FAQ on Amazon UK's registration in the Fulfilment House Due Diligence Scheme (FHDDS)

What is the Fulfilment House Due Diligence Scheme (FHDDS)?

Amazon is approved by HM Revenue & Customs (HMRC) as meeting the licensing requirements of the FHDDS. FHDDS is a legal requirement in the UK that imposes registration, due diligence, and record keeping requirements on all operators of fulfilment businesses in the UK in respect of goods of a non-EU origin stored on behalf of non-EU sellers. Amazon UK Services Limited (Amazon UK), as the operator of Amazon’s UK fulfilment centres, is approved by HMRC as meeting the licensing requirements of the scheme. All Fulfilment by Amazon (FBA) services are compliant with FHDDS. Further information on the FHDDS, and the obligations it places upon Amazon, is available here and here.

Does Amazon UK's registration under FHDDS change anything for me as a seller?

As an approved fulfilment house operator, Amazon is required to maintain certain records relating to goods that are stored in Amazon UK fulfilment centres on behalf of non-EU established sellers, which have a non-EU origin (full list of EU countries here). If you are a non-EU seller sending inventory to Amazon’s UK fulfilment centres, Amazon is required to maintain a record of the following information from your seller account:

• Name and contact details,
• Validated UK VAT registration number (VRN), for more details click here,
• Inventory record, including quantity and description of any goods of non-EU origin stored in our fulfilment centres,
• Any Import Entry Numbers (IENs) provided by you for those goods shipped to Amazon’s UK fulfilment centres.

Amazon already records your contact details, VRN, and maintains inventory records for goods stored under FBA. From 1 April 2019, you will be able to upload Import Entry Numbers (IEN) for any shipments to Amazon’s UK fulfilment centres wherever you have an IEN number.

What is an Import Entry Number (IEN)?

Import entry numbers (IENs) are allocated by EU Customs authorities when goods are imported into the EU. When your shipment enters the EU, and is declared to the Customs Authority, the shipment will be allocated an IEN. The IEN is issued to the customs declarant, which may be your logistics agent or freight forwarder. If you are using a freight forwarder, they may be able to communicate the IEN to you. There may be cases in which shipments are not allocated IENs, or you may not have access to them. Please check with your logistics provider/carrier or the Customs Authority at the time of importation.

Further information on importing to the UK from outside the EU is available from HMRC here.

What if I cannot obtain my Import Entry Numbers (IEN) for some, or all, of my shipments?

There are a number of scenarios where you may not have an IEN for a shipment to an Amazon UK fulfilment centre. If you do not have IENs for a shipment, you do not need to enter one.

What will Amazon do with any Import Entry Numbers (IENs) provided?

Amazon will maintain a record of any IENs provided to us. The UK Tax Authorities may request that we share any IENs provided, and they have the ability to verify where IENs are missing or incorrect.

What is the difference between an Import Entry Numbers (IEN) and an EORI?

An Economic Operator Registration and Identification (EORI) number is needed to trade goods with countries in the EU. Sellers receive EORI numbers from HMRC and use them when making customs declarations. An EORI is different from an IEN, as the EORI is assigned on a business level and remains the same for each shipment. The IEN, however, is different for each shipment. You can find more information about EORI here.

What does an Import Entry Number (IEN) look like?

EU IENs do not follow a standard format of numbers and/or letters. IENs may be issued by different EU Customs Authorities and may vary dependent on the method of import. On customs documentation, IENs may be identified variously as "Import Number", "Entry Number", or "Customs Entry Numbers".

Where do I enter my Import Entry Numbers (IEN)?

Beginning 1 April 2019, you will be able to enter IENs for shipments already created that are not in closed, deleted, or cancelled status, and for shipments created on or after 1 April 2019. You do not need to provide details for shipments that have been closed, deleted, or cancelled, nor for shipments created before 1 April 2019. On your Shipping Queue page, you will see an IEN status next to each shipment subject to FHDDS, indicating whether the IEN entry is complete, incomplete, or closed for editing. You can click on the IEN status to open a box where you can either enter IENs corresponding to the shipment or indicate that you do not have IENs for the shipment. Once you save your IEN entry, the IEN status will indicate "complete".

