What actually differs between the three
Most brands do not stall in a new marketplace because the ads were wrong. They stall because something administrative was missed, and by the time it surfaces the listings are already down.
| Amazon UK | Amazon US | Amazon EU | |
|---|---|---|---|
| VAT | Registration threshold is £90,000 of taxable turnover over 12 months. That threshold does not apply to a non-established taxable person, who must register if they make any taxable supplies at all, whatever the value. | Per-country thresholds were replaced by a single EU-wide threshold of €10,000. Below it, distance sales within the EU may stay taxed where the seller is established. Above it, the destination country’s VAT applies, and OSS lets you file once instead of registering in each country. | |
| Product safety | Northern Ireland sits inside GPSR scope under post-Brexit arrangements. The rest of the UK does not. | The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. It is a regulation, so it applies identically in every member state with no national transposition, and it sets explicit duties for online sales, marketplaces and fulfilment providers. | |
| Packaging | You must collect and report packaging data at £1m turnover and more than 25 tonnes supplied or imported in the previous year. Large producers, £2m and over 50 tonnes, pay fees on household packaging through PackUK. In 2025 to 2026 those are flat base fees per tonne. | The Packaging and Packaging Waste Regulation (EU) 2025/40 entered into force in February 2025 and its rules apply on a phased basis from 12 August 2026. It covers all packaging regardless of material or origin. Not every obligation lands on that date; the harder ones run to 2030 and beyond. | |
| Brand Registry | An active registered trademark, or in some cases a pending application, issued by the designated government trademark office of a country with a corresponding Amazon store. Word mark, or design mark containing words, letters or numbers. The trademark owner enrols; an agent is added afterwards as an additional user. | ||
Last reviewed: . Rules change. Confirm current requirements before acting on anything here.
Amzlify flags compliance issues that affect account health, listing suppression or stranded inventory: VAT registration status, EPR, PPWR and GPSR. I do not provide tax or legal advice and do not handle registration or filings. Those go to a specialist.
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