Pan-EU FBA Now Requires a Netherlands Offer, With Belgium to Follow in 2027

If you sell through Pan-European FBA, the list of stores you have to be live in just got longer. Amazon announced in August that from 3 September 2026 every product in the programme, new or existing, must have an active offer on Amazon.nl. A second requirement, an active offer in Belgium, follows on 26 February 2027 for products being enrolled. This post covers what Amazon said in its own words, which products can sit the requirement out, and the fee and VAT questions that come with it.

What Amazon announced

The change was posted by Amazon staff in the Seller Forums news feed in August 2026. The two operative sentences are short:

"Starting 3 September 2026, all Pan-EU FBA products (new and existing) must have an active offer in the Netherlands in addition to existing listing requirements."

"Starting 26 February 2027, you must also have an active offer in Belgium for Pan-EU FBA products, at enrollment. We'll notify you at least 30 days before this requirement goes into effect."

Read the two dates carefully, because they are not the same kind of rule. The Netherlands requirement applies to everything already enrolled as well as anything new. The Belgium requirement, as written, applies at enrollment. Amazon has not said whether products that are already in Pan-EU FBA on 26 February 2027 will later need a Belgian offer the way they now need a Dutch one. Ecommerce News Europe keeps to that narrow reading. ChannelX goes further and advises listing eligible products in Belgium by the end of February 2027 "to retain your Pan-EU FBA standing", which is sensible advice but not something Amazon's announcement states. Plan for the narrower reading but do not be surprised if it widens.

How this fits the existing Pan-EU rules

Pan-European FBA already has two eligibility conditions, and this announcement extends the first of them. According to Amazon's own Pan-European FBA page, you need to "list your eligible FBA products with the same SKU in all required Amazon EU stores: Germany, France, Italy, Spain and the Netherlands", and separately you need to "enable storage in at least two of these countries" from Germany, France, Italy, Spain and Poland.

Two things follow from that. First, the listing requirement and the storage requirement are separate. The staff post is explicit that "you're currently not required to store inventory in the Netherlands or Belgium to participate in Pan-EU FBA." You are being asked to sell into those countries, not to hold stock there. Second, this was signposted. In an earlier Seller Forums notice about a year ago, Amazon staff said new Pan-EU products "must now have an offer in our Netherlands store" and that "later this year, you'll be required to list your existing Pan-EU Fulfilment by Amazon offers on Amazon.nl to stay in the Pan-EU Fulfilment by Amazon programme". The September date is that second step arriving. If you have ASINs that were enrolled before Amazon.nl became a required store, those are the ones to check.

Who can claim an exemption

Amazon says you "may be eligible for an exemption for a limited or unlimited period to the listing requirement for select use cases", and the post lists four:

• "Your products are restricted or can't be sold in the Netherlands or Belgium."
• "Your products don't comply with local language labelling or packaging requirements."
• "Your account is temporarily deactivated in the Netherlands or Belgium store."
• "Your product doesn't have a product detail page in the Netherlands or Belgium store yet."

Note the wording: "may be eligible". None of the four is described as automatic. If your ASIN has no product detail page on Amazon.nl, you may qualify for a limited or unlimited exemption, but you should check the ASIN's status in Pan-European FBA Inventory and follow Amazon's exemption process rather than assume that the missing page settles it. Amazon points sellers to the Pan-European FBA ASIN enrollment help page in Seller Central for that process.

What it does to your fees

The reason Amazon gives for the change is commercial: "reach thousands of new customers, help increase your FBA sales, and save on fulfilment fees." The fee side deserves a closer look because it is conditional.

Amazon's post ties local fee rates in the two new markets to where your inventory placement is switched on:

• "Netherlands: Local fees apply when inventory placement is active in Germany."
• "Belgium: Local fees apply when inventory placement is active in Germany or France."

Under the Pan-EU model you pay the local FBA fulfilment fee for orders in countries where placement is enabled, and the cross-border European Fulfilment Network rate elsewhere. Amazon's Pan-EU page claims sellers "can save up to 53% on shipping fees" against EFN, which is Amazon's marketing figure for the best case rather than a promise for your catalogue. The practical point is narrower: a Dutch order can be fulfilled at a local rate if Germany is one of your placement countries, and a Belgian order can be fulfilled at a local rate if Germany or France is. If neither is enabled, the new orders still arrive but at the higher cross-border rate, and your margin on them will look different from your German or French margin.

That is the number to watch. An extra market at local rates is usually good news. An extra market at EFN rates on a low-priced product can be a net loss per order, particularly once returns are included. Run the per-unit maths for a few representative SKUs before you assume the new orders are profitable. Our guide to Amazon fee analysis walks through how to separate fulfilment fees from the rest of the cost stack so you can compare one marketplace against another on a like-for-like basis.

The VAT question

Amazon's post does not answer the VAT question and neither will this one in full, because it depends on where your stock sits and how you are registered. Amazon simply says "for VAT obligations for selling in these countries, go to European VAT Education."

