Amazon FBA to the UK After Brexit — Who Is the Importer and How to Handle VAT (2026)
Why this is the first question that breaks FBA UK shipments
Over the last few years the EasyClearance Team has worked with dozens of Polish sellers who tried to ship their first pallet to an Amazon FBA UK warehouse — and got stopped at customs clearance. In 9 out of 10 cases, the root cause is the same: the seller assumed Amazon UK would take on customs responsibility for the shipment. They won't. Ever.
Amazon Seller Central UK has long stated clearly: "You are the importer of record for all shipments into Amazon fulfillment centers" (sellercentral.amazon.co.uk — Importing inventory into the UK). That means the seller is responsible for customs clearance, paying duty, accounting for import VAT, and all documentation. A courier or freight forwarder can perform the clearance on your behalf, but the IOR on the CDS declaration is always you. Without that understanding, every FBA UK plan falls apart.
This article is a post-Brexit operational guide: who is who in the chain (seller vs Amazon vs forwarder), how to register for UK VAT, when you need EORI GB and EORI XI, how the marketplace facilitator rule affects quarterly returns, and why PAN-EU FBA no longer works the way it used to. If you are looking for a broader introduction, the pillar piece Amazon FBA UK — duty, VAT, guide covers the context; this spoke goes deep on one question: who is the importer and how to handle VAT.
Who's who in the FBA UK supply chain
Before we move on to VAT registration, it helps to define the roles. After Brexit, the PL → UK FBA supply chain involves at least four parties:
| Role | Who it is | Responsibility |
|---|---|---|
| Exporter (PL) | The seller or their Polish customs agent | Export declaration in AES, IE599, 0% PL VAT rate |
| Importer of Record (UK) | The seller (you) | CDS declaration, duty, import VAT (PVA), HMRC compliance |
| Customs broker (UK) | Customs agent (e.g. EasyClearance) | Files clearance on the basis of your EORI GB — not the IOR |
| Freight forwarder | DPD / DHL / UPS / specialist FBA carrier | Transport, delivery to the FBA warehouse — not the IOR |
| Marketplace | Amazon UK | Warehousing (FBA), collecting 20% VAT on B2C sales, NOT the IOR |
The critical mistake is confusing the party that physically performs a task with the party responsible to HMRC. A freight forwarder can file the declaration on your behalf — but the party entered in the "importer" field (Data Element 3/15–3/18 in CDS) is you, identified by EORI GB. All duty, VAT and any penalties fall on you. More on this concept: Importer of Record UK — what it is.
UK VAT for non-established sellers — £0 threshold
This is the second big trap. Polish sellers often assume the UK has an £85k annual turnover registration threshold (the threshold that applies to UK-established taxable persons). For a non-established seller there is no threshold — the obligation to register arises from the first pound of UK turnover (gov.uk — VAT on goods sold from overseas).
"Non-established" means a business without a fixed establishment in the United Kingdom. A Polish limited company or sole trader with no UK branch = non-established, even if it has an FBA warehouse holding stock on British soil. An Amazon FBA warehouse does not create a fixed establishment (it is Amazon's warehouse, not yours) — but it does create stock in the UK, which automatically triggers a UK VAT requirement.
UK VAT registration — step by step
- Gather documents: KRS/CEIDG extract (translated), PL tax residency certificate, 12-month UK turnover forecast, product description, bank details (IBAN + SWIFT — a GBP account is preferable).
- VAT1 application or online registration: directly with HMRC via gov.uk/register-for-vat. A non-established seller registers as an "overseas business selling goods in the UK".
- Wait for the VAT number: 2–6 weeks, and up to 8 during peak periods (Q4). The number has the format
GB + 9 digits, e.g.GB123456789. - Activate MTD (Making Tax Digital): quarterly returns are filed exclusively through MTD-compatible software (gov.uk/making-tax-digital-for-vat). Xero, QuickBooks, Sage, FreeAgent — all supported.
Note: HMRC may ask for a security deposit from overseas businesses without a track record — typically 3–6 months of projected VAT. This doesn't happen to everyone, but it does occur.
EORI GB — when, why and how
EORI (Economic Operators Registration and Identification) is the number required for every customs operation. After Brexit, a Polish business needs two separate EORIs:
- EORI PL — for exports out of Poland (AES export declaration). Issued by the Polish tax administration.
