US, UK and EU Amazon Marketplaces Compared: What Sellers and Business Buyers Should Know

Amazon Is Global — But Its Marketplaces Are Not Identical

Amazon provides sellers with infrastructure that can make international expansion appear relatively straightforward.

The storefront may look familiar.

Seller Central may look familiar.

FBA may look familiar.

But the underlying business environment can change considerably from one country or region to another.

Differences may include:

• Tax
• Customs
• Import procedures
• Product regulation
• Consumer law
• Fulfilment options
• Inventory placement
• Currency
• Language
• Returns
• Advertising economics
• Marketplace competition
• Verification requirements
• Business documentation

For a seller, those differences affect operational complexity.

For a buyer, they affect due diligence and potentially valuation.

A business generating £1 million equivalent from one marketplace with inventory in one country may be structurally very different from another £1 million business whose revenue depends on inventory distributed across several European countries.

Quick Comparison: US vs UK vs EU

This comparison is intentionally high level.

Tax and regulatory obligations depend on the seller, products, transaction structure and inventory movements.

Understanding Amazon’s Marketplace and Regional Structure

Do not assume that every Amazon country website represents a completely unrelated seller operation.

Amazon uses regional and global selling structures.

For example, Amazon describes its North American selling structure as allowing eligible sellers to operate across the United States, Canada, Mexico and Brazil through its North America and Brazil unified selling environment.

Amazon also provides a regional European selling environment.

However, this does not mean every marketplace behaves identically.

Amazon itself notes that listing a product in one European store does not automatically list that product in all other European stores.

For due diligence, identify:

• Seller Central accounts involved
• Regions enabled
• Individual marketplaces enabled
• Marketplaces actively generating revenue
• Marketplaces with inactive registrations
• Marketplace-specific inventory
• Marketplace-specific tax registrations
• Marketplace-specific compliance requirements
• Marketplace-specific account-health issues

Selling on Amazon in the United States

For many Amazon businesses, Amazon.com is the primary marketplace.

A US-focused business may appear operationally simpler than a multi-country European operation because sales, inventory and fulfilment can potentially remain concentrated in one country.

Review:

• Amazon.com revenue
• FBA vs FBM mix
• US inventory
• State-level sales concentration
• Advertising dependency
• Product concentration
• Returns
• Account Health
• Restricted-product history
• Product compliance
• Insurance where applicable
• Business entity
• Banking
• Tax documentation

Do not mistake operational concentration for low risk.

A business heavily dependent on Amazon.com may have substantial single-market exposure.

Ask:

“What happens to this business if US marketplace performance declines materially?”

Selling on Amazon in the United Kingdom

Amazon.co.uk operates within the UK’s own tax, customs and regulatory environment.

Following the UK’s departure from the EU, Great Britain and the EU should not be treated as one inventory or customs territory.

A UK Amazon business may need to consider:

• UK VAT
• Import VAT
• Customs duties
• EORI requirements where applicable
• Product compliance
• UK-based inventory
• FBA
• Returns
• Consumer requirements
• Product labelling
• Marketplace VAT treatment
• Northern Ireland-specific considerations where relevant

For an acquisition, review whether the business is actually established in the UK or merely incorporated there.

Those concepts are not necessarily identical for VAT purposes.

HMRC guidance makes clear that establishment is based on the substance of where the business is managed and operated, not merely whether a company has a UK incorporation or virtual address.

Selling Across Amazon Europe

“Amazon Europe” is not one consumer marketplace.

Amazon operates country-specific stores across Europe.

Depending on the business and Amazon’s current supported marketplace structure, relevant stores can include major markets such as:

• Germany
• France
• Italy
• Spain
• Netherlands
• Sweden
• Poland
• Belgium
• Ireland
• Other supported European stores

A seller may participate in some without actively selling in all.

Different marketplaces can produce very different:

• Revenue
• Conversion
• Competition
• Advertising costs
• Return rates
• Product demand
• Language requirements
• Tax exposure
• Inventory requirements

Amazon states that sellers expanding into Europe should review taxes and regulations, including VAT, and understand product compliance, safety and listing requirements for the countries in which they operate.

A buyer therefore needs marketplace-level information rather than one combined “Europe revenue” figure.

