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Selling on Amazon UK after Brexit: VAT, customs and EORI
Daniel Pawłowski · Amazonway · · ok. 10 min read
Selling on Amazon.co.uk after Brexit is entirely possible for an EU company, but it means treating the United Kingdom as a separate market beyond a customs border, not as another EU country. In practice that comes down to four things: registering for UK VAT (for non-UK businesses there is no threshold, so it applies from the first sale if you hold stock there), an EORI number for customs clearance, an awareness of customs duty and the 135 GBP threshold at which Amazon accounts for the VAT itself, and a separate stock of inventory, because British FBA is cut off from the European network. Below we break each of these obligations down and give an entry checklist.
Legal position: July 2026. VAT, customs and product rules are updated from time to time. The key claims in this text rest on gov.uk and HMRC guidance and Amazon Seller Central notices; we cite a source at every threshold and rate. Before you decide, confirm the numbers in the current version of those sources and in your own Seller Central account, because this information changes over time.
What Brexit changed for selling into the UK
Since 1 January 2021 the United Kingdom (more precisely Great Britain: England, Scotland and Wales) has been outside the EU single market and customs union. For a seller this means a full customs border: every crossing of the border with goods is an import or an export, with a customs declaration, potential duty and import VAT. Gone too is the freedom that selling within the EU accustoms you to, where goods travel between countries without clearance.
The second change is logistical and catches people out most often: Amazon's UK warehouses have been separated from the European ones. The stock that serves customers in the EU will not serve a customer in London, and vice versa. The third change is tax: for marketplace sales Amazon itself has taken over part of the UK VAT responsibility, but, as we show below, that does not release the seller from registering. On top of that came separate product-marking rules (UKCA alongside CE). The rest of the article is the practical consequences of these four changes.
UK VAT: when you must register
The most important difference from the EU concerns the threshold. A British business only registers for VAT once it passes turnover of 90,000 GBP (the threshold for domestic entities, as of tax year 2024/25 per gov.uk). But that threshold most likely will not apply to you. A business with no UK establishment that sells goods there is a so-called non-established taxable person (NETP), and for an NETP there is no registration threshold. As HMRC states (VAT Registration Manual, series VATREG37000), such a business must register for VAT from its first taxable sale if it meets the conditions (typically: it holds goods in a warehouse in the UK, for example in FBA).
The practical conclusion: if you are planning FBA in the UK, assume UK VAT registration from the start, before the goods even arrive. It is not a "once you grow" option.
The 135 GBP threshold and Amazon's role (deemed supplier / OMP)
After Brexit the UK introduced a rule that for sales of imported goods through an online marketplace the platform, not the seller, accounts for the VAT. Under gov.uk guidance (VAT and overseas goods sold to customers in the UK using online marketplaces, updated 13 May 2022):
- for a consignment worth up to 135 GBP (the value of the whole consignment counts, not a single product) sent from outside the UK to a consumer in Great Britain, VAT is charged at the point of sale, and the marketplace (Amazon) is required to collect it and pay it to HMRC;
- when the goods are already sitting in a warehouse in the UK at the point of sale and the seller is a non-UK business, VAT on the sale to the consumer is also accounted for by Amazon as a so-called deemed supplier;
- for B2B sales, where the buyer provides their UK VAT number, Amazon does not charge the tax and accounting shifts to the buyer (reverse charge);
- for consignments worth over 135 GBP the normal import rules apply: import VAT and any duty at the border.
The 135 GBP threshold is measured in pounds; the exchange rate is something you do not control, so treat any conversion as purely indicative. In practice Amazon then adds 20% VAT in the basket and passes it to HMRC itself, and you receive the price without that amount (the "marketplace facilitator" messaging in Seller Central confirms this). Values in GBP, as of July 2026.
The trap: Amazon collects the VAT, but you still need to register
The most common flawed reasoning goes: "since Amazon collects the VAT, I don't have to register". That is untrue. If you hold goods in the UK, you are an NETP and you must have your own UK VAT registration regardless of Amazon accounting for the VAT on sales to the consumer. The registration is needed, among other things, to import the goods, to account for import VAT and to report the so-called supply to the marketplace. On top of that, Amazon will demand a VAT number from you anyway before it lets you sell from UK stock. So do not confuse the platform collecting VAT with the absence of a registration obligation: they are two different things.
EORI: the number you cannot cross the border without
EORI (Economic Operators Registration and Identification) is the number customs authorities work with. After Brexit, to move goods across the UK-EU border you need one on both sides:
- A GB EORI (format: GB plus 12 digits) to import and export goods between Great Britain and any other country, including the EU. HMRC issues it free of charge; you apply through a Government Gateway account and usually get the number straight away (with additional checks, within a few working days). Basis: gov.uk/eori.
