PAN-EU Amazon: when does it make sense and how do you get started?

What exactly is PAN-EU Amazon?

Pan-European FBA, most commonly referred to as PAN-EU, is a fulfilment model designed for sellers that do not want to treat every European market as a separate logistics project. Instead of keeping inventory exclusively in one country and fulfilling all cross-border orders from there, the business allows Amazon to store its products in several selected countries. As a result, some orders can be fulfilled from a warehouse closer to the customer, using domestic fulfilment rates. In practice, this means moving away from a model in which inventory is concentrated in one or several countries selected and managed independently, towards a network in which Amazon can distribute stock between enabled countries based on expected demand. For a business already generating regular sales in several European markets, this can mean shorter delivery distances and lower fulfilment costs for some orders.

There is, however, another side to this arrangement. The goods still belong to the seller, even when Amazon physically moves them from one country to another. From a VAT perspective, transferring your own inventory between EU Member States may be treated as an intra-Community transfer of goods and can create additional reporting obligations. A logistics decision therefore becomes a tax and operational decision at the same time. This is precisely what distinguishes PAN-EU from simply “extending the reach” of FBA. The business gains access to a more localised fulfilment model, but it must also be prepared for the consequences of storing its own inventory outside the country in which that stock was previously held.

How does Pan-European FBA work?

From a logistics perspective, the PAN-EU mechanism is relatively straightforward. The seller sends inventory into Amazon’s fulfilment network and specifies the countries in which it allows that inventory to be stored. The seller does not, however, choose a particular fulfilment centre or independently decide how many units of a product should be placed in each warehouse. Amazon distributes inventory across its network within the enabled countries, taking into account factors such as forecast demand and operational requirements. PAN-EU inventory storage can currently be enabled in Germany, France, Italy, Spain and Poland, and the seller must allow inventory placement in at least two of these countries. If a business enables Germany and France, for example, part of its inventory may be moved between the two countries without the seller having to organise each transfer independently.

For a medium-sized e-commerce business, the biggest change is therefore not the initial shipment of goods to an Amazon warehouse, but what happens to the inventory afterwards. In a simpler model, a seller can relatively easily determine where its goods are stored and from which country its sales are being fulfilled. With PAN-EU, the business must accept that inventory can be distributed across previously enabled countries according to the needs of Amazon’s network. This makes it possible to fulfil more orders locally or regionally, reduce the distance between the product and the customer, and benefit from domestic FBA fulfilment fees where the programme’s conditions are met. At the same time, every country in which the seller’s own goods are physically stored matters from a VAT perspective. Under the standard PAN-EU model, enabling storage of your inventory in a particular country generally means having to obtain a local VAT registration there and account for inventory movements and subsequent transactions in accordance with local rules. Storage countries should therefore be selected on the basis of sales, margins and compliance costs, rather than simply the size of the market.

PAN-EU, EFN and local FBA — what’s the difference?

The easiest way to understand PAN-EU is to compare it with two models that European sellers will often encounter earlier in their expansion journey. With local FBA, a business stores inventory in a selected country or countries and uses the local fulfilment infrastructure to process orders. EFN, or the European Fulfilment Network, allows inventory stored in a country where the seller has enabled FBA storage to be used to serve customers on other European marketplaces as well. The goods are not automatically moved to the customer’s country simply because an order is placed there. Instead, the parcel can be shipped cross-border from the location where the inventory is already stored. This makes the early stages of expansion simpler, as the business does not immediately have to distribute stock across multiple countries, although fulfilling international orders may involve higher fees than local fulfilment. PAN-EU changes this logic: instead of repeatedly transporting individual parcels across borders to customers, it allows part of the inventory to be positioned in enabled countries in advance and orders to be fulfilled from there.

This distinction matters because PAN-EU is not simply “bigger FBA” or an automatic next step after EFN. When the way inventory is distributed changes, the company’s cost structure and compliance obligations change with it. EFN makes it possible to enter several markets without physically distributing inventory across each of those countries, which can make it a convenient option while testing demand. PAN-EU becomes more interesting once international sales reach a scale at which higher cross-border fulfilment costs begin to have a meaningful impact on margins and local product availability could improve delivery times. The price of that optimisation, however, is greater tax and operational complexity. It is also important to remember that OSS does not replace local obligations arising from storing and moving your own inventory. It can, however, be used to report eligible intra-Community distance sales of goods to consumers in other EU Member States.

Cost calculations should also be based on current fees rather than pricing tables from several years ago. From 17 April 2026, an additional 1.5% fuel and logistics surcharge applies to FBA fees across a number of European markets. These include Germany, France, Italy, Spain, Poland, the Netherlands, Sweden, Ireland and Belgium. The difference may appear small on an individual order, but at several thousand or tens of thousands of shipments per month, it can become relevant when comparing PAN-EU with EFN. The answer to which model is cheaper should therefore always come from an up-to-date calculation based on specific products, parcel dimensions, sales destinations and volumes, rather than from a general assumption that one model will be more cost-effective in every situation.

In which countries can inventory be stored?

With PAN-EU, it is important to distinguish clearly between the marketplaces where a product must or may have an active offer and the countries where Amazon can physically place inventory. These are two different elements of the programme, and confusing them can easily lead to incorrect conclusions about VAT obligations. As of 17 September 2026, PAN-EU inventory placement countries are Germany, France, Italy, Spain and Poland. Sellers choose from these countries when deciding where they allow inventory to be stored, with the programme requiring at least two storage countries to be enabled. The Netherlands and Belgium are not currently PAN-EU inventory placement countries, even if a product may or must have an active listing there. In other words, having an offer on a local marketplace does not automatically mean that the seller’s goods will be physically stored in that country.

Active listing requirements should be considered separately. From 3 September 2026, products participating in PAN-EU must have active offers in markets including Germany, France, Italy, Spain and the Netherlands. Poland, Sweden and Ireland remain additional sales options. From 26 February 2027, Amazon also plans to require an active offer in Belgium. This does not, however, mean that inventory must be stored in all of these countries. A business can therefore maintain an active listing in a market that is not simultaneously a PAN-EU inventory storage country. For a company planning European expansion, this distinction is critical: a listing country is not the same as a storage country, and it is the physical location of the seller’s own goods that is particularly important when determining local VAT registration requirements and the treatment of inventory movements. Programme rules, required marketplaces and eligibility conditions can change, so sellers should always check the current requirements for specific products and selected storage countries before enabling PAN-EU.

When does PAN-EU Amazon really make financial sense?

PAN-EU becomes interesting not simply when a business “starts selling abroad”, but when the scale of those sales means the current fulfilment model is noticeably reducing margins or limiting further growth. In practice, fulfilment costs, sales volumes in individual countries, inventory turnover, product margins and additional tax obligations all need to be considered together. A business can perform very well in Germany or France and still fail to gain enough from PAN-EU if the difference between its current fees and local fulfilment costs is small, or if the additional cost of VAT compliance absorbs most of the savings. On the other hand, when several thousand orders are being fulfilled cross-border, even a moderate difference in the cost of a single shipment can translate into a significant annual amount.

For this reason, the decision to adopt PAN-EU should be treated as a financial and operational project rather than a technical change to account settings. The first step is to establish where the business actually sells, where those orders are currently fulfilled from, how much the existing model costs and which products account for most of the volume. Only then can the potential savings from local fulfilment be compared with the costs of VAT registration and compliance, reporting, storage and maintaining sufficient inventory within the FBA network. For a business that already generates repeatable sales across several countries and has a clear view of profitability at SKU level, PAN-EU can become an optimisation tool. For a company that is still testing whether international markets will be profitable, it can instead increase operational complexity faster than it increases revenue.

