Amazon has alerted both vendors and sellers to prepare for the end of the Brexit transition period on 31 December, 2020. Here is the latest information to help your business ensure a smooth transition with minimal disruption.
On 31 January 2020, the UK left the EU and entered a transition period. During this time, existing arrangements were kept in place with a deadline of 31 December 2020. The UK will formally leave the EU’s Single Market and Customs Union from 1 January 2021. Negotiations between the UK and the EU are ongoing (including determining what tariffs, if any, will apply). However, Amazon has encouraged businesses to plan for a customs border between the UK and EU from 1 January 2021. This change will have an impact on any businesses working across this border in Europe, and all businesses need to think about how to handle this change. As a reminder, businesses will continue to operate as usual until the new year.
The latest details for Amazon vendors
Amazon sent a communication this week to alert vendors that there are less than seven weeks left until the end of the transition period. Starting 1 January, Amazon may not be able to transfer inventory from the UK to EU and vice versa using Amazon’s European Fulfilment Network (EFN). Until there are firm plans in place, Amazon is recommending vendors ship dual inbound.
Ship by dual inbound
In order to reach as many customers as possible, you can ship your products to both an Amazon FC in the UK and an Amazon FC in the EU. As goods will continue to move using EFN within Europe, you can store inventory at one or multiple warehouses there for maximum availability.
Amazon has listed steps for dual inbound shipping on the Brexit Help page in Vendor Central. This checklist summarises the main steps:
- Ensure that you have VAT registrations in place in the territories where these are needed, on the basis that you will act as Importer of Record (IOR) for goods moved into the UK or EU, and your supply to Amazon may be a domestic sale in the ‘ship-to’ or import country depending on your supply chain routes.
- Ensure you have accurate customs data, including the country of origin (COO) information for your products, to complete declarations that are required for cross-border movement.
- Identify the correct Harmonised System (HS) Codes to allow you to make a customs declaration when you bring goods out of or into the UK, and to ensure the correct rate of duty and import VAT is applied. You can find more information here.
- Ensure you have the correct Economic Operator Registration and Identification (EORI) numbers that are needed for your supply chain. If you will only deal with customs declarations in the UK, you will need a UK EORI, but if you deal with customs declarations in the UK and the EU, you will also need an EU EORI. You can find more information here.
- Decide how you want to make customs declarations (g. whether this will be in-house or via a third party), and ensure you are prepared to meet all other customs requirements for your goods, including supporting documentation and customs value.
- Ensure you are ready to comply with all new UK product compliance and labelling requirements (e.g. the new UK Conformity Assessed (UKCA) mark to replace the current Conformité Européenne (CE) marking on Toys/Electronics).
- If you are not the owner of the intellectual property rights (IPR) for the products, make sure you have the consent of the IPR owner to sell products sourced in the UK in the EU.
- In order to ship to an Amazon FC in both the UK and EU, you will need an Amazon vendor account (and vendor code) for both the UK and EU. To complete this step, use Contact Us or your regular Amazon point of contact.
Steps for vendors who don’t want to ship dual inbound
- Determine accurate ‘country of origin’ (COO) information for each of your products. You will need to upload this COO information into Amazon’s ‘Vendor Central’ or ‘Advantage’ catalogues. Amazon is sharing guides on how to do this, which will be uploaded to our Help page soon. You can also get the guide from your Amazon point of contact. If you have gone through the guide and are still facing issues that you cannot resolve yourself, you can raise a request through Amazon’s Contact Us.
- Ensure you meet all new UK product compliance and labelling requirements (e.g. the new UK Conformity Assessed (UKCA) mark to replace the current Conformité Européenne (CE) marking on Toys/Electronics).
We recommend all vendors regularly check the Brexit Help page, which is being updated regularly. Also, watch your email for direct notifications from Vendor Central, or contact your vendor manager, AVS specialist, or submit a contact us via your account.
The latest details for Amazon sellers
Similar to vendors, Amazon is recommending Amazon sellers prepare for Brexit by splitting inventory between UK and EU fulfilment centres to mitigate the impact of Brexit and ensure you have sufficient stock on either side of the customs border. Amazon has created inventory split recommendations in your account that directly correspond to your FBA catalogue. If you have previously sold in both the UK and the EU, you can find out more information about the suggested replenishment process here.
There are a number of resources for both Amazon FBA sellers and Seller Fulfilled Orders on the Brexit Help page in Seller Central.
FBA deadlines and dates to be aware of
As of this week, the deadline for inventory removal orders has passed (ie, removing inventory from UK fulfilment centres to EU addresses and from EU fulfilment centres to UK addresses).
On 18 December, Pan-European FBA inventory transfers will stop between the UK and EU. From this point, you will need to send stock to fulfilment centres in the UK and EU to maintain proper stock levels.
On 21 December, cross-border fulfilment via EFN and Pan-European FBA will start winding down, stopping in full on 28 December.
Amazon Brand Registry and intellectual property impacts
There will be changes in trademark laws due to Brexit. EU trademarks will no longer be valid for the UK and hence brand owners will need to register their trademarks in both UK and EU IP offices. Doing this will ensure Brand Registered businesses will continue to be protected across the UK and EU in Brand Registry.
Product and labelling compliance
The UK Government has announced that it will set up a domestic conformity marking regime, the UKCA, which will take the place of CE marking, the Europe-wide regime, from 1 January, 2021. This does not apply to existing stock, for example, if your goods were fully manufactured before 1 January. For detailed information, refer to the UK government guidelines.
There are also specific new requirements for food and drink labelling, in addition to the general label compliance requirements. You can continue to use the EU oval health and identification mark on products of animal origin (POAO) produced and sold in the UK until 1 January, 2021. From 1 January, you must use the new UK health and identification marks for POAO to clearly show the UK product has been subjected to strict health and welfare checks.
Additional detail on labelling compliance can be found on the Amazon Seller Central Brexit Help pages FAQs.
There is a wealth of information, links to official government resources, and guidelines specific to Amazon located on Vendor Central and Seller Central. We recommend ensuring your business is compliant and contacting Amazon directly with questions well in advance of deadlines, if possible. If you need additional support or account management, please contact us.