How much time do I have to enter my Import Entry Numbers (IEN)?

You have 240 days after creating a shipment to go to your Shipping Queue and add any relevant IENs that you might have received for that shipment. After 240 days from when the shipment is created, the IEN status will indicate closed for editing. At this time, you will still be able to view your IEN entry, but you will no longer be able to make edits.

What happens if I want to edit an incorrect Import Entry Numbers (IEN) entry or add a missing IEN after 240-day editing window has closed?

After 240 days, the IEN entry is locked for editing, and Amazon will maintain a record of the IEN as provided to us. The UK Tax Authorities may request that we share any IENs provided, and they have the ability to verify where IENs are missing or incorrect.

If I have multiple Import Entry Numbers (IENs) corresponding to a shipment, what format should I follow to enter these?

You can enter multiple IENs per shipment into the IEN entry field separated by comma, space, or one IEN per line.

Example 1:

ABC123, BCD345 (separated by a comma)

Example2:

ABC123 BCD345 (separated by a space)

Example3:

ABC123

BCD345 (separated by a new line)

Can I edit IENs that I previously provided?

Yes, you can edit a saved IEN entry within 240 days of shipment creation. After 240 days, the IEN entry is locked for editing.

Can I upload IENs in bulk?

It is not possible at this time to upload IENs in bulk.

I am a UK-based or EU-based seller. Does this affect me?

Amazon is only required to maintain records in respect of non-EU sellers. That means that the regulation only affects sellers that do not have a registered business established in either the UK or an EU country (full list of EU countries here). If you have an established business in the EU, you are not affected by this requirement.

I am an MFN-only seller. Does this affect me?

The FHDDS applies specifically to fulfilment houses in the UK, in respect of goods of a non-EU origin stored on behalf of non-EU sellers. Therefore, if you are not using Fulfilment by Amazon services, these changes do not impact you.

What about goods that I am storing in a non-Amazon UK warehouse?

All UK fulfilment businesses are required to be approved by HMRC as meeting the licence requirements of FHDDS. After 1 April 2019, if you are storing goods outside of FBA in a non-approved fulfilment house, then your goods may be seized by HMRC. For goods that are stored in non-Amazon warehouses in the UK, please contact your warehouse operators directly to confirm that they have registered under the FHDSS.

What if my goods were shipped into the UK from within the EU?

Amazon is required to maintain records of any import entry numbers for non-EU goods that were imported to the UK from a non-EU country. Where goods have been imported into, or purchased in, an EU country, then these goods are not within the scope of FHDDS. If you wish to inform us that a shipment is not relevant to FHDDS, then you should confirm this in your Shipping Queue page (refer to “Where do I enter my Import Entry Numbers (IEN)?”above). Further information on importing to the UK from outside the EU is available from HMRC here.

My goods were moved to the UK by Amazon (for example, I am a Pan-European FBA seller). Does this affect me?

Amazon is required to maintain records of any goods imported into the UK from outside of the EU. If your goods were moved to the UK from an EU country by Amazon, including transhipped under Pan-European FBA of the European Fulfilment Network (EFN), then Amazon is not required to maintain records on these goods.

What obligations does FHDD place on Amazon as an approved fulfilment house operator?

Amazon is obligated to notify HMRC where it knows or has reasonable grounds to suspect that a seller has not complied with UK VAT and customs obligations related to imported goods. If Amazon has such reasonable grounds to suspect non-compliance and continues to do so after 60 days, Amazon will be obligated to cease the provision of fulfilment services in respect of your goods. A failure to comply with these obligations may result in Amazon being liable to a penalty of £3,000 for each failure, which may result in Amazon’s licence being revoked.