There is no single “magic” sales threshold

There is no reliable way to say that PAN-EU starts to make sense at 500, 1,000 or 5,000 orders per month. Amazon does not define a minimum sales volume at which the programme becomes economically viable, because the outcome depends on the seller’s specific configuration. Two businesses generating 2,000 orders per month can reach completely different conclusions if one has most of its customers outside the country where inventory is stored, while the other sells primarily within its domestic market. Product dimensions and weight, current fulfilment fees, unit margin and the share of orders fulfilled cross-border also matter. The difference can be substantial. Amazon indicates, for example, that with the appropriate inventory placement configuration, fulfilment fees for orders in the Netherlands can be around 45% lower on average than cross-border EFN fees. This is not, however, a universal savings rate that can be applied to every product or market.

The calculation should also include storage costs, working-capital requirements, VAT compliance and the predictability of demand. For seasonal products or products with highly uneven sales patterns, forecasting the right level of inventory within the FBA network becomes more difficult, increasing the risk of overstocking and the associated storage and capital costs. The seller does not need to manually maintain a specific number of units in each country: once the relevant storage countries are enabled, Amazon can redistribute inventory between them according to forecast demand. The calculation should always use current pricing. From 17 April 2026, Amazon also applies a 1.5% fuel and logistics surcharge to FBA fees on the European marketplaces covered by the change, so any PAN-EU versus EFN comparison should be based on current rates for the specific SKUs involved.

6–7 signs that PAN-EU may make sense

The first strong signal is consistent sales across several European markets. This does not mean occasional orders appearing from time to time, but a level of volume that can already be forecast using data from previous months. The second signal is a high proportion of orders being fulfilled cross-border. If a business regularly ships hundreds or thousands of orders to customers in other countries from inventory stored in a single location, it is worth calculating what the cost structure would look like after enabling additional inventory placement countries. Fast product turnover and relatively stable demand are also positive indicators. The easier it is to forecast sales in the most important markets, the easier it becomes to manage overall inventory levels and reduce the risk that excess stock will begin generating unnecessary storage costs.

Margins and the company’s organisational readiness are equally important. PAN-EU should not be assessed solely through the lens of a lower per-order fulfilment fee, because VAT registrations, tax returns and inventory-flow monitoring also come at a cost. It is also worth remembering that the number of marketplaces on which a company has active offers does not automatically correspond to the number of VAT registrations required. Having to maintain a listing in a particular Amazon store does not mean inventory is stored there. PAN-EU inventory placement can currently be enabled in Germany, France, Italy, Spain and Poland, and the programme can be launched with two storage countries. The final important signal is a well-organised catalogue and compliance setup. A business with strong control over product documentation, sales data and tax reporting is in a much better position to scale the programme than one that already struggles to reconcile inventory or tax obligations under its existing setup.

Which products are particularly well suited to PAN-EU?

PAN-EU is worth analysing first and foremost for products that sell quickly and generate regular sales across several markets. Consistent demand provides enough data to compare the current cost of cross-border fulfilment with a model in which Amazon can store inventory closer to some customers. Products that sell throughout most of the year can be particularly interesting, as their demand and required inventory levels are easier to forecast. Delivery speed may also matter. If customers in a particular category expect fast fulfilment and compare similar offers partly on that basis, the ability to fulfil a larger share of orders locally may strengthen an offer’s competitiveness. That said, faster delivery alone should not be assumed to justify the additional tax and operational complexity.

Product size and weight also matter because they affect fulfilment fees, storage costs and the economics of each SKU, but they are not standalone criteria for determining whether PAN-EU will be profitable. A large or heavier product can still generate meaningful savings if the difference between cross-border EFN fees and local fulfilment is sufficiently high. Rather than assuming that the programme is mainly suited to small and lightweight products, it is better to assess each product using actual fee data. Unit economics remain crucial: the margin must be sufficient to cover fulfilment, storage and VAT compliance while still leaving the business with a meaningful benefit after changing the model. For this reason, the first candidates for analysis should usually be the best-selling SKUs rather than the entire catalogue.

Is PAN-EU right for me? A quick decision test

The simplest test is not based on a single metric, but on a few questions about the company’s current situation. Do you sell regularly in several EU countries? Is a significant share of those orders currently fulfilled cross-border? Do you have products that maintain stable sales over many months rather than only during a short season? At your current scale, is the difference between local and cross-border fulfilment fees beginning to have a noticeable impact on profitability? If the answer to most of these questions is “yes”, PAN-EU is at least worth analysing in detail at the level of specific products and markets.

The second part of the test concerns organisational readiness. A business may have sufficient sales volume and still not be ready to expand inventory placement. It is therefore important to check whether product margins leave room for additional compliance costs, whether the company is prepared for local VAT obligations in the selected storage countries, and whether it has processes in place to reconcile sales, inventory and stock movements between countries. PAN-EU is far more predictable for a business that understands its operational data and can use it to monitor profitability in individual markets. If those data are missing, the first step should be to organise them before deciding whether to allow Amazon to distribute inventory across additional countries.

PAN-EU is probably worth calculating if…

PAN-EU is particularly worth analysing once international sales have moved beyond the experimental stage. If several markets generate orders consistently, best-selling products have stable demand and a significant share of parcels are being shipped to customers from inventory stored in another country, there is usually enough data to build a realistic calculation. In that situation, the business can calculate how much it currently spends on cross-border fulfilment and compare that with the cost of fulfilment after enabling additional inventory placement countries. This becomes increasingly important at higher volumes, as even a relatively small difference per order begins to accumulate. In some configurations, the gap can be much larger. One example is Amazon’s comparison for orders in the Netherlands, where, with the appropriate inventory placement setup, the average difference compared with EFN can reach around 45%.

At the same time, the business should be prepared for the additional processes that come with logistics savings. If the company has sufficient margin, is ready for local VAT registrations and reporting in the countries where inventory will be stored, and its team can monitor inventory movements, PAN-EU can become a natural next step in scaling. A well-organised catalogue is another positive sign, particularly when it is easy to identify products with the greatest potential and separate them from low-turnover SKUs. There is also no need to enable the entire product range at once, as PAN-EU eligibility and enrolment operate at product level. A business can therefore start with selected ASINs for which the cost difference appears most promising and then measure the programme’s actual impact on profitability.

PAN-EU is probably not right for me yet if…

If international sales are only just beginning and individual markets generate only a handful or a dozen occasional orders, PAN-EU may be introduced too early. At that stage, the business does not yet know which countries will genuinely matter, what demand for individual products will look like, or whether it will remain stable over the coming months. Unpredictable demand also makes it harder to determine the right overall level of inventory sent into the FBA network, which can increase the risk of overstocking and higher storage costs. A similar issue arises with very low-margin products or SKUs whose sales outside the main market are too limited for lower fulfilment costs to offset the additional tax and operational expenses.

Caution is also advisable when the business does not yet have VAT processes in place, does not continuously track the location and movement of its own inventory, or has gaps in product documentation and compliance requirements. PAN-EU does not solve these problems; in most cases, it increases the number of processes that need to be controlled. If a company already struggles to reconcile sales data under its current model, adding further inventory placement countries can quickly increase the risk of tax and operational errors. In that situation, it is more sensible to organise internal processes first, confirm demand and build repeatable international sales. Only then is it worth returning to the PAN-EU calculation and checking whether fulfilling a greater share of orders locally generates enough savings to justify the additional complexity.

How do you calculate whether PAN-EU will be profitable?

PAN-EU profitability is best analysed simultaneously at the level of individual products, sales destinations and the company’s overall operating model. An account-wide average can hide significant differences between individual SKUs. One product may generate clear savings through local fulfilment, while another may prove less attractive once actual fees, storage and its share of administrative costs are included. The starting point should be data from the previous few months: the number of orders shipped to individual countries, the current cost of fulfilling them, unit margin, product size and weight, and the way inventory is currently stored. A second scenario should then be built showing what those same orders would look like under PAN-EU. The key principle is simple: do not add together every cost associated with international selling. Instead, compare the difference between the current scenario and the PAN-EU scenario. If the business already incurs a particular cost under EFN, that cost should not be counted again as an additional PAN-EU expense.

