Amazon C.O.S programme ended: what FBA sellers must do for VAT

What was Amazon C.O.S?

Amazon C.O.S, short for Call-Off Stock, was a VAT and logistics arrangement used by Amazon sellers in Europe. It allowed eligible sellers to place inventory in Amazon fulfilment centres in countries such as Germany, France, Italy or Spain while Amazon acted as the buyer when the goods were sold locally.

In practice, the seller did not make a direct local B2C sale from that foreign stock. The seller made a B2B supply to Amazon when Amazon took the goods, and Amazon then sold to the final customer. That is why many sellers could expand across Europe without immediately opening several VAT numbers.

• Store inventory closer to customers in major EU markets.
• Improve delivery times and Prime availability.
• Avoid part of the local VAT registration burden while the COS model applied.
• Keep a simpler compliance setup than full multi-country FBA storage.

What changed when Amazon ended the C.O.S programme?

The change is simple: sellers can no longer rely on Amazon C.O.S to hold stock in several EU countries without local VAT numbers. Since 1 August 2024, sellers who want to continue local storage through Amazon generally need to move to Pan-European FBA or reorganise fulfilment through another model.

For VAT, the most important consequence is the place where the goods are stored. If your inventory is physically held in Germany, France, Italy, Spain or another EU country, that country may require a VAT registration before sales are made from that stock.

• A VAT number in each country where stock is stored.
• Local VAT returns for domestic sales from that stock.
• Intrastat or ESL reporting where thresholds and flows require it.
• Correct reconciliation between Amazon reports, local VAT returns and accounting records.

Which sellers are most affected?

The sellers most affected are those who used C.O.S to reach several European marketplaces from one tax setup. If you previously stocked goods in Amazon fulfilment centres outside your home VAT country, you should treat each storage country as a separate VAT compliance point.

This is especially sensitive for non-EU sellers, UK sellers after Brexit, and EU sellers using Amazon to accelerate delivery in countries where they do not yet have a VAT number.

Option 1: activate Pan-European FBA

Pan-European FBA is the natural replacement if your priority is fast delivery and local stock across Europe. Amazon can distribute inventory across its European fulfilment network, but the VAT consequence is heavier: you need VAT registrations in the countries where your stock may be stored.

For Amazon sellers, this usually means preparing VAT numbers before the inventory is moved. A local VAT registration can cost around EUR 700 to EUR 1,000 per country when handled externally, before ongoing filing fees and compliance monitoring.

If this is your route, start with the countries that create the highest commercial gain. Do not activate every storage country just because the option exists in Seller Central.

Option 2: use EFN from one stock country

The European Fulfilment Network, or EFN, is often simpler from a VAT point of view. You keep stock in one country and Amazon ships cross-border to customers in other European countries. This can reduce the number of VAT registrations linked to storage.

The trade-off is operational. EFN may involve higher fulfilment fees and slower delivery than local FBA storage. For smaller sellers, that cost can be acceptable if it avoids opening four or five VAT numbers too early.

See also our guide on selling in Europe with EFN without multiple VAT registrations if you want to compare this route with Pan-European FBA.

Option 3: selective local storage

Selective local storage is often the cleanest approach for growing sellers. You choose one or two strategic countries, register for VAT there, and keep the rest of Europe supplied through EFN or another fulfilment setup.

This avoids a common mistake: opening VAT numbers in countries where sales volume does not yet justify the monthly reporting work. VAT registration is not just an admin form. It creates recurring filing, reconciliation and audit obligations.

• Start with the countries where stock will genuinely be stored.
• Confirm whether Amazon can move stock automatically into additional countries.
• Register before the first taxable local flow, not after the first sale.
• Build a monthly reporting calendar for every active VAT number.

What must be declared after C.O.S?

After C.O.S, your VAT declarations depend on the fulfilment model. If you use local FBA storage, you generally declare domestic sales from that stock in the country where the goods are located. You may also need to report stock transfers between EU countries when inventory moves from one fulfilment centre to another.

Amazon reports are useful, but they are not a VAT return. Your VAT file must identify where goods were stored, where they moved, who sold to whom, and which transactions were already taxed by the marketplace mechanism.

For deeper operational rules, read our guide on Amazon warehouses in Europe and FBA VAT rules.

How to prepare your VAT setup now

The safest method is to build your VAT setup before changing your Seller Central storage settings. If Amazon starts moving stock before VAT numbers are active, you may create obligations that are hard to reconstruct afterwards.

• Export your Amazon inventory placement settings and identify active storage countries.
• List the countries where you already hold a VAT number.
• Compare stock countries with VAT registration countries.
• Register where storage will continue.
• Set up local VAT return calendars and Amazon report extraction before the first filing period.
• Reconcile VAT collected by Amazon separately from VAT due on your own taxable flows.

If you need a VAT number for Amazon, use our guide on VAT registration for selling on Amazon in Europe. If you sell from outside the EU or manage several FBA countries, an Amazon tax representative can secure the registrations, filings and exchanges with local tax authorities.

Final advice for Amazon sellers

The end of Amazon C.O.S did not make European FBA impossible. It removed a shortcut. The right answer is now a deliberate storage and VAT strategy: one country for simplicity, Pan-European FBA for speed, or selective local storage for controlled growth. See our guide on Quick Fixes.

If your Amazon stock is moving between countries, start with the VAT map before changing fulfilment settings. See our guide on Amazon VAT Guide Sellers.

See also: Amazon tax representative · EU stock transfers France VAT rules