With the old EFN (UK to Europe) FBA returns would get sent to EU fulfilment centres. Does this happen with the new EFN? Does that have VAT implications?
from the EFN handbook
Where are the items going to be returned?
The items will be sent to the source store.
You generally aren’t required to register for VAT in the
destination store when fulfilling between the UK and the EU.
For business-to-consumer sales that do not exceed
€150/£135, Amazon must account for VAT, which the
customer pays at checkout. For such sales above €150/£135,
and all business-to-business sales, the customer is the
importer of record and pays any import VAT and duties.
Amazon will collect an estimate of these import fees from
the customer at checkout to remit these amounts on the
To learn more, go to our EU VAT on eCommerce legislation
page or UK VAT on eCommerce legislation page.
Note: VAT information is provided for general reference only
and is not tax advice. Consult your tax adviser for further
Thanks. Is this what happens in practice?
I believe that with the old EFN items were usually returned to and stored at European fulfilment centres and sometimes even re-sold from European fulfilment centres without seller consent.
We were told that EFN European returns would be returned to the UK, so that we would have no stock stored in the EU (therefore not needing EU VAT registration in those countries.
Guess what? Under the new EFN, returns are being stored in the EU country they are returned to, despite Amazon’s promise otherwise. We have a case open with Seller Support, but with no useful answer as yet.
Thanks Thingimijigs. I imagined that might be the case.
Strange timing (coincidence?) but we had confirmation from Amazon yesterday that they cannot and will not guarantee that EFN returns will be returned to the UK.
We had turned off Pan-EU FBA post-Brexit, after trying to send stock to Germany/Poland. It just didn’t work with our seasonal stock. Given that we returned/disposed of all our EU-held stock, and having nothing in storage, we decided to de-register for VAT in all those countries.
So when Amazon promised Pan-EU would offer returns to the UK, we thought this was a great way to fulfil orders to the EU without requiring re-registration for VAT, so we enrolled. We enrolled, but pretty soon it because clear that returns were now being stored in the EU, putting us at risk of prosecution (given lack of VAT registration). We’ve had cases open with Amazon, each time they have destroyed all the stock and re-imbursed us.
This last time however they have told us they won’t guarantee returns won’t go into EU stock, and that we should turn off Pan-EU to avoid prosecution.
Not sure if this is a typo - pan eu instead of efn, but double check pan eu isn’t still activated on your account
If it is, it maybe why they are storing your stock in EU instead of returning it to uk
I frequently find that my EFN returns end up in Europe and are then resold. Luckily I am still registered for VAT in these countries.
Are your fba settings still showing pan eu enabled with those countries ticked to allow storage ?
Yes they are. I still have some residual Pan EU stock and I am about to start Pan EU again.
Amazon still should not be storing EFN returns in these depots as they promised they wouldn’t.
I believe if you have pan eu activated, with the boxes ticked to allow storage in certain countries, that overrides them being required to send the stock back to uk
If you are uk only with no eu vat, they should return stock to uk
Do you have experience of amazon actually returning EFN stock to the UK? And not storing any returns in EU fulfilment centres?
I wonder if storing returned goods, which are not for sale, makes one eligible for EU VAT? I wouldn’t imagine it does.
Yes it was a typo - as we had Pan Eu switched off - we have all the settings set to only store in UK, (as we then started de-registering EU VAT), we did set up the BIL for EFN -
All Settings have been checked several times, and each time Seller Support confirmed that customer returns would not be stored overseas again…
As we are now de-registered in some of the countries, we cannot take the risk of EFN returns going to EU FC’s - I have been chasing on this, and this is the reply they sent from Managing Director email, as we were not getting anywhere with the general seller support queries
Furthermore, in regards to the European Fulfillment Network between the UK and the EU, as we continue to improve both our platform and our service and input from our sellers is invaluable, I have forwarded your feedback on EFN Programme to the relevant departments. Although we are unable to follow up with any outcome or actions made by our teams, and we can’t guarantee at the moment that your units won’t be stored anymore outside of United Kingdom as a result of the customer returns, we do promise that your message has been reviewed at an executive level
it then goes on to say:
unfortunately, at the moment the only resolution to prevent storing your units in unauthorized countries, is to sell only on Amazon.co.uk and to set the Shipping programmes and export settings from Amazon.co.uk to "Disabled". So, only customers with postal addresses in the UK can order your FBA products and if this is a case, the customer returns will return to UK only:
So basically Amazon are saying they have set up the EFN programme, but that they have no confidence in where the returns will end up - which is at odds with the programme, and the purpose that retailers do not need VAT numbers on this programme…
The problem is when Amazon has processed the returns (in the country of return) they do put them back into stock instead of returning them to the Seller in the UK.
We had to turn off EFN yesterday to protect ourselves - there is no difference between storing a return that’s now on sale again and storing new stock.
This is really shocking. The implications for a Non Vat registered person are huge both in cost and time.
Amazon mistakenly sent some of my inventory to Germany, I still have a notification in my DE account stating I must register for VAT there. I’ve got nowhere with Amazon support