A simple profitability formula

The most practical formula can be written as follows: PAN-EU impact = (fulfilment cost before – fulfilment cost after) × number of orders + additional sales margin – additional fixed costs – additional variable costs. This approach is more useful than simply subtracting “VAT costs”, because VAT due itself is not an implementation cost in the same sense as tax compliance services. The calculation should primarily include additional VAT compliance expenses such as registrations, returns, reporting, accounting, data reconciliation and the handling of movements of the company’s own inventory. On the revenue side, it is sensible to remain cautious. Faster and more predictable delivery may increase sales, but unless the company has its own data demonstrating that effect, it is better to prepare a base case with no additional growth and a second scenario assuming a moderate improvement in sales. This prevents the decision from being based on an optimistic assumption that may later be difficult to verify.

When analysing individual SKUs, shared costs also need to be allocated correctly. VAT registration and monthly VAT return services in Germany do not arise separately for each product. If, for example, the cost of supporting a particular country is EUR 300 per month and the company sells 30 products there under the model being analysed, it would be incorrect to assign the full EUR 300 to every SKU. An allocation method is needed, for example based on units sold, revenue, order volume or the product’s share of sales. The same applies to other shared costs incurred at company or market level. Only after these costs have been allocated can the business see which products are genuinely financing the more complex model, where PAN-EU improves profitability, and where it only appears attractive when looking at the fulfilment fee alone.

Example calculation

Assume a business fulfils 1,500 cross-border orders per month and, after applying an appropriate PAN-EU configuration, the average fulfilment cost for those orders would be EUR 1.80 lower. This is purely a hypothetical assumption, as the actual difference depends on the specific product, its dimensions and weight, the destination market and the current fee schedule. Under these assumptions, the potential gross saving would be EUR 2,700 per month, or EUR 32,400 per year if order volume remained unchanged. This is only the first stage of the calculation. Only the costs that genuinely appear or increase as a result of the new configuration should then be deducted. If additional VAT compliance, reporting, accounting, storage and other incremental costs total EUR 1,100 per month, the actual benefit falls to EUR 1,600. It is this figure, rather than the initial EUR 2,700, that shows the real operational benefit before any potential increase in sales is taken into account.

It is worth running the calculation across several volume scenarios from the outset, because some costs will be fixed while others will change with the number of orders. If sales decline, the cost of local VAT compliance may remain broadly similar while fulfilment savings decrease significantly. As volume increases, the opposite may happen: fixed costs will represent a smaller share of total sales, while per-order savings will scale with order volume. The comparison should also be based on current fees. From 17 April 2026, a 1.5% fuel and logistics surcharge is added to FBA fees on the European marketplaces covered by the change. For that reason, calculations should not rely on old pricing tables or historical rates, but should use current fees for the specific products and sales destinations being analysed.

Costs that are easy to overlook

The most common mistake is to compare two fulfilment fees and treat the entire difference as pure savings. In reality, the calculation needs to include above all the additional costs that arise only after the configuration changes. These may include VAT registrations, preparation of local returns, reporting movements of the company’s own goods, additional accounting reconciliations and, where applicable, Intrastat obligations under local rules and thresholds. The business should also consider inventory financing, storage and return-handling costs if these change compared with the current model. Even if Amazon can redistribute inventory between enabled countries without charging a separate fee for the transfer itself, the business still needs to finance an appropriate level of inventory across the overall pool and bears the consequences of overstocking.

More caution is needed when assigning costs such as EPR, listing localisation or product compliance directly to PAN-EU. Not all of these arise because of a change in the storage model. A business that already sells on a particular marketplace through EFN may already have EPR obligations, translated listings, local product descriptions and compliance processes in place independently of PAN-EU. The calculation should therefore include only the portion of a cost that appears or increases as a result of the new configuration. If an obligation already existed and its cost will not change after moving to PAN-EU, it should not be treated as a new expense. The same applies to listing management, product documentation and returns. From an economic perspective, the most important question is not “how much does PAN-EU cost in total?”, but rather “how much will my overall costs and margins change compared with the current model?”.

Watch out for changes from 2027. The VAT obligations described in this section refer to the rules applicable in 2026. From 1 January 2027, changes resulting from the EU’s ViDA package are due to take effect, including a new mechanism covering cross-border movements of a business’s own goods under the Single VAT Registration framework. This is particularly relevant for companies using PAN-EU, because the current treatment of movements of their own inventory between Member States is one of the areas affected by the changes. Before launching or changing a PAN-EU configuration in 2027, it will therefore be worth reassessing the scope of required VAT registrations and the way inventory transfers are reported.

What happens if you do not move to PAN-EU?

Not using PAN-EU does not in itself mean that a business is operating inefficiently. The problem arises when a company steadily increases sales in other European markets, fulfils more and more orders cross-border, and at the same time fails to check whether the existing model still makes economic sense. A cost that was almost invisible at low volume can become a significant drag on margins after a year or more. The point is therefore not that every business should switch to PAN-EU, but that the model should be recalculated as sales grow. If the absolute cost difference between cross-border EFN and local fulfilment continues to increase, maintaining the existing setup stops being a neutral decision. The company begins paying for the simplicity of the current model, even though the administrative convenience may no longer compensate for the higher cost.

You may be consistently overpaying for cross-border fulfilment

At a few dozen orders per month, the difference between local and cross-border fees may be too small to justify additional registrations and processes. At several thousand orders, the picture can look very different. If the difference is, for example, EUR 1 per shipment, then at 2,000 orders this amounts to EUR 2,000 per month, or EUR 24,000 per year. This does not mean that the entire amount will automatically become profit after switching to PAN-EU, because additional VAT compliance, storage and other process-related costs still need to be deducted. It does, however, show the potential scale of the issue. A small but recurring difference per order can eventually become one of the more significant costs associated with European expansion. A company that never performs this comparison may spend years paying more simply because the fulfilment model chosen at the beginning of its expansion was never reassessed.

Slower delivery may limit sales potential

One of the main benefits of local or regional inventory placement is the ability to shorten and stabilise delivery times. This will not matter equally in every category, and businesses should not assume that moving to PAN-EU will automatically produce a specific increase in conversion. In some segments, however, fulfilment speed is one of the factors customers consider alongside price, reviews and product availability. If a comparable offer is delivered faster or within a more predictable timeframe, it may have an advantage, particularly for frequently purchased products, everyday goods or orders where timing matters. Remaining with a cross-border model therefore means consciously accepting the current level of logistics performance. That may be perfectly reasonable, but it should be based on data rather than on a lack of analysis.

The hardest part is putting a value on the impact of delivery speed on sales, because it cannot be measured as easily as fulfilment fees. A conservative approach is therefore advisable. First, check whether PAN-EU makes financial sense without assuming any additional sales growth. Only then should a potential conversion improvement be treated as additional upside. This reduces the risk of making a decision based on assumptions that may not hold true in a particular category. If the company later sees that faster fulfilment genuinely increases sales, that becomes an additional benefit, but it does not need to be the factor that justifies the entire project.

As sales grow, lost margin can increase faster than implementation costs

The most expensive situation occurs when a business grows but its logistics model remains the same as it was at the beginning of its expansion. An additional fee of EUR 1 or EUR 2 has limited significance at a few dozen orders per month. At several thousand orders, however, it becomes a recurring cost that may exceed the monthly expense of additional VAT registrations, reporting or accounting support. At that point, failing to optimise is no longer financially neutral. The company does not receive one large invoice for using the wrong model; instead, it gives up a small amount of margin on every additional order. The faster volume grows, the faster the total amount of lost margin increases.

The question should therefore not only be “how much will PAN-EU cost to implement?”, but also “how much does staying with the current model cost us?”. If implementation and ongoing compliance cost a certain amount per month while predictable savings on cross-border fulfilment are two or three times higher, the cost of inaction becomes measurable. This relationship will not apply to every business, which is precisely why an individual analysis is necessary. For companies rapidly increasing sales across several EU countries, regularly recalculating this point may ultimately matter more than a one-off optimisation of pricing or advertising campaigns.

