Pan-EU vs EFN: The Break-Even, With Amazon's 2026 Fees

✨ Written with AI assistance from Amazon's published EU rate card and programme pages, and reviewed by Avanta Global EOOD before publication. Learn more

Short answer: Pan-EU beats EFN when the fees it saves on cross-border orders exceed the fixed cost of the extra VAT registrations it brings. For a small parcel up to 400 g, Amazon's July 2026 rate card charges €7.05 through EFN against a local fee of €5.07 in France, €4.54 in Italy, €3.74 in Spain and €3.13 in Germany: a saving of €1.98 to €3.92 per unit, depending on where the buyer is. The cost is one more VAT registration, with its filings, per storage country. Divide one by the other and you have the monthly volume at which Pan-EU pays.

We have not run Pan-EU or EFN ourselves; our only live store is Amazon Australia. Every EU fee below is quoted from Amazon's pages, read on 30 September 2026.

What each programme costs you

Amazon's European FBA page draws the line in two sentences. For Pan-EU: "a VAT identification number is required for each country in which goods are stored." For EFN: "a VAT identification number is generally not required in the destination store."

• EFN: stock sits in one country; sales there pay the local fee, sales in other EU stores pay the cross-border EFN fee.
• Pan-EU: you enable storage in at least two of Germany, France, Italy, Spain or Poland, and Amazon moves stock between them free of charge. Enabled countries pay local fees; stores you have not enabled still pay EFN. The product must be listed with the same SKU in Germany, France, Italy, Spain and (since 3 September 2026) the Netherlands; Belgium joins on 26 February 2027.
• Pan-EU adds a fee EFN does not have: €0.18–0.46 per small parcel when stock falls below 28 days of supply.

The per-unit gap, from the rate card

Small parcel (up to 35 × 25 × 12 cm), two weight bands. "Gap" is the EFN fee minus the local fee in the country where the buyer ordered.

Sold in	EFN fee ≤400 g	Local fee ≤400 g	Gap ≤400 g	Gap ≤900 g
Germany (CEP stock)	€7.05	€3.13	€3.92	€5.31
France	€7.05	€5.07	€1.98	€2.66
Italy	€7.05	€4.54	€2.51	€3.50
Spain	€7.05	€3.74	€3.31	€4.50

Stock kept in Germany only (outside the Central Europe Programme) costs €0.26 more per unit shipped, so EFN from it is €7.31; heavier parcels widen the gap. Full tables: Amazon FBA fees in Europe: which fee applies where. Amazon advertises Pan-EU savings of "up to 53%", its best case across sizes; for this parcel sold in France it is 28%.

The fixed side: what actually changes

Only costs that differ between the two programmes belong in the break-even.

1. VAT registrations in the extra storage countries. A sale from local stock is a domestic sale, and the EU's One-Stop Shop does not cover those: its own example, a sale "from Bulgaria to Bulgaria", goes on the Bulgarian domestic return. So each stocked country means registering and filing there.
2. The Central Europe Programme is the same trade-off in miniature. It saves €0.26 per unit on German stock, but Amazon warns that storage in Poland and the Czech Republic "will trigger VAT obligations and other reporting requirements", under EFN or Pan-EU.
3. Packaging EPR is mostly not part of this decision. Germany's packaging register puts the duty on foreign companies that "ship packaged products directly to end users in Germany", and since 12 August 2026 those without a German branch must appoint a German authorised representative. It follows the buyer, not the stock, so both programmes pay it. We have only checked Germany; if Pan-EU would stock a country you don't sell in, ask whether its scheme applies.

What does a VAT registration cost? We have no quote outside Germany. The only published price list we found is Amazon's VAT Services rate card dated 10 January 2023: €50 to register in Germany, €150 in France, Italy, Spain, Poland or the Czech Republic; €350 a year per country for filing; €250 a year for fiscal representation in France, Italy, Spain or Poland if you are established outside the EU and UK. Those prices are almost three years old: check Seller Central and get an adviser's quote.

The break-even formula

Units per month at which Pan-EU pays = F ÷ (12 × g)

F = extra fixed cost per year for one added storage country (VAT registration spread over the years you expect to keep it, plus filings, plus any fiscal representative) g = EFN fee − local fee in that country, for your size tier and weight

Run it once for each country you would enable. A country only pays its way on the units sold in that country's store.

Illustration, not a measurement. Say a seller stores only in Germany (no CEP) and adds France under Pan-EU. - g = €7.31 − €5.07 = €2.24 per unit sold on amazon.fr - At Amazon's 2023 filing price of €350/year: 350 ÷ (12 × 2.24) ≈ 13 French units a month - At a round placeholder of €1,000/year (not a quote, just a stand-in for adviser fees): ≈ 37 a month

Below that, French stock costs more than it saves. The sum leaves out the low-inventory fee, any conversion lift from faster delivery, and your own time; we cannot measure those from here.

What we got wrong

The earlier version of this page invented its numbers: a "~€3.60" German fee, a "€1.50–2.50" cross-border fee, a "€40,000/year" cost of choosing wrong. It also said Pan-EU charges the same fee wherever the order ships from and needs six VAT registrations. Amazon's page says local fees apply only in countries you enable, and the minimum is two. Every figure here now comes from Amazon's published pages.

Where we stand ourselves

Avanta Global EOOD is based in Bulgaria, which is not a Pan-EU storage country, so any EU stock means a new VAT registration. We applied for German VAT on 9 September 2026 (Finanzamt Neuwied, quoted wait 4–12 weeks). Our EU accounts are open but have never sold. On packaging, our 4 August research put a German authorised representative plus dual-system licence at roughly €700–900/year. That cost applies under either programme. Our plan is EFN from Germany first, adding a country only when its measured sales pass its break-even.

How to run it on your own product

1. Find your size tier and weight band (parcels bill on the greater of real weight and L × W × H ÷ 5,000).
2. From the current rate card, subtract each country's local fee from the EFN fee: that is g.
3. Take monthly units per store, not an EU total.
4. Get written quotes for registration, filing and any fiscal representative per candidate country: that is F.
5. Enable a country only where units exceed F ÷ (12 × g), then check real fees per order in the settlement report. Our FBA fee calculator estimates them before you ship.

FAQ

Is Pan-EU always cheaper per unit? In enabled countries, yes: €3.13–5.07 against €7.05 for this parcel. Elsewhere you still pay EFN. Overall it is cheaper only once volume covers the extra VAT filings.

Do I need a VAT number in every EU country for EFN? Amazon says generally not in the destination store; you need one where the stock sits. Confirm your position with an adviser.

Does the fee gap change my ad targets? Yes. A lower fulfilment fee raises contribution, so break-even ACoS rises. See ACoS vs profit and how a fee change moved ours in the referral fee post.

About this article

Fees: Amazon "Rate Card — Europe Fees, effective as of 1st July 2026" (PDF), pages 6, 10, 12 and FAQ Q14–Q19. Programme rules and VAT lines: sell.amazon.de/versand-durch-amazon/europa. OSS scope: European Commission, OSS. Packaging: ZSVR, online retailers and authorised representative. VAT service prices: Amazon's VAT Services rate card of 10 January 2023 (PDF). All read on 30 September 2026. Our own facts are Avanta Global EOOD records from August–September 2026. Fees and rules change, so check the current versions before acting. We are not accountants, tax advisers or lawyers.