The general shape is this. Because Pan-EU FBA does not require stock in the Netherlands or Belgium, a sale to a Dutch or Belgian consumer shipped from your German or French inventory is an intra-EU distance sale. The European Commission's One Stop Shop guidance states that "without the OSS schemes, the supplier would be required to register in each Member State in which he supplies goods or services to his customers", and that a business using the scheme "is only required to register in one single Member State, the Member State of identification". Two qualifications from the same guidance matter here. The scheme is optional: "The OSS schemes are optional for taxable persons." And it is additional: "The OSS VAT returns are additional and do not replace the VAT return a taxable person submits to his Member State under his domestic VAT obligations." So where a Dutch or Belgian sale qualifies as an intra-EU distance sale and you already use the Union OSS, its VAT can generally be reported there. Sales that do not qualify, for example goods shipped from stock you hold in the destination country, are treated differently.

What changes is the amount of VAT flowing through that return at Dutch and Belgian rates, and the fact that your profit figure on those orders is only right if the correct rate is deducted. Check with your adviser whether anything about your setup, such as stock held with a third-party warehouse in either country, creates a local registration obligation. Our Amazon VAT management page explains how per-marketplace VAT rates feed into profit reporting.

What to do this week

1. Start from Amazon's at-risk list, not your full catalogue. In Seller Central open Pan-European FBA Inventory. Amazon's earlier Netherlands notice said that products "with a Netherlands offer (or offers exempt from this requirement) will appear under Enrolled ASINs", while "existing Pan-EU Fulfilment by Amazon products without a Netherlands offer will appear under ASINs with enrolment ending soon." Work through the second group. For each ASIN there, either add an active Netherlands offer or follow Amazon's exemption process. Leave Enrolled ASINs alone: they already have an offer or an exemption.
2. Add the Dutch offers. Amazon's instructions are to open Manage All Inventory, select the offer, choose Edit listing, and enable the Netherlands offer under "Manage offers in other marketplaces". Alternatively, in Amazon's words, "you can enable a Build International Listings (BIL) connection to the Netherlands".
3. Check the offer is actually active. Amazon's wording is "an active offer", so a listing that exists on Amazon.nl but is suppressed or inactive is not obviously enough. Fix any stranded or suppressed offers rather than assuming the listing counts.
4. Decide on exemptions. Products that cannot legally sell in the Netherlands, or that fail Dutch labelling rules, should go through the exemption route rather than being listed and then pulled.
5. Confirm your placement countries. If Germany is not one of your enabled placement countries, Dutch orders will be fulfilled at EFN rates. If neither Germany nor France is enabled, the same is true for Belgium from next year.
6. Diary February 2027. Belgium applies at enrollment from 26 February 2027 and Amazon has promised at least 30 days' notice. Any new Pan-EU enrolments after that date will need a Belgian offer from the start.

Seeing the new markets in your numbers

Once Dutch and Belgian orders start landing, the useful question is not "are we selling there" but "are we making money there". In SellerLegend each connected marketplace is its own account, and the aggregate dashboard shows a panel per marketplace so Amazon.nl sits alongside Amazon.de rather than being blended into a European total. On plans that include the VAT module, VAT is deducted from each European order at the rate you set for the marketplace or, where it differs, for the individual product, so the Dutch and Belgian profit figures are net of the right VAT rather than the German one. See how it works on the multi-marketplace analytics page.

Key takeaways

• From 3 September 2026, every Pan-EU FBA product, new or existing, needs an active offer on Amazon.nl.
• From 26 February 2027, products enrolling in Pan-EU FBA will also need an active offer in Belgium. Amazon has not yet said whether this will extend to products already enrolled.
• You do not have to store inventory in either country. This is a listing requirement, not a placement requirement.
• You may be eligible for an exemption for restricted products, labelling non-compliance, temporary store deactivation or ASINs with no local detail page yet. None is automatic, so follow Amazon's process.
• Local fulfilment rates in the Netherlands depend on German placement being active. In Belgium they depend on German or French placement.
• Consumer sales shipped to either country from stock held elsewhere in the EU may be intra-EU distance sales. Where they qualify and you have opted into the Union OSS, they are reported there. Confirm your own position with an adviser.

Selling into two more European stores only pays if you can see the margin on each of them. Start a free 21-day SellerLegend trial and track Amazon.nl and Amazon.com.be next to the rest of your European accounts.

Sources

• Amazon Seller Forums (Amazon staff): Pan-EU FBA to require Netherlands and Belgium offer
• Amazon Seller Forums (Amazon staff): earlier notice adding the Netherlands for new Pan-EU FBA products
• Amazon: Successful selling with Pan-European FBA (eligibility and fees)
• ChannelX: Amazon Pan-EU FBA adds Netherlands and Belgium requirement (28 August 2026)
• Ecommerce News Europe: Amazon expands listing requirements for Pan-EU FBA (31 August 2026)
• European Commission: VAT One Stop Shop