- EORI GB — for goods entering the United Kingdom (CDS import declaration). Issued by HMRC.
If you also sell to Northern Ireland (e.g. a customer in Belfast, shipped from an FBA UK warehouse), you additionally need EORI XI. EORI GB is usually issued automatically after UK VAT — in the format GB + VAT number + 000. Process details: EORI number — how to obtain, when to use.
PVA — how to avoid tying up cash on import VAT
Postponed VAT Accounting (PVA) is a mechanism introduced in January 2021 after Brexit, allowing import VAT to be accounted for on the quarterly return rather than paid at the border (gov.uk — PVA guidance). For an FBA seller it's a must-have — without PVA you tie up 20% of each pallet's value for 3+ months before recovering VAT as input tax.
You activate PVA by instructing your customs agent, at the moment of filing the CDS declaration, to use "postponed accounting" instead of "immediate payment". On the VAT return, Box 1 shows the import VAT due, Box 4 shows the same VAT as input (recoverable). Net cash-flow effect: £0, full compliance. Details: Postponed VAT Accounting PVA UK.
Marketplace facilitator rule — what Amazon actually does
From 1 January 2021 the UK introduced the "overseas goods" rules (gov.uk — VAT and overseas goods), obliging marketplaces (Amazon, eBay, Etsy) to collect and remit 20% VAT on B2C sales for overseas sellers. This does not apply to every transaction equally:
- B2C under £135, goods outside the UK: Amazon charges 20% VAT at the point of sale; you report zero-rated on your return.
- B2C from UK FBA stock (stock in UK, non-established seller): Amazon collects 20% VAT and remits to HMRC; you report a "deemed supply" at 0% to Amazon + Amazon→buyer 20%.
- B2B (UK VAT-registered buyer): VAT responsibility sits with the seller, standard 20% VAT invoice.
Bottom line: you hold a UK VAT number mainly to account for import VAT (PVA) and handle B2B — B2C via Amazon is effectively on the marketplace's side. This does not remove the registration requirement; registration and reporting zero-rated sales is mandatory.
Why PAN-EU FBA no longer works the way it used to
Before Brexit, PAN-EU FBA meant: you ship goods to a single Amazon warehouse (e.g. DE) and Amazon distributes them across UK, FR, IT, ES, PL. After 1 January 2021 the UK was dropped from PAN-EU. Currently:
- PAN-EU covers: DE, FR, IT, ES, PL, CZ (plus NL recently).
- UK FBA = separate programme, separate VAT registration, separate Seller Central configuration.
- Movement of goods PL ↔ UK = full customs clearance (no single market).
The operational consequence: sellers typically run two stock streams — one in PAN-EU (EU), a second dedicated to the UK. Two forecasts, two shipment flows, two VAT returns.
What you need on day 1: checklist
The EasyClearance Team uses this checklist in every FBA UK seller onboarding:
- [ ] UK VAT number (format GB123456789) — active in MTD
- [ ] EORI GB (auto-issued after UK VAT) — verified via gov.uk/check-eori-number
- [ ] EORI PL — for exports out of Poland (tax office)
- [ ] EORI XI — only if Northern Ireland is in scope
- [ ] GBP account or Wise/Revolut Business with GBP invoicing
- [ ] MTD-compatible software (Xero / QuickBooks / FreeAgent)
- [ ] UK VAT entered in Amazon Seller Central → Tax Settings
- [ ] UK customs agent holding your EORI GB on file — ready for CDS
- [ ] HS codes for every SKU in the product catalogue
- [ ] PVA set as the default with your customs agent
- [ ] Export invoices from Poland issued at 0% VAT once IE599 is received
Most common mistakes Polish FBA UK sellers make
- "I'll wait for £85k turnover before registering" — for non-established there is no threshold. Register before the first FBA shipment. Delay = retroactive VAT + penalties.
- "The forwarder will handle the import" — the forwarder is not the IOR. Your EORI GB must be on the CDS declaration.
- "I don't need UK VAT because Amazon collects VAT for me" — marketplace facilitator does not remove the registration requirement. Without VAT you have no PVA and block 20% on import VAT.
- "I'll send the pallet and register afterwards" — the pallet won't enter, because the import declaration has no recipient EORI or VAT. Amazon rejects undelivered-through-customs shipments.