- An EU EORI, to declare the export of goods from the EU. An EU company obtains it from its national customs administration (in Poland, through PUESC).
Without an EORI on the sending and receiving side, clearance will not close and the shipment gets stuck. It is the first, purely formal thing to sort out before you send anything to a British warehouse.
Customs duty and declarations: who pays and on what terms
Here comes the most common mistaken assumption: "there is a UK-EU trade deal, so there is no duty". The Trade and Cooperation Agreement (TCA) does indeed remove duties and quotas, but only for goods that meet the rules of origin. A zero duty rate applies when the goods are "originating" in the EU or the UK (made or sufficiently processed in that area) and when, at clearance, you claim the preference and hold proof of origin (a statement on origin issued by the exporter, or so-called importer's knowledge). This follows from gov.uk guidance on proving origin status in UK-EU trade.
The consequence is inconvenient for many sellers: if you source goods from outside the EU (typically from Asia) and merely re-export them from the EU to the UK, they usually do not meet the rules of origin, so despite the UK-EU deal you will pay UK customs duty at a rate that depends on the tariff code. That is a real cost you have to build into the price.
The second decision is the delivery terms (Incoterms), that is, who is responsible for import clearance and charges. In retail sales to a consumer, two mainly matter:
- DDP (Delivered Duty Paid): you as the seller clear the import, pay the duty and import VAT, and the customer receives the parcel with no extra charges. More expensive and more work to handle, but the customer is not caught out.
- DAP (Delivered At Place): responsibility for clearance and charges falls on the recipient. For a B2C parcel that is a straight road to a disappointed customer who, on delivery, is handed a bill for duty and VAT, refuses to pay and returns the parcel.
For consumer sales shipped from the EU, DDP is usually the safer choice. In the FBA model the problem disappears a different way: you clear the goods once, when you bring them into the British warehouse, and after that you sell "locally".
Logistics after Brexit: the UK and the EU are two separate warehouses
This is the change that surprises sellers used to Amazon's European network. Since 1 January 2021 Amazon has stopped FBA inventory transfers between the UK and the EU. In practice this means that the EFN and Pan-EU programmes that link EU countries no longer cover the UK-EU relationship. You cannot fulfil a British customer's order from a warehouse in France, nor a German order from a warehouse in England.
So you have two ways to serve the UK market:
- Stock in the UK (FBA UK or a British warehouse): you clear the goods across the border once, then sell locally with British Prime and local delivery times. It requires UK VAT registration and importing the goods, but gives the best buying experience.
- Shipping from the EU on every order: you build no stock in the UK, but every parcel crosses the customs border, which slows delivery and complicates returns. It makes sense for market tests and low volume, weak at scale.
The choice between them is the same trade-off as when planning logistics within the EU, only with a harder border. Before you work out the profitability of the UK, it is worth understanding the FBA cost structure itself: we break it down in a separate post on Amazon FBA fees. With UK stock you also add British fulfilment and storage, billed in pounds, so calculate the margin for this market separately.
Product marking: UKCA, CE and a UK responsible person
Many product groups (toys, electronics, machinery, personal protective equipment) require a conformity marking to reach the market. After Brexit the UK created its own UKCA marking, but the "everyone switches to UKCA" plan was withdrawn. Under the Product Safety and Metrology etc. (Amendment) Regulations 2024 the UK recognises the CE marking indefinitely for most consumer categories (21 groups of regulations). This means a product with a valid CE mark can legally be placed on the Great Britain market without a separate UKCA; UKCA remains a valid but voluntary alternative (source: gov.uk "Using the UKCA marking").
Three caveats to check for your own category:
- Construction products and medical devices have separate timelines and are not covered by the general CE recognition; confirm their status separately.
- Northern Ireland is a different regime: CE applies there (or UKNI), and UKCA alone is not enough.
- For many regulated products the British market requires a responsible person or economic operator established in the UK (an importer or an authorised representative) who is accountable for conformity. This is an obligation separate from VAT and duty, and it depends on the category; check it in the product-specific guidance on gov.uk before you place goods on the market.
UK vs EU markets: the key differences
If you already sell in the EU, the easiest way to understand the UK is by contrast. Below is a rundown of what works differently from, say, a demanding market like Amazon.de.
| Feature | EU markets (e.g. Amazon.de) | Amazon.co.uk after Brexit |
|---|---|---|
| Customs border | None (single market and customs union) | Full clearance on every import |
| Shared FBA stock | Yes (EFN and Pan-EU link EU countries) | No, UK stock is separated from the EU |
| VAT registration threshold | Register where the goods sit; OSS for distance sales | No threshold for non-UK businesses (register from the 1st sale when you hold stock in the UK) |
| Marketplace role in VAT | Deemed supplier for imports up to 150 EUR (IOSS), among others | Amazon collects VAT on consignments up to 135 GBP and on UK-held goods of non-UK sellers |
| Customs duty | None within the EU | 0% only if the UK-EU rules of origin are met; otherwise a duty rate |
| Marking | CE | CE (recognised indefinitely) or UKCA; Northern Ireland separate |
The practical takeaway: the UK is not "a harder France". It is a market beyond a customs border, which counts separately in costs, taxes and stock. So you plan the profitability of entry per UK, not by converting EU rates.