But not using PAN-EU is not always a mistake

PAN-EU is not a mandatory stage in the development of every seller, and in many situations remaining with a simpler model may be the more rational choice. If sales in other European markets are still limited, demand is difficult to forecast and the company is still testing which countries genuinely have potential, the cost of additional registrations and ongoing VAT compliance may exceed the savings on fulfilment. The same applies to SKUs generating too little volume or products for which the difference between local and cross-border fees is small. EFN can then provide a way to test demand without increasing the number of countries in which the company’s own goods are stored and without adding more processes before sales volume has been confirmed.

The key, however, is to ensure that remaining with the current model is the result of a calculation rather than habit. The risk is not simply “not having PAN-EU”. The risk is continuing to use a more expensive solution once the numbers already show that the additional cost of VAT compliance and managing a more distributed model would be lower than the recurring fulfilment savings. If, on the other hand, the calculation shows that the savings are limited, demand is unstable and incremental costs are high, remaining with EFN may be entirely rational. PAN-EU makes sense when it improves the company’s financial performance after all cost differences are taken into account, not simply because it appears more operationally advanced.

The biggest PAN-EU trap: VAT

PAN-EU logistics are relatively easy to understand: the business provides inventory, selects inventory placement countries, and Amazon can move goods between enabled countries and fulfil orders closer to customers. The tax side of the same process is much more complex. From the business owner’s perspective, the goods may simply have moved from one warehouse to another within the same logistics network, but for VAT purposes, the company’s own inventory crossing a border can constitute a separate event that may need to be reported accordingly. On top of this, there may be local sales from inventory stored in a particular country and cross-border sales to consumers in other Member States. As a result, one inventory pool can generate several different types of transactions that do not automatically fall into the same reporting mechanism. With PAN-EU, it is therefore not enough to know how much the company sold and which country the order was delivered to. The business also needs to know where the goods were located before the sale, whether they had previously been moved, and from which country the shipment to the customer began.

Why doesn’t OSS solve the entire problem?

OSS, or the One Stop Shop, does significantly simplify European e-commerce, but it is easy to assume that its scope is broader than it really is. The Union scheme allows a business to report in one Member State, among other things, qualifying intra-Community distance sales of goods to consumers located in other EU countries. It is not, however, a system through which the entire VAT treatment of a company’s European operations can be handled. Under the rules applicable in 2026, the standard Union OSS does not cover the movement of a company’s own inventory from one Member State to another, nor does it generally cover domestic sales of the company’s own goods from a warehouse to a consumer located in the same country. A business may therefore use OSS in its Member State of identification while simultaneously filing local VAT returns in Germany, France or other countries in which it stores its own inventory.

The key principle can therefore be summarised as follows: under the rules applicable in 2026, the standard Union OSS does not replace local VAT registration required as a result of storing and moving a company’s own goods in another Member State. This distinction is particularly important with PAN-EU, because marketplace presence and the physical location of inventory are two separate issues. A business may sell to consumers in several countries without holding inventory in each of them and report qualifying cross-border B2C sales through OSS. However, if it enables inventory placement in another country and its own goods are physically moved there, an additional layer of obligations arises. Before enabling another storage country, the business therefore needs to assess not only the potential fulfilment savings, but also how the decision affects local VAT registrations and the reporting of inventory movements.

Why does inventory storage create additional obligations?

The first source of additional obligations is the simple fact of holding your own inventory in another country. Under PAN-EU, the seller remains the owner of the goods stored in fulfilment centres, even if Amazon decides how those goods are physically distributed across enabled countries. If inventory is moved, for example, from France to Germany, that movement of the company’s own goods is generally treated for VAT purposes as a relevant intra-Community transaction and must be reported correctly. No sale to a customer needs to take place. The goods may still belong to the same company, yet their physical movement between Member States can still trigger tax consequences. This is one of the most important differences between the logistics and tax perspectives on PAN-EU: what looks operationally like an internal warehouse transfer may, for VAT purposes, need to be accounted for on both sides of the movement.

The next stage is the sale itself. If a product is stored in a warehouse in Germany and sold to a consumer in Germany, this will generally be treated as a domestic German sale, subject to any special arrangements that may apply in the specific situation. If the same product stored in Germany is instead shipped to a consumer in France, an intra-Community distance sale of goods may arise and, provided the relevant conditions are met, it may be reported through Union OSS. On top of this, there may also have been earlier inventory transfers between enabled countries. A single unit of stock may therefore first be moved between two Member States as the seller’s own inventory and only later become the subject of a domestic or cross-border sale. This is why PAN-EU accounting requires reliable data on the physical movement of goods, not merely information about the final value of sales.

OSS vs local VAT — what do you report where?

The simplest way to think about OSS is as a procedure that simplifies the reporting of certain B2C transactions, rather than as a replacement for domestic VAT systems. Where a particular transaction should be reported depends mainly on its nature and on the location of the goods before dispatch begins. Under PAN-EU, this means sales data need to be combined with inventory-location data. Knowing only that the customer is in France is not enough to classify the transaction correctly. A sale to a French consumer from a warehouse in France is treated differently from a shipment to the same customer from a warehouse in Germany.

In practice, a business using PAN-EU may therefore file an OSS return in its Member State of identification while also submitting standard VAT returns in countries connected with the storage of its inventory. This does not mean that the same sale is taxed twice. It means that different events are being reported through the appropriate systems. OSS may cover qualifying cross-border B2C sales, while domestic VAT returns are used for events that fall outside the scope of OSS. The biggest risk is assuming that, because the business already uses OSS, all of its European VAT obligations have been “centralised”. With PAN-EU, that simplification can lead to overlooked inventory transfers, domestic sales or other stock-related events.

How many VAT numbers might be needed?

There is no single number of VAT registrations that applies to every business using PAN-EU. Under the rules applicable in 2026, the answer depends primarily on the countries in which the seller allows its inventory to be stored and the types of transactions created by that configuration. PAN-EU inventory placement can currently be enabled in Germany, France, Italy, Spain and Poland, and the programme can be started with as few as two active storage countries. An EU-based business could therefore use a setup involving, for example, France and Germany, or France, Germany and Italy. Enabling an additional inventory placement country may mean adding another local VAT registration and dealing with VAT returns in that jurisdiction under the applicable rules.

The number of marketplaces should not, however, be directly translated into the number of VAT registrations required. A business may have active offers on several European Amazon stores without storing its own goods in every one of those countries. A listing is not the same as inventory placement, just as selling to a customer in a particular country does not automatically mean the inventory was stored there. When determining which VAT registrations may be required, the more useful question is therefore not “how many marketplaces do we sell on?”, but rather “in which countries is our own inventory located, or where could it be located, and what transactions are carried out from that inventory?”. The map of physical goods flows should be the starting point for determining the VAT structure.

This description refers to the rules applicable in 2026. The EU’s ViDA package provides for a significant simplification of cross-border movements of a business’s own goods through a new special scheme under Single VAT Registration. This solution is expected to apply from 1 July 2028. For businesses using PAN-EU, it may in future reduce some of the registration obligations that currently arise when their own inventory is moved between EU Member States. Until the new rules take effect, however, obligations should continue to be assessed under the VAT framework currently in force, and businesses should not assume that starting PAN-EU operations in 2027 will automatically remove existing registration requirements.

PAN-EU is not only about VAT. What other obligations should you keep in mind?

VAT is usually the first area a business considers when evaluating PAN-EU, but it should not be the only one. Expanding across several markets also means more inventory data, reporting, environmental requirements and product-related obligations. Some of these are directly connected with inventory movements, while others arise simply because particular products are offered to consumers in a given market. This distinction matters because, just as with profitability calculations, obligations that already existed before PAN-EU should not automatically be attributed to the programme. A business using EFN may already be subject to EPR, product-safety requirements or local information obligations. Changing the fulfilment model may, however, increase the scale of operations and the number of processes that require regular monitoring.

