Sept 3
2026, the date the Netherlands offer became required for Pan-EU FBA
Feb 26
2027, the date Belgium is added to the same requirement at enrolment
30 days
minimum notice Amazon says it gives before each requirement applies
Key takeaways
- Since 3 September 2026, every Pan-EU FBA product needs an active offer in the Netherlands, new and existing alike.
- From 26 February 2027 the same requirement adds an active offer in Belgium at enrolment.
- Amazon says it gives at least 30 days of notice before each requirement takes effect.
- An ASIN that falls out of Pan-EU keeps selling and loses the local fulfilment fee. The sales report shows nothing.
- Exemptions exist for products that are restricted locally or that fail local language labelling rules.
The Pan-EU FBA Netherlands requirement is not a warning about something coming. It took effect on 3 September 2026, which was twenty days ago, and it applies to existing Pan-EU products as well as new ones. If an ASIN of yours has no active offer on amazon.nl today, the question is not whether to plan for it. It is which of your ASINs already fell out of the programme.
What changed, and when
Amazon announced that Netherlands offers are now required for Pan-EU Fulfilment by Amazon products. The rule adds one condition on top of the existing listing requirements: an active offer in the Netherlands.
The same announcement sets the next date. From 26 February 2027, an active offer in Belgium is required at enrolment too.
Amazon says it notifies sellers at least 30 days before each requirement takes effect. That notice for the Netherlands went out in the summer, which is exactly when nobody reads programme emails.
Why this costs money rather than time
Pan-European FBA is the programme that lets you place inventory in the countries you choose and pay the local fulfilment fee instead of a cross border one. The Pan-European FBA help page is explicit that the lower fulfilment cost is the point of it, and that storage in Germany is what unlocks the local fees in the Netherlands and Sweden.
So an ASIN that drops out of Pan-EU does not stop selling. It keeps selling at a different cost per unit, in the quarter where your unit economics matter most. Nothing in your sales report announces it.
The compliance cost nobody prices in
Adding an active offer in the Netherlands is not only a listing action. That offer is a Dutch offer, and the Dutch compliance checks apply to it.
Packaging is the one that bites first. We covered how Amazon widened its packaging EPR registration check across the EU in August: without the registration number for that country, the offer gets deactivated there. Creating an NL offer to stay in Pan-EU and then having it suppressed for a missing EPR number leaves you in exactly the same place, minus the work.
The product side has its own list. The responsible person field for EU listings and what the PPWR already binds today both apply to a Dutch offer the same way they apply to a German one.
The exemption route
Amazon states that sellers may be eligible for an exemption, for a limited or unlimited period, to the listing requirement in select cases. The examples given are products that are restricted or cannot be sold in those countries, and products that do not meet local language labelling requirements.
Language labelling is the one worth reading twice. If your packaging carries no Dutch text and the category requires it, the exemption route is the correct path, not a rushed listing.
What to do this week
- Open Inventory, then Manage FBA Inventory, and pull the Pan-EU eligibility report. It tells you which ASINs are enrolled and which are not.
- For every enrolled ASIN, check whether an active offer exists on amazon.nl. Not a listing. An active, buyable offer.
- For the ASINs without one, decide per ASIN: create the Dutch offer, or request the exemption if the product genuinely cannot be sold there.
- Before you create the offer, check the Dutch packaging EPR registration is in place. Creating an offer that gets suppressed a week later is the worst outcome.
- Put 26 January 2027 in the calendar. That is a month before Belgium, which gives you the window Amazon says it gives.
What we could not confirm
Amazon's announcement posts and the programme help page are consistent on the dates and on the requirement. What we could not open directly today is the Seller Central help pages behind login, so the exact wording of the exemption form and the treatment of ASINs that were already enrolled before 3 September should be checked in your own account before you act on a large catalogue. Sellers reporting their own cases in the Seller Central Europe thread on the Netherlands requirement are the fastest read on how it is landing in practice, but a forum thread is not the policy.
If you are moving inventory into Europe for Q4 anyway, this pairs with how AWD landed in Europe for bulk storage: the placement decision and the programme eligibility are the same decision made twice.
Sources
- Amazon Seller Central, Pan-European FBA: How it Works sellercentral-europe.amazon.com
- Amazon Seller Central, Netherlands offers now required for new Pan-EU Fulfilment by Amazon products sellercentral.amazon.com
- Amazon Seller Central, Pan-EU FBA to require Netherlands and Belgium offer sellercentral.amazon.com
- Amazon Seller Central Europe, hilo de vendedores sobre el requisito de Países Bajos sellercentral-europe.amazon.com
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