A checklist for entering Amazon.co.uk
The minimum list of things to close before you start selling from UK stock:
- UK VAT registration planned before you send the goods (for a non-UK business, with no threshold).
- A GB EORI obtained from HMRC and an EU EORI on the origin side.
- Logistics model chosen: UK stock (FBA UK or a British warehouse) versus shipping from the EU, with margin calculated per model.
- Duty estimated: tariff code checked and whether the goods meet the UK-EU rules of origin, plus proof of origin from the supplier if you want the zero preference.
- Incoterms set for shipments from the EU (for B2C usually DDP), so the customer does not pay on delivery.
- Product compliance confirmed: CE or UKCA for your category and any UK responsible person or entity.
- VAT number added in Seller Central and VAT collection by Amazon set where it applies.
- Listing localised into British English (not a translator) and prices set in GBP with the full market cost.
The most common post-Brexit pitfalls
Four mistakes that most often cost sellers money or block the account:
- "Amazon collects the VAT, so I won't register." Untrue if you hold goods in the UK: you are an NETP and registration is mandatory regardless of the platform's collection.
- Assuming EU stock will serve the UK. It will not. EFN and Pan-EU no longer link the UK with the EU, so the British market needs its own stock or cross-border shipping on every order.
- "The UK-EU deal removes duty." Only for UK/EU-originating goods, with proof of origin. Goods from Asia re-exported from the EU will usually pay duty.
- B2C sales on DAP. The customer gets a bill for duty and VAT on delivery, refuses and returns the parcel. For retail, DDP is safer.
Entering the UK with the paperwork on our side
The British market is one of the directions we run as part of international expansion, market by market. In practice most of the time goes not on the listing itself but on the formalities: VAT registrations and returns, EORI, clearances and choosing a logistics model. That is the part we take on at Amazonway so the seller does not get stuck at the border or in HMRC. In our Waypoint framework, entering a new market is stage WP 05 (New markets): the next country joins a proven route, on tested processes, without starting everything from scratch. You can see the stages in how we work.
An honest caveat: we do not promise specific sales or rankings, because they depend on the product, the price and the competition. What we promise is orderly paperwork and profitability worked out before you spend money on UK stock.
FAQ: Amazon UK after Brexit
Can an EU company sell on Amazon.co.uk?
Yes. You do not need a British company. You need the right registrations (UK VAT if you hold goods in the UK), an EORI number and handling of customs and product compliance. The UK is, however, a market beyond a customs border, so treat it separately from the EU.
When must I register for VAT in the UK?
A non-UK business that stores goods in the UK (for example in FBA) has no threshold and should register for VAT from its first sale (NETP status per HMRC). The domestic 90,000 GBP threshold applies to British entities, not to you.
If Amazon collects the VAT, do I still need to register?
Yes. Amazon collecting VAT on consignments up to 135 GBP and on goods sitting in the UK is the platform's obligation, but it does not release you from your own registration when you hold stock in the UK. The registration is needed for imports and returns, and Amazon will demand a VAT number anyway.
How many EORI numbers do I need?
Usually two: a GB EORI (from HMRC) for the British side and an EU EORI (in Poland via PUESC) for export from the EU. Without both, clearance will not close.
Does the UK-EU deal mean I pay no duty?
Only if the goods meet the UK-EU rules of origin and you claim the preference with proof of origin. Goods made outside the UK/EU (for example in China) and merely re-exported from the EU will usually pay duty, despite the deal.
Can I fulfil UK orders from an EU FBA warehouse?
Not within FBA. Since 2021 Amazon does not move FBA inventory between the UK and the EU, and EFN and Pan-EU no longer link those areas. The UK market needs its own stock or cross-border shipping from the EU on every order.
Do I need UKCA marking instead of CE?
For most consumer categories, no: the UK recognises CE indefinitely (Product Safety and Metrology Regulations 2024), and UKCA is a voluntary alternative. Check the exceptions (including construction products, medical devices, Northern Ireland) separately for your category on gov.uk.
Plan your UK entry before you send stock
Amazon UK can be a very good market, but after Brexit you win on the paperwork and on profitability worked out in advance, not on the listing alone. If you want to enter the United Kingdom with VAT, EORI, customs and logistics in order, start with an analysis: we will show whether your range makes sense in the UK and what the real cost of entry is.