Local VAT returns and movements of your own inventory

Once storage is enabled in several countries, the business needs to monitor not only sales, but also transfers of its own inventory. In practice, this means regularly reconciling data showing where goods were dispatched from, where they were moved to and from which country they were ultimately sold. This information is needed to prepare local VAT returns correctly and account for intra-Community movements of the company’s own goods under the rules applicable in 2026. Operationally, the transfer may take place automatically within the fulfilment network, but responsibility for correct tax reporting remains with the business. The company therefore needs a process that allows it to obtain inventory-movement data regularly, combine them with sales data and resolve discrepancies before returns are prepared.

At larger scale, checking total monthly turnover is not enough. There needs to be consistency between inventory reports, shipment data, transfer information and the accounting records. If operational data show that goods have already moved from France to Germany, but the system used for VAT reporting still treats them as French inventory, the error can affect several subsequent reports. One of the most important capabilities in PAN-EU is therefore not simply preparing VAT returns, but systematically reconciling the underlying source data. The more SKUs, storage countries and transfers are involved, the harder it becomes to maintain full control over the movement of goods without such a process.

Inventory reports and Intrastat

Inventory movement reporting matters for more than VAT. Depending on the country, the value of the flows and local rules, Intrastat obligations may also arise. Businesses should not assume that enabling PAN-EU automatically means filing Intrastat declarations from the first month, as thresholds are set nationally and may be updated. In practice, the relevant movement values need to be monitored to determine whether the company has exceeded the applicable thresholds for a particular country and direction of movement. Importantly, Intrastat is not limited to traditional invoiced sales to customers, so physical transfers of the company’s own inventory may also be relevant.

From a business perspective, inventory data should be treated as a core record of the entire PAN-EU model. They should make it possible to reconstruct the journey of goods from their entry into the FBA network, through any transfers between countries, to the final shipment to the customer. These data are useful not only for preparing returns, but also for monitoring profitability. Without information about where orders were actually fulfilled from and how often inventory changed storage country, a business may have a complete view of revenue but a much weaker understanding of costs and the reasons those costs are changing.

EPR and environmental obligations

EPR, or Extended Producer Responsibility, is easy to misinterpret as a cost arising directly from PAN-EU. In reality, EPR obligations are primarily linked to placing certain products or packaging on a particular market, rather than solely to where those goods are stored. A business already selling into Germany or France through EFN may therefore be subject to some EPR obligations before PAN-EU is ever enabled. The scope depends on the country and the product category. Different requirements may apply to packaging, electrical and electronic equipment, batteries or accumulators. Depending on the system, businesses may need to register, report regularly on the quantities of products placed on the market, and finance the relevant waste-management schemes.

For this reason, companies expanding across Europe should build a country-by-product map of their obligations rather than relying on a single checklist for the entire European Union. Existing obligations should also be separated from those that arise only when the business enters another market or expands the scope of its sales. If a company has been selling a product in Germany for some time and already holds the required environmental registrations, moving from EFN to PAN-EU does not automatically create a new EPR obligation. By contrast, expanding sales into a new market or introducing a new product category may require additional action regardless of where the inventory is physically stored.

Product safety, CE marking, labels and instructions

Every product offered to consumers in the EU must comply with the applicable safety requirements regardless of whether sales are fulfilled through PAN-EU, EFN or the seller’s own online store. The exact requirements depend on the product category and the company’s role in the supply chain. In online sales, businesses need to take into account requirements arising from the GPSR, including appropriate information identifying the product and manufacturer, required warnings and relevant safety information. This is particularly important for businesses importing products from outside the European Union, which is a common model for marketplace sellers.

For products originating from a manufacturer outside the EU, it is also necessary to verify who acts as the responsible person in the EU and whether the required details of that entity are made available correctly under the applicable rules. Depending on the product and regulation, this information may need to appear on the product, its packaging, accompanying documentation and, in distance selling, also within the offer itself. For a business importing products from China or another non-EU country, this means that having a correct listing and active FBA setup is not enough. The chain of product responsibility must also be properly organised and capable of being documented.

Similar care is required with CE marking. It is not a universal mark required for every product sold in the European Union. It applies to categories covered by the relevant harmonisation legislation, such as toys, machinery, personal protective equipment and certain electrical and electronic equipment. Depending on the product, the business may need an appropriate conformity assessment, technical documentation and an EU declaration of conformity. Products for which CE marking is not required are still subject to the relevant safety rules and information requirements. Language requirements also need to be considered for instructions, warnings, labels and other information provided to users. Entering another market therefore involves more than translating the product listing. The product itself, its documentation, packaging and the information available to the customer before purchase also need to be reviewed.

How do you get started with PAN-EU step by step?

The safest way to implement PAN-EU is not to expand the entire catalogue across the maximum number of countries at once, but to run a controlled pilot using a small number of well-understood products that meet the programme’s current requirements. The business should first select ASINs with stable sales, calculate the economics of the current model and the PAN-EU scenario, choose inventory placement countries, prepare the required VAT registrations and make sure the products meet the relevant listing and regulatory requirements. Only then should the programme be activated and actual costs monitored. This approach reduces the risk of a situation in which fulfilment savings look attractive in the initial calculation but are later reduced by additional administration, storage costs or compliance issues.

Step 1. Select a few ASINs for the pilot

There is no need to enrol the entire catalogue in PAN-EU at the outset. A much better approach is to select a small number of eligible ASINs for which the business already has enough data to assess sales, margins and inventory turnover. The strongest candidates are usually products that are regularly ordered in several countries, have predictable demand and generate sufficient unit economics to absorb additional operating costs. They do not need to be only the smallest or lightest products. What matters much more is the size of the gap between the current cost of cross-border fulfilment and the PAN-EU scenario, and whether the product generates enough volume for that difference to materially affect profitability. Each selected ASIN must also meet the programme’s current eligibility and enrolment criteria.

A pilot involving only a few products has an important advantage: it allows the business to test the entire process without exposing hundreds of SKUs to the same risk at once. The company can see how inventory flows, charged fees, reporting and VAT data reconciliation work in practice. If the model performs as expected, the scope can gradually be expanded to additional products. If problems appear with margins, listings, documentation or reporting, they can be addressed at a relatively small scale. PAN-EU does not therefore need to be an “all or nothing” decision. It is more sensible to treat it as a model that should first be validated using products with the greatest potential and the appropriate programme status.

Step 2. Calculate profitability for each product and market

For each pilot ASIN, the current cost of fulfilment should be compared with the expected cost after PAN-EU is enabled. The starting point should be actual data: the number of orders going to individual countries, current fulfilment fees, storage costs, average margin and returns. The next step is to calculate how profitability would change if some orders were fulfilled from inventory located closer to the customer. The analysis should not be limited to the difference in FBA fees. The appropriate share of additional VAT compliance, reporting and other process costs that genuinely arise under the new model should also be allocated to the calculation. Costs that already exist under the current setup should not be counted again simply because the business is considering PAN-EU.

A good practice is to prepare several scenarios: conservative, base case and continued-growth. This makes it possible to see what happens to profitability if volume is lower than expected or, conversely, rises quickly. Separating fixed and variable costs is particularly important. The cost of supporting a local VAT registration may remain broadly similar whether the business sells 500 or 2,000 units per month, while fulfilment savings increase with the number of orders. Only this type of comparison shows at what scale PAN-EU begins to finance its additional complexity and which products genuinely belong in the programme.

Step 3. Choose storage countries

The choice of inventory placement countries should be based on sales data rather than on the assumption that enabling more countries will always produce greater benefits. Under the rules applicable in 2026, PAN-EU inventory placement can include Germany, France, Italy, Spain and Poland. To use inventory redistribution under PAN-EU, storage must be enabled in at least two eligible countries. The first step should therefore be to identify where the business generates the highest volume of repeat orders and where cross-border fulfilment is currently most expensive. The potential savings should then be compared with the additional tax and administrative obligations created by choosing a particular country.

