Yes. Since 3 September 2026 every ASIN enrolled in Pan-European FBA must carry an active offer on Amazon.nl, and from 26 February 2027 an active offer on Amazon.com.be is required at enrolment. Amazon notified European sellers on 14 August 2026. An ASIN without a Dutch offer drops out of Pan-European FBA and goes back to paying cross-border fulfilment fees on every European order.
No stock has to be placed in the Netherlands or Belgium: this is a listing obligation, not a logistics one. But for a group that enrolled its catalogue years ago and has not audited it since 3 September, the margin on German, French and Spanish orders may have changed without anyone noticing.
What does Amazon require from 3 September 2026?
An active offer in the Netherlands store for every Pan-European FBA product, new and existing, on top of the existing conditions: active offers in Germany, France, Italy and Spain, and inventory stored in at least two countries.
The rule arrived in steps. From 28 August 2025 the Dutch offer was required only for products newly enrolled. From 3 September 2026 it applies to all of them. From 26 February 2027 Belgium is added, for now only for products enrolled from that date onwards; Amazon has committed to at least 30 days’ notice before extending it to the existing catalogue.
What happens to a product without a Dutch offer?
It loses Pan-European eligibility. Orders from the other European stores are fulfilled through the European Fulfilment Network (EFN), which charges a cross-border fulfilment fee per unit, higher than the local one.
The gap is material. In its 2025 notice on the Netherlands, Amazon itself put the Pan-European saving against cross-border fees at “up to 53%” of fulfilment costs. The problem is that the switch happens ASIN by ASIN and silently: the detail page stays live, sales continue, only the cost line in the settlement report changes. That is why the check belongs in this quarter’s agenda, not in the year-end review. Our marketplace services for European groups include this cost review by category.
We read the Pan-European inventory report and the settlement of each account and tell you which ASINs left the programme after 3 September, and what it costs. The first 30-minute call is free.
Do we have to store stock in the Netherlands or Belgium?
No. Amazon states that “you are not currently required to store inventory in the Netherlands or Belgium to participate in Pan-European FBA”. Storage stays in the countries you selected, at least two among Germany, France, Italy, Spain and Poland.
Dutch orders attract local fees when inventory placement is enabled in Germany; Belgian orders when it is enabled in Germany or France. In practice, a group storing in Germany already covers both markets.
Which exemptions exist?
Four, listed by Amazon, valid for a limited or unlimited period depending on the case:
- the product is restricted or cannot be sold in the Netherlands or Belgium;
- the product does not meet local-language labelling or packaging requirements;
- the account is temporarily deactivated in the Dutch or Belgian store;
- the product does not yet have a detail page in that store.
The last point is a time-limited exemption, not an exit. Where the detail page is missing, Amazon normally creates it through Build International Listings (BIL). The labelling exemption is the one that genuinely matters for food, cosmetics and toys, where on-pack language is a legal requirement rather than a marketing choice.
What changes for VAT and language?
Selling in the Netherlands means selling to Dutch consumers: VAT on distance sales is reported through the OSS scheme in the country of establishment or, beyond the EU-wide €10,000 distance-selling threshold, through a local VAT registration. A group already filing OSS for Germany and France adds a country to the quarterly return, nothing more.
On the listing side, Amazon machine-translates the detail page, but machine-translated titles and bullets rarely convert. Customer questions arrive in Dutch: with FBA, Amazon handles customer service; with merchant fulfilment, you do. The full picture of countries, taxes and rules is covered in our note on operating Seller and Vendor accounts across Europe. Tax decisions remain with your advisers.
We manage accounts across Italy, Germany, France, Spain, the Netherlands, Belgium, Ireland, Sweden, Poland and Turkey: per-country pricing, exemptions and BIL-created offers checked one by one. Every account has a named person on it.
How do we check which ASINs are at risk today?
In Seller Central, under “Pan-European FBA Inventory”: it shows the enrolment status of each product and the stores where an offer is missing. A Dutch offer is added through “Manage All Inventory”, “Edit offer”, “Manage offers in other marketplaces”, or by enabling a BIL connection with the Netherlands.
Three checks we run on the accounts we manage, in this order:
- how many Pan-European ASINs have no offer on Amazon.nl, and since when: if the date is after 3 September, those products are already paying EFN fees;
- which exemption applies, product by product, and whether it is time-limited;
- the Dutch price: an automatically created offer inherits the price of another store, and Dutch VAT at 21% is neither Italian 22% nor German 19%.
And from 26 February 2027 with Belgium?
From 26 February 2027, products enrolled in Pan-European FBA must also carry an active offer on Amazon.com.be. For products already enrolled Amazon has not yet set a date; it will come with at least 30 days’ notice, as happened with the Netherlands.
Belgium adds a complication: three official languages, with the Amazon store serving customers in French and Dutch. A group that already lists in France and the Netherlands starts ahead; one with labels only in Italian and English will probably fall under the language exemption for as long as it lasts.
Frequently asked questions on Pan-European FBA
What is the difference between Pan-European FBA and the European Fulfilment Network?
With Pan-European FBA Amazon moves your stock between its European warehouses and each order pays the local fulfilment fee of the destination country. With EFN stock stays in one country and every foreign order pays a higher cross-border fee. Pan-European pays off when you sell steadily in several countries.
Can we stay in Pan-European FBA without selling in the Netherlands?
Only under one of the four exemptions. Otherwise the product leaves the programme and orders move to EFN. The choice is not “sell in the Netherlands or not”: it is “pay local fees or cross-border fees on every European order”.
Do we need a Dutch VAT number?
Normally not, if distance sales are reported through OSS. Storing goods in a country does trigger a local VAT registration, but Amazon does not require storage in the Netherlands or Belgium. Each case should be confirmed with your tax adviser.
Does Amazon create the Dutch offers or do we?
Either: manually from “Manage All Inventory”, or by letting Build International Listings generate them from existing offers. In both cases price, translation and label compliance need checking.
Pan-European FBA is one of the levers we monitor in our Amazon account management service: enrolments, exemptions, per-country pricing and actual fulfilment costs, read every month from the settlement report. Source: Amazon Seller Central Europe notice of 14 August 2026, “Pan-European FBA will require offers in the Netherlands and Belgium”.
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