Marketplace Size vs Operational Complexity

A larger geographic footprint can create growth.

It can also create complexity.

Compare:

Business B may have greater geographic diversification.

It may also require more administration.

Neither structure is automatically better.

The question is whether the operational complexity is understood, compliant and economically justified.

Sales Tax in the United States

US sales tax should not be described as the equivalent of one national VAT system.

Sales tax is primarily governed at state and local level.

Marketplace-facilitator rules can require marketplaces such as Amazon to calculate, collect and remit sales tax on qualifying marketplace transactions.

However, marketplace collection does not automatically eliminate every tax or filing obligation a business may have.

A prospective buyer should determine:

• Where the business is established
• Where inventory is stored
• Whether the business has employees or other operations
• Which states have registrations
• Whether filings are current
• Whether sales occur outside Amazon
• Whether historical liabilities exist
• Whether professional tax advice has been obtained

VAT in the United Kingdom

VAT is a major consideration when reviewing a UK Amazon business.

The correct treatment depends on factors including:

• Where the seller is established
• Where the goods are located when sold
• Where the customer is located
• Whether the customer is a business or consumer
• Whether Amazon is treated as responsible for VAT on the transaction
• Whether goods are imported
• The value and nature of the consignment
• Whether the seller also makes direct sales

For UK-established businesses, the normal domestic VAT-registration rules can be relevant.

For overseas sellers, different rules can apply and UK VAT registration may be required in circumstances where a domestic threshold should not simply be assumed.

Where an overseas seller stores goods in the UK, importing the goods can create import VAT and customs obligations even where the marketplace later accounts for VAT on certain consumer sales.

Review:

• UK VAT number
• Registered legal name
• VAT returns
• Import VAT records
• Customs records
• EORI where applicable
• Marketplace VAT reports
• Accountant correspondence
• Historical liabilities
• VAT treatment of non-Amazon sales

VAT Across the European Union

The EU operates a VAT system, but VAT obligations are administered through individual Member States within the common framework.

A seller may therefore encounter:

• Domestic VAT registrations
• Intra-EU sales
• Intra-EU inventory movements
• Distance sales
• Imports
• Marketplace deemed-supplier rules
• OSS
• IOSS
• Local VAT filings
• Different VAT rates

A commonly misunderstood figure is the EU’s €10,000 threshold for certain intra-Community distance sales.

It should not be read as allowing sellers to simply sell €10,000 into Europe before needing to consider VAT.

The threshold has specific conditions.

It generally concerns certain cross-border B2C supplies by businesses established in only one EU Member State and is not a universal VAT-registration exemption for every international Amazon seller.

A business storing inventory in several EU countries may have VAT obligations arising from the location and movement of that inventory independently of this threshold.

What OSS and IOSS Actually Do

OSS and IOSS can simplify certain EU VAT reporting.

They do not make every VAT obligation disappear.

Neither should be described as a substitute for understanding where inventory is physically stored.

A seller storing stock in another Member State can have local VAT-registration obligations that OSS does not necessarily remove.

Inventory Location Can Change the Tax Picture

This is one of the most important concepts in European Amazon due diligence.

Inventory is not merely an operational asset.

Its physical location can affect:

• VAT registration
• VAT reporting
• Imports
• Customs
• Inventory transfers
• Compliance
• Returns
• Fulfilment speed
• Storage cost

Example — a seller says:

“We sell across Germany, France, Italy and Spain.”

That statement does not tell a buyer where the inventory actually sits.

The VAT and operational structure may be very different.

Before acquiring a European Amazon business, request an inventory-location map.

FBA in the US, UK and Europe

Fulfilment by Amazon can simplify customer fulfilment, but the underlying structure still needs review.

For each region investigate:

• FBA inventory quantity
• FC inventory location where relevant
• Available inventory
• Reserved inventory
• Inbound inventory
• Unfulfillable inventory
• Aged inventory
• Storage charges
• Removal exposure
• Reimbursements
• Returns
• Stranded inventory
• Inventory by ASIN

European Cross-Border Fulfilment

Amazon offers different fulfilment approaches for European sellers, and programme names and eligibility can change over time.