It is important to continue distinguishing between three separate concepts: marketplace, inventory placement and VAT registration. A business may maintain an active offer on a particular marketplace without storing its own inventory there. Enabling inventory placement, on the other hand, gives Amazon permission to place the seller’s goods in that country. The seller does not choose the specific fulfilment centre or the number of units that should be sent to a particular warehouse. The decision to enable another country should therefore be based on margins, sales scale, differences in fulfilment costs and VAT consequences, rather than solely on the attractiveness of the local marketplace.

Step 4. Organise VAT registrations

Under the current rules for standard PAN-EU, the required local VAT registration and VAT number should be prepared before inventory placement is enabled in a particular country, and the number should then be configured correctly within the FBA settings. This stage should not be treated as a formality to be completed only after the programme has already started. Once inventory begins moving into an enabled country, the business needs to be ready to report those transfers and subsequent transactions correctly. Obtaining the VAT number is only part of the preparation. The company also needs to establish filing frequency, data sources, the treatment of movements of its own goods, and responsibility for preparing and reviewing the returns.

Planning the data-reconciliation process is particularly important at this stage. The business should know where information about inventory transfers will come from, who will compare those data with sales, and how the information will be passed into the VAT reporting process. In 2026, standard Union OSS does not replace local obligations arising from storing and moving the company’s own goods, so the tax structure needs to reflect the selected inventory placement countries. Only once registrations and reporting processes have been prepared should the business proceed to actual inventory storage.

Step 5. Prepare listings and product compliance

Under the rules applicable in September 2026, businesses need to verify not only product status but also the required PAN-EU listings. From 3 September 2026, new and existing PAN-EU products must also have an active offer in the Netherlands, subject to exceptions provided by Amazon for specific situations, such as products restricted in a particular market, products that do not meet certain local labelling or packaging requirements, or products for which an appropriate local product detail page does not yet exist. From 26 February 2027, a similar requirement is expected to apply to Belgium. This does not mean that inventory must be stored in the Netherlands or Belgium. These markets should therefore be treated as part of the listing requirements rather than automatically as additional inventory placement countries.

At the same time, each selected product needs to be checked to ensure that it can legally be sold in the relevant markets. Businesses should review content localisation, pricing, safety documentation, markings, instructions, distance-selling requirements and any applicable EPR obligations. It should not be assumed that all of these obligations arise only because PAN-EU is being introduced. Some may already apply to a business selling through EFN. The important question is therefore what changes compared with the current model. The mere existence of an ASIN on a marketplace does not confirm that the product satisfies all regulatory requirements applicable in that market.

Step 6. Activate PAN-EU for selected products

Once the economics, VAT setup, listings and compliance requirements have been prepared, the programme can be activated for selected products that meet PAN-EU eligibility criteria. Activation does not, however, mean that the business should immediately increase the amount of inventory sent into FBA significantly. During the pilot, stock levels should be based on actual demand, replenishment lead times and an appropriate safety buffer. This helps reduce the risk that an overly optimistic sales forecast will lead to excess inventory and additional storage costs.

Once inventory enters the network, Amazon can redistribute units between eligible enabled countries based on forecast demand. The seller does not manually specify that a particular number of units should be held in a particular fulfilment centre. During the first phase, the objective should be to collect data that allow the original assumptions to be compared with the programme’s actual performance. The business should check which countries orders are fulfilled from, how inventory levels change and whether the real cost structure matches the earlier calculation. Only once the economics have been confirmed should the number of products or inventory levels be increased.

Step 7. Monitor the first operating period

The first weeks and months should be treated as a period of active monitoring rather than the point at which the PAN-EU project can be considered complete. The business needs to track where inventory is actually located, which countries it moves between and from which locations orders are fulfilled. Fulfilment and storage fees should be monitored in parallel, because only actual data will show whether the savings match the original model. It is worth comparing margins for the same ASINs before and after activation rather than looking only at total revenue. Higher sales do not necessarily mean higher profitability if inventory costs, fees or administration increase at the same time.

The enrolment status of individual ASINs in Pan-European FBA Inventory should also be checked regularly. Problems with required listings, offer availability or product eligibility can affect access to PAN-EU benefits, so businesses should not assume that once a product is enrolled it will remain eligible indefinitely. Monitoring should also cover tax and compliance. If inventory begins appearing in another enabled country, the business needs to be confident that the event enters the correct reporting process. PAN-EU should be treated as a dynamic operating model whose performance depends on sales, product status, inventory levels and the structure of the markets involved.

Step 8. Reconcile sales, inventory and VAT every month

PAN-EU is not a “set it and forget it” configuration. At least once a month, the business should reconcile three areas: sales, the physical movement of inventory and tax reporting. It should confirm that sales reports match the accounting records, identify movements of the company’s own goods between countries, and verify that those transfers have been reflected correctly in the relevant returns. Inventory levels and turnover should also be monitored to identify products for which storage is becoming too expensive. A monthly process of this kind makes it possible to identify problems early, before an error repeated across several reporting periods begins to require corrections in multiple countries.

The original profitability calculation should also be revisited regularly. If sales increase, the fixed cost of VAT compliance may become less significant on a per-order basis. If volume falls, the opposite may happen. The business should therefore periodically check which ASINs still justify PAN-EU and which have fallen below the required level of sales or margin. This kind of regular control is what distinguishes a deliberately managed operating model from a logistics configuration that remains unchanged simply because it was activated at some point in the past.

The most common mistakes when implementing PAN-EU

PAN-EU usually causes problems not because the mechanism itself is exceptionally difficult, but because businesses implement it too broadly or base the decision on an oversimplified calculation. A common mistake is to enable the programme immediately for a large part of the catalogue, even though only a handful of products have proven sales across several countries. Low-turnover SKUs then make it harder to assess the economics and increase the risk of overstocking. A similar problem arises when additional inventory placement countries are enabled without first calculating how many orders each market generates and whether the potential savings exceed the cost of local VAT compliance. The more elements a business changes at the same time, the harder it becomes to determine what actually improved performance and what made it worse.

Mistakes in profitability calculations

The most common financial mistake is looking only at the lower fulfilment fee. If a business sees a clear difference on a single shipment, it is easy to multiply that amount by the number of orders and treat the result as future profit. In reality, additional VAT compliance, reporting, storage and inventory-financing costs also need to be included. The opposite mistake is possible too: assigning PAN-EU costs that the business was already incurring, such as certain EPR expenses or listing-localisation costs. A correct calculation should compare two scenarios and include only the cost difference between them.

Forecasts should also not be built around the programme’s maximum advertised savings. Amazon communicates the possibility of achieving fulfilment savings of up to 53% in certain PAN-EU versus EFN comparisons, but this figure represents the maximum potential saving in specific product, size and weight configurations. It is not an average or a guaranteed outcome for every seller. For a particular ASIN, the difference may be significantly lower, so the only sensible basis for the decision is the company’s own calculation using current fees and the real structure of its orders.

Mistake: using an outdated fee schedule

FBA fees change over time, so a model prepared several months before PAN-EU is launched may no longer reflect the real costs on the activation date. Before starting a pilot, it is worth recalculating the selected ASINs using current rates and then updating the model regularly whenever fees change. From 17 April 2026, Amazon also applies a 1.5% fuel and logistics surcharge to FBA fees on the European marketplaces covered by the change, including Germany, France, Italy, Spain and Poland. If the calculation was prepared using earlier rates, it may overstate the expected margin.

This mistake is particularly easy to miss in companies that prepare an expansion project several months before the actual launch. During that time, not only the fulfilment fee schedule but also the sales mix and the share of individual ASINs in cross-border orders can change. The final recalculation should therefore take place as close as possible to programme activation and use current fees for the specific product weight, dimensions and sales destination.

VAT and compliance mistakes

A second group of errors arises from treating PAN-EU primarily as a logistics change. One particularly risky assumption is that using OSS replaces local obligations linked to storing the company’s own inventory. Under the rules applicable in 2026, it does not. If a business enables an inventory placement country, it first needs to understand the VAT consequences of that decision and put an appropriate reporting process in place. It is equally risky to activate a product without checking required listings, documentation, markings, safety requirements or environmental obligations. The mere fact that an ASIN exists on a marketplace does not confirm that the product fully complies with the requirements applicable in that market.