- "I'll do everything through a Polish customs agent" — a Polish agent handles the export side (AES / IE599). For the UK side you need a UK customs agent with CDS access.
- "EORI is one global number" — EORI PL ≠ EORI GB ≠ EORI XI. Three numbers, three administrations.
Real-world costs
A typical starting budget for the first FBA UK shipment (2026 figures, indicative):
| Item | Cost | Notes |
|---|---|---|
| UK VAT registration (DIY) | £0 | Self-serve on gov.uk |
| UK VAT registration (via adviser) | £200–500 | PL / UK VAT specialist |
| Quarterly VAT bookkeeping | £80–200 per quarter | Depends on volume |
| EORI GB | £0 | Auto after UK VAT |
| UK customs agent (import declaration) | £55–85 per declaration | EasyClearance — per-declaration model |
| Freight PL → FBA UK (pallet) | £150–400 | Depends on weight and carrier |
| Duty (if no TCA applies) | 0–12% of value | Depends on HS code |
| Import VAT (PVA) | £0 cash-flow | Accounted for on return |
EasyClearance model: per-declaration (from £55), no monthly retainer. Billing per pallet / per container, matched to actual shipment volume. For specific terms — WhatsApp or email.
Launching Amazon FBA UK and need a customs agent on the British side?
WhatsApp: +44 7404 091 503 · email: biuro@easyclearance.pl
The EasyClearance Team files CDS declarations with PVA within 24 h of receiving documents.
FAQ — 7 most common questions
Is Amazon the importer for goods sent to FBA UK?
No. Amazon UK does not take on the Importer of Record role for goods sent to FBA warehouses. The IOR is always the seller — even if the seller is not physically present in the UK. Amazon requires shipments to arrive DDP (delivered duty paid), with customs clearance already completed. A container or pallet arriving without clearance is returned at the sender's cost.
Do I need to register for UK VAT as a Polish FBA seller?
Yes — mandatory from the first sale. For non-established taxable persons (sellers without a fixed establishment in the UK) the registration threshold is £0 — unlike UK-established businesses, where the threshold is £85k. Registration before the first FBA shipment is required, because storing stock in the UK automatically creates a VAT obligation.
Who pays duty and import VAT on shipments to FBA UK?
The seller (IOR). Import VAT is accounted for via PVA (Postponed VAT Accounting) on the quarterly return — £0 cash outflow at entry. Duty is paid either upfront or through a deferment account (HMRC deferred-payment account). The customs agent / freight forwarder is not the IOR, even when acting as an indirect representative.
What is the marketplace facilitator rule and how does it affect my accounts?
Since 1 January 2021, Amazon UK as a marketplace collects and remits 20% VAT on B2C sales to UK customers for overseas sellers. This does not mean you don't need UK VAT — you need it to reclaim import VAT (PVA) and handle any B2B sales. On the quarterly return you report the sales at 0% (marketplace-collected) and input VAT on imports.
What happens if a shipment arrives without customs clearance?
Amazon rejects the shipment. The fulfilment centre will not accept goods without completed customs clearance. The pallet is returned to the sender (or sits at the port/terminal) at the seller's cost, plus demurrage and storage charges. Most common mistake: the forwarder suggested 'Amazon will accept as consignee' — Amazon never does.
Can I use PAN-EU FBA after Brexit?
Partially. PAN-EU FBA still works, but only within the EU (DE, FR, IT, ES, PL, CZ). The UK is no longer part of PAN-EU — it requires separate FBA UK configuration, separate UK VAT registration and separate shipment of goods (with customs clearance on entry to the UK). Sellers often run two stock streams: EU in PAN-EU + UK separately.
Do I need a Polish or British EORI number?
Both. EORI PL for exports out of Poland (AES export declaration, IE599 confirmation for 0% Polish VAT). EORI GB for goods entering the United Kingdom and filing the CDS import declaration. If you ship to Northern Ireland, you additionally need EORI XI.
Where to go next
- Full FBA UK pillar: Amazon FBA UK — duty, VAT, guide
- IOR in a nutshell: Importer of Record UK — what it is
- EORI GB: EORI number — how to obtain, when to use
- PVA vs DDA: Postponed VAT Accounting PVA UK