Depending on the business, arrangements may involve:

• Domestic FBA
• Cross-border fulfilment
• European Fulfilment Network-style arrangements
• Multi-country inventory placement
• Pan-European fulfilment structures where eligible
• Remote fulfilment structures where offered

Not every programme is necessarily available to every seller or marketplace.

The due-diligence questions are more durable:

• Where can Amazon store inventory?
• Where is inventory currently stored?
• Which programmes are enabled?
• Which countries require VAT registrations under the current structure?
• What fees apply?
• What happens if a programme is disabled?
• Which countries generate most orders?
• Which countries generate most profit?

Customs, Importing and Importer Responsibilities

Cross-border Amazon operations can involve customs responsibilities before a product ever becomes available for sale.

Review:

• Country of origin
• Commodity / tariff classification
• Customs valuation
• Importer of record arrangements
• Import VAT
• Customs duty
• EORI numbers where applicable
• Freight documentation
• Commercial invoices
• Supplier documentation
• Product certification
• Customs brokers
• Incoterms
• Freight contracts

Do not assume that because inventory successfully reached an Amazon fulfilment centre, the underlying importing structure was necessarily correct.

For acquisitions, request historical import documentation where material.

Product Compliance: US vs UK vs EU

Product compliance is highly category-specific.

No marketplace has one universal product-compliance checklist.

For due diligence, investigate:

• Product category
• Applicable legislation
• Test reports
• Certificates
• Declarations where required
• Technical files
• Product labels
• Packaging
• Warning information
• Manufacturer information
• Importer information
• Responsible-person information where applicable
• Compliance requests from Amazon
• Historical product removals
• Recalls
• Safety complaints

EU General Product Safety Regulation

The EU General Product Safety Regulation — Regulation (EU) 2023/988 — has applied since 13 December 2024.

It establishes a general product-safety framework for consumer non-food products covered by the regulation, while product-specific EU legislation can impose additional requirements.

Among other things, the GPSR strengthens:

• Product safety responsibilities
• Traceability
• Information requirements
• Recall processes
• Online marketplace obligations
• Distance-sales information requirements

For products covered by the applicable rules, there must be a responsible economic operator in the EU.

Depending on the supply chain, that role can be fulfilled by an EU-based manufacturer, importer, authorised representative or, in relevant circumstances, a fulfilment service provider.

Distance-sale product offers can also require manufacturer and responsible-person information, together with relevant product identification and safety information.

For an Amazon acquisition involving EU sales, review:

• Manufacturer identity
• EU responsible economic operator where required
• Product traceability
• Safety information
• Product warnings
• Technical documentation where applicable
• Recall history
• Safety complaints
• Amazon compliance requests

Currency and Foreign-Exchange Exposure

International Amazon businesses can generate revenue and expenses in different currencies.

Common exposures can include:

• USD
• GBP
• EUR
• Other marketplace currencies
• Supplier currencies
• Freight currencies
• Advertising charges
• Amazon conversion charges
• Bank conversion charges

A business can grow revenue while losing margin through currency movements.

Review:

• Revenue by currency
• Costs by currency
• Amazon currency-conversion arrangements
• Banking
• Payment providers
• Supplier currency
• Freight currency
• Historical exchange-rate impact
• Hedging arrangements where applicable

Do not convert every marketplace into one headline currency and stop there.

Language, Listings and Customer Expectations

European expansion can involve localisation rather than simple translation.

Review:

• Listing language
• Keywords
• Product titles
• Bullet points
• Images
• A+ Content
• Customer questions
• Product instructions
• Packaging
• Safety information
• Customer support
• Returns communication

A listing that performs well in the UK may not automatically perform well in Germany simply because the text was translated.

Customer search behaviour and competitive positioning can differ.

Returns and Customer-Service Differences

Returns can materially affect marketplace profitability.

Review by marketplace:

• Return rate
• Refund rate
• Return reasons
• FBA return handling
• Merchant-fulfilled return costs
• Cross-border return costs
• Damaged inventory
• Reimbursements
• Product-specific return concentration
• Customer-service metrics
• Consumer-law obligations

A marketplace generating high revenue may produce weaker profit if returns and fulfilment costs are substantially higher.

Ask:

“Which marketplace produces the strongest contribution margin after returns?”

Advertising and Marketplace Economics

Advertising performance should be analysed separately by marketplace.

