EFN and the the German Cert



I currently use EFN. My sales to Germany are under the threshold to be registered for VAT in Germany. I’m a little confused by customer returns to German warehouses. I remove this “returned stock” once a month (I get it returned to the UK). Would these “returns by customers” be seen as storing stock in Germany? And therefore I need the German Tax Certificate etc.


I think the answer would be Yes and Yes I’m afraid. For the month or so that the returns sat in Amazon’s German depot, were they available for sale?


No, they go into FC Transfer. But I never leave them for long.


Unfortunately, Amazon will require you to submit the German Tax Certificate if any of your FBA inventory is stored in Germany, including customer returns.


Hi NewBeginings,
We are in similar situation only using EFN. We have been notified that we need to obtain German Tax Certificate by 1st Oct19.
Not sure what would the circumstance be if we don’t obtain this certificate. We don’t mind loosing privilege selling in DE as we have very little sales there.
We are worried about

  • the stock held in DE warehouses
  • we will be suspended from selling in DE but not sure if it will affect our UK account
  • would we get any penalties from Germany tax authorities

what is your situation? have you applied and how? if you wish to share.



Hi rob2.

I’ve stopped selling in Germany. It wasn’t financially viable to apply for the German Certificate, and pay VAT on German sales (I’m currently on the Flat Rate scheme in the UK).

I didn’t want to take a risk with the German returns (especially as my busiest time is the next quarter).


Thanks for replying.
I’m thinking that too to stop selling in DE. I have already closed all the DE listings and deactivated EFN setting to DE.
Not sure if we get any penalties from Germany tax authorities for not registering as I was sent message from Amazon
“Removing your FBA inventory settings will not remove your historical VAT obligation and we will begin restricting your account abilities if you do not upload your VAT number(s) by the deadline. This may include loss of inbounding and selling privileges.”
Lets see…


I’ve not had that email. I’m not sure why they’ve sent you that.

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