Marketplace imports to the UK (Amazon, eBay) — who is responsible for customs clearance

Thousands of European businesses sell their products on Amazon UK, eBay UK or Etsy UK — and a significant proportion have never stopped to ask: who is formally the importer when they ship goods to an FBA warehouse in Coventry, or send a parcel directly to a customer in Manchester? The answer is not obvious, and it has real financial and legal consequences. Amazon is not your importer — even when you use FBA (Fulfilment by Amazon). The platform takes on only certain obligations (for example, collecting VAT from customers), but customs clearance for your goods entering the UK is your own responsibility. This article explains in detail who is the Importer of Record under each marketplace selling model in the UK, what documents are required, how VAT and duty liability works, and what risks a seller without a UK EORI faces.

Who is the Importer of Record when selling via FBA to the UK

FBA (Fulfilment by Amazon) means you send your goods to an Amazon warehouse in the UK, and Amazon handles storage, picking, packing and dispatch to end customers. But Amazon is never the importer of your goods into the UK.

The Importer of Record (IoR) for FBA UK is always the seller — i.e. you, as the owner of the goods and the party shipping them into the UK.

Process element	Who is responsible
Customs clearance on import of goods into the UK	Seller (Importer of Record)
Storage and fulfilment	Amazon
Charging VAT to B2C customers	Amazon (deemed supplier)
Remitting UK VAT to HMRC	Amazon or seller (depends on the model)
Responsibility for correct HS code classification	Seller
Risk of HMRC audit	Seller

This means that when you ship a pallet of goods from Poland to an Amazon warehouse in the UK: 1. The goods must be cleared on import in the UK 2. Someone must lodge a customs declaration as the importer 3. That party must hold a UK EORI number — either you (once you have obtained a UK EORI), or a fiscal importer / customs agent acting on your behalf

Source: gov.uk — VAT and overseas goods sold to customers in Great Britain using an online marketplace

UK EORI — why it is essential for FBA sellers

A UK EORI (Economic Operator Registration and Identification) number is the mandatory identifier for submitting customs declarations in the UK. Without a UK EORI: - Your goods cannot be legally cleared on import into the UK - Your customs agent cannot lodge a declaration in your name (they must use their own EORI, which creates complications with indirect representation) - Amazon may refuse to accept goods into FBA without proof of customs clearance

How to obtain a UK EORI: UK EORI registration is available online via gov.uk. For businesses based outside the UK, an online application is required — processing typically takes 5–7 working days. Link your UK EORI to your UK VAT registration number.

Alternative if you do not have a UK EORI — a fiscal importer: If you do not wish to register for a UK EORI, you can use a fiscal importer (fiscal representative / customs importer). This is a UK-based entity that takes on the IoR role — clearing your goods in the UK as importer on your behalf. Typical cost: £50–150 per clearance, plus a fixed monthly fee.

Amazon as a "deemed supplier" — what this means for VAT

Amazon is a "deemed supplier" for UK VAT purposes only in specific circumstances:

Amazon is the deemed supplier (and accounts for VAT): - B2C sales below £135 by sellers based outside the UK - Amazon charges UK VAT to the customer and remits it to HMRC - The seller receives the net amount (excluding VAT)

Amazon is NOT the deemed supplier (the seller accounts for VAT): - Sales above £135 — VAT is accounted for at import or by the seller - B2B sales (between VAT-registered businesses) - Sales by sellers registered for UK VAT who hold goods in a UK warehouse (FBA)

An important FBA pitfall: Once your goods are in a UK warehouse (FBA), every sale takes place on UK soil — it is no longer an import but a domestic UK supply. In this case: - You must be registered for UK VAT - You account for UK VAT yourself regardless of transaction value - Amazon is not the deemed supplier for goods stored in the UK

FBM vs FBA — differences in customs liability

FBA (Fulfilment by Amazon): - Goods stored in a UK warehouse → seller must be IoR on the initial import - Requires a UK EORI + UK VAT registration - Customs clearance is a one-off event when goods are shipped to the FBA warehouse - More cost-effective at higher volumes

FBM (Fulfilled by Merchant / Direct shipping): - Each parcel sent from overseas to a UK customer is a separate import consignment - For parcels below £135: the seller or marketplace collects VAT at the point of sale - No UK EORI needed for each individual shipment (the courier handles clearance) - The seller must however hold a UK VAT registration (or sell via a marketplace as a deemed supplier)

Aspect	FBA UK	FBM UK
UK EORI required	Yes (for import to warehouse)	No (courier handles it)
UK VAT registration	Yes	Yes (or via marketplace)
Customs clearance	One-off (bulk)	Per shipment
Who is IoR	Seller	Seller (or fiscal importer)
Clearance cost	£45–150 for bulk import	Included in courier cost (hidden)

eBay Managed Payments and customs obligations

On eBay UK the position is similar to Amazon, but with a few differences:

UK VAT via eBay: - eBay automatically charges and remits UK VAT on parcels below £135 from sellers based outside the UK - This has applied since 1 March 2021 - The seller sees the net amount in their account, excluding VAT

Import and customs clearance on eBay: - eBay does not take on any customs importer obligations - Every parcel shipped from overseas to a UK customer is a B2C import - For parcels below £135, eBay collects VAT, but customs clearance remains the responsibility of the seller / courier - Labels generated through the eBay Global Shipping Programme (GSP) include customs data — however GSP is only available for a limited range of goods categories

Risk on eBay without GSP: Sellers dispatching parcels outside the GSP must ensure: - Correct customs description on the parcel (value, goods description, HS code) - CN22 or CN23 declaration for postal items - Correct country of origin on the label

Risks for sellers without a UK EORI under FBA

Operating FBA without a UK EORI exposes the seller to:

1. Goods being held at the UK border Without a correctly lodged customs declaration, goods may be detained by UK Border Force. Storage costs and customs charges accrue for every day goods are held.

2. Liability for customs irregularities If a fiscal importer makes an error on the declaration (because they did not have accurate information from the seller) — HMRC may pursue the outstanding duty from the owner of the goods, i.e. the seller.

3. Amazon Seller Central account suspension Amazon verifies compliance with customs and tax rules. Sellers without proper import documentation risk having their Seller Central account suspended.

4. Retrospective customs assessments HMRC has the right to audit customs declarations going back 3 years. An incorrect HS code classification for goods imported to FBA can result in an assessment for unpaid duty plus interest.

How to prepare your first FBA UK import correctly

A practical checklist before your first FBA UK import:

• Register for a UK EORI (gov.uk — free of charge)
• Register for UK VAT (gov.uk — free, but allow time for processing)
• Prepare documentation: commercial invoice, packing list, HS codes for all products
• Check duty rates in the UK Trade Tariff (trade-tariff.service.gov.uk)
• Check product compliance requirements (e.g. UKCA marking, safety standards)
• Select a customs agent or freight forwarder with FBA UK experience
• Confirm the FBA delivery address matches Amazon's instructions (specific fulfilment centre)
• Retain a copy of the import declaration (Entry Number) — required for UK VAT accounting

Cost of a bulk import clearance to FBA UK with Easy Clearance: from £45 to £150 per declaration, depending on the number of tariff lines and the documents required.