Review:

• Spend
• Attributed sales
• Orders
• ACoS
• ROAS
• CPC
• Conversion
• Search-term performance
• Branded vs non-branded traffic
• Organic ranking
• Marketplace-specific competition

A keyword that is highly competitive in the US may behave very differently in the UK or Germany.

Do not assume that a successful US advertising structure can simply be duplicated across Europe.

Compare (illustrative structure — no real figures):

Marketplace Concentration Risk

Geographic diversification can reduce dependence on one marketplace.

But concentration should be measured rather than assumed.

Illustrative example:

That is technically a multi-marketplace business.

Economically, it remains heavily dependent on Marketplace A.

Review:

• Revenue concentration
• Profit concentration
• Advertising concentration
• Inventory concentration
• ASIN concentration by marketplace
• Tax dependencies
• Regulatory dependencies
• Fulfilment dependencies

What Business Buyers Should Review

Before acquiring an Amazon business operating internationally, build a marketplace map.

For each marketplace identify:

1. 01Revenue
2. 02Profit contribution
3. 03Currency
4. 04Active ASINs
5. 05Inventory location
6. 06Fulfilment method
7. 07Advertising spend
8. 08Return rate
9. 09Tax registrations
10. 10Tax filing status
11. 11Import structure
12. 12Product-compliance requirements
13. 13Account Health
14. 14Historical enforcement
15. 15Brand / trademark position
16. 16Operational dependencies
17. 17Banking / payment flow
18. 18Customer-service requirements
19. 19Supplier dependencies
20. 20Post-acquisition changes required

Then compare the marketplace map against external records.

Marketplace Due-Diligence Checklist

Common Marketplace Misconceptions

Questions to Ask Before Acquiring a Multi-Marketplace Amazon Business

1. 01Which Amazon marketplaces are currently active?
2. 02Which marketplaces generated revenue during the last 12 months?
3. 03What percentage of total revenue comes from each marketplace?
4. 04What percentage of profit comes from each marketplace?
5. 05Which legal entity operates the Seller Central account?
6. 06Where is that entity genuinely managed and operated?
7. 07Which countries currently hold inventory?
8. 08Which fulfilment programmes are enabled?
9. 09Is inventory moved between countries?
10. 10Which VAT registrations are currently active?
11. 11Are all required VAT returns up to date?
12. 12Is OSS used?
13. 13Is IOSS used where applicable?
14. 14Are any historical tax liabilities unresolved?
15. 15Which entity acts as importer of record?
16. 16Are EORI registrations required and current?
17. 17Can historical customs and import records be provided?
18. 18Which products require regulatory documentation?
19. 19Are current test reports and certificates available where required?
20. 20Which products fall within GPSR or other applicable EU product rules?
21. 21Who is the EU responsible economic operator where required?
22. 22Have any products been removed for compliance or safety reasons?
23. 23What is the return rate by marketplace?
24. 24What is advertising spend by marketplace?
25. 25Which marketplace is most dependent on paid advertising?
26. 26What currency exposures exist?
27. 27Which marketplace produces the strongest contribution margin?
28. 28What operational, tax or compliance details need updating after the acquisition?
29. 29Could ownership or business-information changes trigger Amazon verification?
30. 30Which professional advisers should review the transaction before completion?

Quick comparison

Final Takeaway

Amazon provides infrastructure that can make international commerce look seamless.

The underlying business is rarely that simple.

The US, UK and EU differ in tax systems, customs structures, product regulation, fulfilment arrangements, currencies and operational requirements.

Europe introduces an additional layer because selling across several Amazon stores can involve multiple countries without those countries becoming one identical operating environment.

For an Amazon business buyer, the correct question is therefore not simply:

“How much does this business make?”

It is:

“Where does it make its money, where is its inventory, and what infrastructure is required to keep those sales operating?”

Before proceeding with an acquisition, understand:

• Legal entity
• Marketplace structure
• Revenue by marketplace
• Profit by marketplace
• Inventory geography
• FBA structure
• Tax registrations
• Customs
• Importing
• Product compliance
• Account Health
• Advertising dependency
• Currency exposure
• Returns
• Brand and IP
• Post-acquisition changes

The stronger the due diligence, the clearer the business becomes.

StealthEcom is designed around that principle: information before transaction.