Treating EPR as an obligation created exclusively by PAN-EU is another common mistake. A business may already be subject to environmental requirements simply because it places certain goods or packaging on a particular market. For this reason, the pre-implementation analysis should separate existing obligations from those that arise under the new model. This makes it possible both to prepare compliance correctly and to avoid overstating the cost of PAN-EU by assigning it expenses that would also exist under EFN.

Mistakes after the programme goes live

The biggest mistake after launch is failing to monitor where inventory is actually located and what events occurred during a given month. Amazon can redistribute stock between enabled countries, so the seller should not assume that goods will remain where they were originally sent. If inventory and transfer reports are not reconciled regularly, the business may miss events that matter for VAT or fail to notice that a particular product is generating higher storage costs than expected. It is just as easy to overlook a change in the enrolment status of a particular ASIN or a problem with a required listing that affects access to programme benefits.

Failing to reconcile data monthly is one of the most expensive mistakes precisely because its consequences often become visible only after several reporting periods. PAN-EU should be reviewed regularly in terms of sales, margins, inventory, transfers, product status and VAT reporting. If an ASIN loses velocity or a particular market no longer generates sufficient volume, the assumptions made on the launch date may no longer be valid. The objective is not to keep PAN-EU running at all costs, but to use it where it genuinely improves the economics of sales and where the business can maintain control over both performance and the obligations created by the chosen configuration.

PAN-EU or EFN — which model fits each stage of growth?

EFN and PAN-EU solve a similar problem, but they do so in different ways. EFN allows businesses to sell across several European markets without automatically placing inventory in the customer’s country. Goods remain in the country or countries where the business has FBA storage enabled, while international orders can be fulfilled cross-border. This makes the model relatively simpler operationally and can work well when the company is still testing demand in new markets or when volume is not yet high enough to justify the additional obligations associated with PAN-EU. PAN-EU becomes more interesting when sales across several countries are already consistent, the share of cross-border shipments is high, and the difference between local and cross-border fulfilment fees is beginning to have a noticeable impact on margins. This does not mean that one model is inherently better than the other. In practice, they simply suit different stages of international growth.

In practice, many businesses should not treat the decision as a permanent “EFN or PAN-EU” choice for the entire operation. A product- and market-level approach is more useful. Some ASINs may remain under the simpler model because they sell too infrequently or have insufficient margin, while the fastest-moving products may justify PAN-EU. Two levels of decision-making also need to be separated. Eligibility and enrolment apply to specific products, while inventory placement is configured at country level. A product can therefore participate in PAN-EU only when it meets the offer requirements and the business has the appropriate storage configuration enabled in at least two eligible countries.

The same principle applies to markets. Strong sales in the Netherlands do not mean that the company should store inventory there under PAN-EU, because the Netherlands is not currently an inventory placement country within the programme. What is more, access to local fulfilment rates does not always require physical storage in the customer’s country. Under the current programme configuration, appropriate inventory placement in Germany may allow sellers to benefit from domestic fulfilment rates for orders in the Netherlands and Sweden, while Belgium may be supported through placement in Germany or France. This illustrates why the decision should not be reduced to the simple logic of “we sell a lot in country X, so we need to store inventory in country X”. The current programme rules should be checked first, and only then should the business calculate which configuration produces the best economic result.

For a business only beginning its European expansion, EFN can therefore serve as a model for gathering demand data. It allows the company to see which markets generate sales, how individual products perform and where volume remains stable over several consecutive months. Once those data are available, the economics can be recalculated and the business can decide whether PAN-EU is the next rational step for selected ASINs. Conversely, a company that has been fulfilling high cross-border volumes for a long time should not remain with EFN solely because the existing model is organisationally convenient. At larger scale, simplicity also has a price, and it is worth checking regularly whether that price has become higher than the cost of a more advanced model.

Checklist before launching PAN-EU

Before activating PAN-EU, it is worth going through a review that covers not only logistics settings, but also profitability, VAT, listing requirements, compliance and ongoing programme monitoring. If the answer to several of the points below is still “I don’t know”, it is better to fill those gaps first than to enable inventory storage and only later try to understand the consequences. The most important thing is that, before launch, the business knows why it is choosing PAN-EU, which products it wants to include and how it will measure the actual result afterwards.

• I have selected specific eligible ASINs for the pilot and am not enabling the programme automatically for the entire catalogue.
• I know the actual sales performance of the selected products in individual markets and can identify where demand is repeatable.
• I have compared current EFN costs with expected PAN-EU costs for specific products and sales destinations.
• I have calculated margin after including additional VAT compliance, storage and other costs that will genuinely change after implementation.
• I have checked the calculation against the current FBA fee schedule and recalculated the selected ASINs immediately before launch, taking into account applicable surcharges and current rates.
• I have selected at least two inventory placement countries from those currently available for PAN-EU — Germany, France, Italy, Spain and Poland — and prepared the VAT numbers required for that configuration.
• I understand that a marketplace, an inventory placement country and a local VAT registration are not the same thing, and I do not automatically assume that selling in a particular country means inventory must be stored there.
• I have prepared the required local VAT registrations and VAT numbers for the countries selected for inventory placement, and I know how movements of my own goods and other VAT events will be reported.
• I have checked that each selected ASIN meets the current PAN-EU eligibility and enrolment criteria.
• I have active offers under the same SKU on the required PAN-EU marketplaces: Germany, France, Italy, Spain and the Netherlands, or I have confirmed that an Amazon exception applies in the specific case.
• I know that from 26 February 2027 Amazon plans to require an active offer in Belgium for enrolment as well, subject to the exceptions provided for specific situations.
• I understand that a mandatory listing in the Netherlands, and in future also Belgium, does not mean that inventory must be stored in those countries.
• I have reviewed product documentation, safety, markings, instructions and distance-selling requirements.
• I have checked the relevant EPR obligations and know which already apply to the business independently of PAN-EU and which may arise from the new sales configuration.
• I have set the pilot inventory level based on actual demand, replenishment lead times and an appropriate safety buffer.
• I have a process for monitoring inventory movements and can determine where stock is physically located and between which countries it has been transferred.
• I have a process for regularly checking the enrolment status of individual ASINs.
• I have a monthly reconciliation process for sales, inventory, movements of my own goods and the data used for VAT reporting.
• I have set a date for recalculating profitability after the first few months of operation so that actual fees and margins can be compared with the assumptions made before launch.

A good checklist is not meant to guarantee that PAN-EU will prove profitable or that every selected product will be formally accepted by Amazon. Its purpose is to make sure the business is operationally prepared, understands what to expect and knows how to measure the outcome. If the products have proven demand, the fulfilment cost difference is meaningful, the required VAT registrations are ready, and the team can regularly reconcile inventory movements and sales, the business has a solid operational basis for running a controlled pilot, provided the selected ASINs also meet Amazon’s current eligibility criteria. If, on the other hand, data are missing, compliance is disorganised and no one is responsible for monthly reconciliation, the biggest risk will not be PAN-EU itself, but launching it without a process for determining whether it is actually improving performance.

Summary — when is PAN-EU a good next step?

PAN-EU begins to make sense when European expansion stops being a test and becomes a repeatable sales channel. The business already has proven demand in several markets, understands the structure of its cross-border orders and can identify products for which the difference between current EFN costs and local fulfilment rates is large enough to matter. A lower fulfilment fee alone is not sufficient grounds for the decision. Potential savings need to be compared with additional VAT compliance, reporting, storage and the cost of operating a more complex model. If, after all relevant incremental costs are included, the calculation still shows a sustainable advantage over the current setup, PAN-EU can become a genuine tool for improving sales economics. It is also worth remembering that the decision does not need to apply to the entire catalogue. A safer approach is to begin with selected ASINs that have good turnover, stable demand and sufficient margin.

