan-EU FBA?

From 26 February 2027, Pan-EU FBA products will need an active offer on Amazon.com.be at enrolment. Amazon has said it will give at least 30 days’ notice.

### Do I have to store stock in the Netherlands or Belgium?

No. Amazon states that you are not required to store inventory in those countries to take part in Pan-EU FBA. The requirement is an active offer in their stores.

### What happens if I don’t enable the offer in the Netherlands?

The product stops meeting the Pan-EU enrolment requirements, which you can see in its enrolment status on the Pan-European FBA Inventory page. If it leaves the programme, it loses local fulfilment fees in the other countries.

### Is Amazon.co.uk part of Pan-EU FBA?

No. The UK has not been part of Pan-EU FBA since 1 January 2021. To sell with FBA in the UK and the EU, you need stock in both, or Remote Fulfilment between them.

### Do I need a VAT number in the Netherlands or Belgium?

Not for Pan-EU itself, unless your stock is stored there: Amazon requires a VAT number in each country where your goods are stored. If your business is in the EU, sales shipped to consumers in those countries are declared through OSS if you are registered; without OSS you generally need a VAT number in the destination country. If your business is outside the EU, Amazon handles the VAT on business-to-consumer sales as the deemed supplier. Confirm it with your tax adviser.

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*Sources: [Amazon Seller Forums, ‘Pan-EU FBA to require Netherlands and Belgium offer’ (August 2026)](https://sellercentral.amazon.com/seller-forums/discussions/t/61296686-3581-4d1a-b3c2-dacbef755b22); [Amazon Belgium, Pan-European Fulfilment by Amazon (English)](https://sell.amazon.com.be/en/expedie-par-amazon/europe); [Council Directive 2006/112/EC on the common system of VAT, consolidated text (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006L0112-20250101), Articles 14a and 136a. Checked on 7 October 2026. This article is for information only and is not tax advice.*

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