Most cross-border e-commerce problems begin when a customer clicks “buy”. Fulfilment by Amazon inverts that order: your stock clears the border weeks before anyone orders it. That single fact is why Amazon FBA UK customs obligations look nothing like those that apply to a parcel posted from Poznan to a buyer in Leeds — and why the GBP 135 threshold that dominates every e-commerce VAT guide does almost nothing for an FBA seller.
Amazon FBA UK customs starts before the first sale
An FBA shipment is a commercial import of goods you still own. There is no customer, no sale and no VAT-inclusive price at the border — only a consignment arriving into Great Britain that needs a customs declaration, a commodity code and a customs value. Duty and import VAT fall due at that moment, on you, not on the person who buys the item three weeks later.
Two separate tax events therefore sit inside one FBA product: the import when the pallet lands, and the supply when the unit sells. Sellers who treat FBA as “selling online to the UK” plan only for the second. Settle this before the first pallet moves, because the question of who counts as the importer on an FBA consignment decides who can recover the VAT later.
You also need an EORI number to move goods between Great Britain and any other country, including the EU. Where a business is not eligible to apply itself, gov.uk says “you’ll need to appoint someone to deal with customs on your behalf”. Our guide to getting a UK EORI number covers the application steps.
The GBP 135 rule does not rescue an FBA seller
The GBP 135 rule is about consignment value, and HMRC applies it to “the total consignment that is imported, not the separate value of individual items”. A pallet of 400 phone cases is one consignment far above the threshold, even though each case is a low-value item on its own.
More importantly, the threshold only governs goods that are outside the UK at the point of sale. FBA stock is inside the UK, sitting in a fulfilment centre. For that situation gov.uk is explicit: “If you are an overseas seller who own goods of any value that are located in the UK at the point of sale you must register and account for VAT on any sales you make directly to customers in Great Britain or Northern Ireland.”
Any value. The GBP 135 exemption disappears the moment your goods physically enter the country, which in the FBA model is always.
Import VAT: paying it once, and getting it back
Import VAT on an FBA shipment is money leaving your account at the border, recoverable only if the paperwork names the right business. Two mechanisms matter.
Postponed VAT accounting (PVA) lets a UK VAT-registered business account for import VAT on its VAT Return instead of paying it at the frontier. Per gov.uk, “You do not need any approval to account for import VAT on your VAT Return” — but two conditions must hold: the goods are for business use with disposal rights, and your VAT registration number appears on the import declaration. Practically, that means the declaration must carry your VAT number at header level in Data Element 3/40, and must not use payment method G in Data Element 4/8. The choice cannot be changed after the declaration is submitted, which is the part that catches sellers out.
A business not established in the UK must appoint a customs representative and tell them to select PVA and “enter your details as the consignee”. A third party importing on your behalf must hold written confirmation before proceeding.
The C79 certificate is the alternative route, used where import VAT was paid at the border rather than postponed; it is the evidence HMRC expects behind a reclaim. Our note on using the C79 certificate to reclaim import VAT covers what to do when the certificate does not match your records.
The deemed supply: when Amazon accounts for the VAT instead of you
Once your goods are in the UK and sell through the marketplace, a second rule takes over. Where the seller is not established in the UK, “the online marketplace will be liable to account for the VAT on the sales made through its marketplace”.
HMRC structures this as a deemed supply: “the overseas seller will be considered to have made a zero-rated supply of the goods to the online marketplace”, which then supplies the end customer and carries the VAT. Marketplaces must keep full records, including VAT invoices, for six years from the date goods are sold.
Read both halves together and the picture is complete. You carry duty and import VAT at the border; the marketplace carries output VAT on its sales. Your UK VAT registration connects them — it is the condition for postponed VAT accounting, the route to recovering import VAT, and where the zero-rated deemed supply is reported. Direct sales outside the marketplace remain yours to account for, at any value.
Checklist before your first FBA shipment
- EORI number in place for moving goods into Great Britain (and a customs representative appointed if you cannot apply yourself).
- UK VAT registration active before stock arrives, not after the first sale.
- Commodity codes classified per SKU, not per pallet, and a customs value established on a defensible basis — there is no sale price yet.
- PVA decision made before the declaration is submitted, with your VAT number instructed for Data Element 3/40 and payment method G excluded from 4/8.
- Written confirmation issued to whoever declares on your behalf.
- C79 or postponed VAT statements reconciled monthly against marketplace settlement reports.
Sellers on the Poland-to-UK lane usually want one party handling both the export side and the GB import declaration — the everyday work of a customs agency covering the UK-Poland route.
Mini-FAQ
Does the GBP 135 threshold apply to my FBA stock?
No. It applies to consignments sold while the goods are outside the UK. FBA stock is in the UK at the point of sale, so an overseas seller must register and account for VAT on goods of any value sold directly to customers.
Do I need HMRC approval to use postponed VAT accounting?
No. gov.uk states no approval is needed, but your VAT registration number must be on the import declaration and the goods must be for business use with disposal rights.
If Amazon accounts for the VAT, why do I still need a UK VAT registration?
Because the marketplace rule covers only the sale to the end customer. The import, the recovery of import VAT and the zero-rated deemed supply to the marketplace all sit with you.