Operational readiness is just as important as the economics. Under the rules applicable in 2026, the business needs to be prepared for local VAT obligations in the countries selected for inventory placement, correct reporting of movements of its own stock, and ongoing reconciliation of sales and inventory data. It also needs to monitor listing and product requirements, because an active marketplace, a storage country and a local VAT registration are three separate elements of the model. PAN-EU is therefore a good next step not simply when a business wants to “sell more in Europe”, but when it has the data to calculate the impact, the processes to control it, and a team or partner capable of managing the tax side of the expansion.

Before enabling PAN-EU, calculate the cost of VAT compliance in each storage country

One of the most frequently overlooked elements of the calculation is the actual cost of VAT compliance in the inventory placement countries. This does not mean assuming that every additional enabled country always requires a completely new registration and creates the same additional cost. An EU-based business may already be registered for VAT in one of the countries it intends to use for inventory placement, so enabling storage there may not create the same incremental cost as entering a completely new jurisdiction. The calculation should therefore be based on incremental cost: additional registrations, new returns, reporting movements of the company’s own goods, reconciling tax data with inventory reports and any other obligations that arise only because of the chosen PAN-EU configuration.

In practice, adding another inventory placement country may produce attractive logistics savings but still fail, at the current sales volume, to cover the additional tax-compliance cost. On the other hand, as sales grow quickly, fixed compliance costs may represent an increasingly small share of margin per order. Each storage country should therefore be assessed separately and compared with the company’s current model. amavat can help translate the logistics plan into a concrete map of VAT obligations, required registrations, returns and ongoing compliance costs. This kind of analysis allows the business to assess in advance whether the chosen storage-country configuration makes economic sense and what processes need to be prepared to reduce the risk that fulfilment savings are significantly eroded by unexpected administrative costs.

FAQ: PAN-EU Amazon

Is PAN-EU Amazon profitable?

PAN-EU can be profitable if a business has regular sales in several countries, currently fulfils a large share of orders cross-border and can materially reduce fulfilment costs through the right configuration. There is, however, no single answer that applies to every seller. The result depends on the specific ASINs, their weight and dimensions, sales destinations, margins, inventory turnover and VAT compliance costs. The best way to assess it is to compare two scenarios: the current model and PAN-EU, and then include only those costs and savings that will genuinely change after implementation. If, after incremental costs are taken into account, the calculation still shows a sustainable advantage over the current setup, PAN-EU may be a justified next step.

At what sales level is it worth moving to PAN-EU?

There is no official or universal order-volume threshold at which PAN-EU becomes profitable. For one product, a few hundred orders may already create a sufficient cost difference, while for another, even several thousand may not justify the additional obligations. The share of orders fulfilled cross-border is particularly important, because this is where the potential difference between EFN and local fulfilment rates can be most visible. In practice, the signal to perform a detailed calculation comes when sales in several countries become repeatable and the monthly cost of cross-border fulfilment is no longer a marginal expense. At that point, it is better to calculate the break-even level using the company’s own data than to rely on an arbitrary order threshold.

Does PAN-EU require VAT registration in several countries?

Under the rules applicable in 2026, the standard PAN-EU model generally requires local VAT numbers in the countries selected for inventory placement, because the seller’s own goods may be stored there and moved within the fulfilment network. This does not mean that the number of VAT registrations must match the number of marketplaces on which the business has active offers. A listing in a country and physical storage of inventory are two different events. PAN-EU inventory placement can currently include Germany, France, Italy, Spain and Poland, and the business must enable at least two eligible countries. Under the current rules, the scope of required registrations should therefore be determined primarily by the actual storage configuration and physical movement of goods, while taking into account any registrations the business already holds before entering the programme.

Is OSS enough for PAN-EU?

No. Under the rules applicable in 2026, standard Union OSS does not replace local VAT obligations arising from storing and transferring the company’s own inventory. OSS is primarily used to simplify the reporting of certain cross-border B2C sales, for example when goods stored in Germany are shipped to a consumer in France and the transaction qualifies as an intra-Community distance sale of goods. A transfer of the company’s own goods between France and Germany, however, is not an ordinary consumer sale reported through OSS. Similarly, a sale from a German warehouse to a German consumer is generally a domestic German sale. In practice, a business using PAN-EU may therefore use OSS while also filing local VAT returns in the countries connected with inventory storage.

How many storage countries need to be enabled?

Under the rules applicable in 2026, PAN-EU requires inventory placement to be enabled in at least two eligible countries. The currently available storage countries are Germany, France, Italy, Spain and Poland. This does not mean that enabling all five immediately is the best option. Each additional inventory placement country can increase logistics flexibility, but depending on the company’s starting position it may also create additional tax and administrative obligations. An EU-based business may already be VAT-registered in one of those countries, so the key is to calculate the actual incremental costs rather than mechanically assuming one entirely new VAT-registration cost for every enabled country. The configuration should be built around sales data, the share of cross-border orders, fulfilment costs and VAT compliance costs.

What is the difference between PAN-EU and EFN?

The main difference is how inventory is used. Under EFN, goods remain in the country or countries where the business has FBA storage enabled, while orders from customers in other markets can be fulfilled cross-border. Under PAN-EU, the seller enables eligible inventory placement countries and Amazon can then redistribute inventory between them based on expected demand. With the appropriate configuration, this can allow local fulfilment rates to apply to a larger share of orders under the programme’s current rules. It should not be assumed, however, that inventory must always be physically stored in the customer’s country in order for a particular configuration to qualify for the relevant local rate. The economics should therefore be checked for the specific market and the programme rules in force at the time.

Can you start PAN-EU with only a few products?

Yes. PAN-EU does not have to be launched for the entire catalogue at once. Eligibility and enrolment apply to qualifying products, so a business can begin with a small number of ASINs that have the strongest economics and proven demand. This is particularly sensible at the beginning because it allows the company to test real fulfilment costs, inventory movements, margin impact and VAT processes without exposing hundreds of SKUs to the change. The selected products must, however, meet Amazon’s current criteria, including requirements for active offers on the relevant marketplaces, and the business must have the appropriate inventory placement configuration. A pilot should therefore include not only products that sell well, but also products that formally qualify for the programme.

On which marketplaces do you need active offers for PAN-EU?

Under the rules applicable in September 2026, PAN-EU products should have the required active offers under the same SKU in Germany, France, Italy, Spain and the Netherlands. The Netherlands was added to this requirement for new and existing PAN-EU products from 3 September 2026. Amazon provides exceptions for certain situations, for example where the sale of a product is restricted in the local market, certain local labelling or packaging requirements are not met, or no appropriate local product detail page exists yet. From 26 February 2027, Amazon also plans to require an active offer in Belgium for enrolment, again subject to specified exceptions.

Required marketplaces should not, however, be confused with storage countries. The Netherlands and Belgium are not currently PAN-EU inventory placement countries, while Poland, Sweden and Ireland may play a different role in the sales configuration. This distinction is worth remembering as one of the most important principles of the model: a required listing does not mean inventory placement, and inventory placement is not the same thing as simply selling into a country. Only when these elements are combined with the actual physical location of inventory can the logistics and VAT consequences be determined correctly.

How do you calculate the cost of PAN-EU before implementation?

The best place to start is with the cost of the current model and compare it with the expected PAN-EU scenario for specific ASINs. The basic framework is the difference between fulfilment costs before and after the change, multiplied by the number of orders, plus any additional sales margin and minus additional fixed and variable costs. Incremental costs may include, among other things, managing new local VAT registrations, filing returns, reporting inventory transfers, storage and other processes that genuinely change after implementation. Costs the business already incurs independently of PAN-EU should not be counted again, such as existing VAT compliance in a country where it is already registered or product obligations that apply in a market under EFN as well.

It is worth preparing the calculation for several volume scenarios and running it again immediately before programme activation using the current FBA fee schedule. This helps prevent the business from making a decision based on historical rates or maximum savings figures communicated for selected configurations. The final answer to whether PAN-EU is profitable should come from the company’s own data: actual volume, current fees, incremental costs and the margin generated by the specific products involved.