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    European regulatory considerations


    When you import goods into the European Union (EU), you will need to comply with EU customs laws, as well as laws and regulations that are applicable to the EU country of import. Please note that you are not authorized to import your goods in the name of Amazon EU S.à r.l. or any other Amazon subsidiary or affiliate (indistinctly referred to as "Amazon" and its corporate name as an "Amazon name") or to reference Amazon anywhere in your shipping documentation. Otherwise, your shipments may be returned to their origin, abandoned, or destroyed at your cost, at the discretion of the carrier or freight forwarder carrying your goods.

    Importation regulations may differ between countries in the EU and will depend on the mode of shipping you choose. Therefore, you should strongly consider hiring a logistics provider, such as a customs broker or freight forwarder, to handle the importation process for your company and help you understand all applicable requirements.

    Commercial invoice
    When your goods are ready to be shipped from your facility, manufacturer, or distributor, the shipper prepares the commercial invoice. It is critical that the commercial invoice be accurate to avoid delays in clearing customs. The following information must be included on the commercial invoice when importing goods into an EU country:

    • Invoice issue date.
    • The complete name and address of the exporter or shipper (seller or manufacturer).
    • The shipper's contact name, company name, address, and tax ID number.
    • Ship-to address. Provide the legal name of your company, followed by "c/o FBA." Below this, you may use the address of the Amazon fulfillment center to which your goods should be delivered. Amazon does not, however, authorize you to include any Amazon name in this address. Please see the example below.
    • Importer of record: Provide the legal name of your company or EU import representative, along with full contact details, Economic Operators' Registration and Identification number (EORI) and VAT registration number for the country of import (example below). Prior to shipping, you should consider ensuring that your company or representative can fulfill all criteria to act as importer of record in the country of import.

    Amazon expressly prohibits the use of an Amazon name, including a fulfillment center's name, as the importer of record for any shipment of FBA inventory. Any FBA inventory shipment attempting to make entry with an Amazon name as the importer of record will be refused and returned at the shipper's expense—no exceptions.

    Leaving this information blank also can result in your shipment being refused and returned.

    Example "Ship to/Deliver to" field

    Example "Importer of record" field

    [Seller legal name] c/o FBA
    1401 Rue du Champ Rouge
    45770 Saran, France

    [Seller legal name] or [Seller's
    representative legal name]
    1234 Rue de Lyon
    9876 Paris, France
    EORI: XY123456789
    VAT ID: YX87654321

    Please note the differences in addresses. The "Ship-to" address includes the Amazon fulfillment center, while the "Importer of record" address includes the seller's or seller representative's registered address.

    • FBA Shipment ID (FBA reference). This is the number you receive when you create the shipment in your Amazon seller account. This ensures that Amazon can quickly identify the shipment as belonging to FBA if customs questions arise. If your FBA Shipment ID in Seller Central does not contain "FBA," please add it in a visible place on the invoice.
    • Detailed description of the goods invoiced. Includes, among other required elements, the following:
      • Harmonized Tariff Schedule Code (HTS Code)
      • Product quantity
      • Value of each product. For samples or products with no commercial value, a nominal or fair-market value must be stated for customs purposes
      • Total value of all products in a shipment 
    • Currency of the transaction

    Additional information may also be required. These requirements are subject to change. It is your responsibility to determine and comply with import requirements.

    Depending on the type of product, there may be additional certificates and licenses required for import. These can include a Declaration of Conformity, test reports or leather certificates.

    Please note that the document requirements listed above are in addition to the system-generated document requirements specified in the Shipment Creation Workflow.

    Please check with your logistics provider or customs broker to ensure that you have the complete documentation needed to import into the EU destination country.

    Shipping best practices
    Amazon fulfillment centers have requirements for the shipments they receive, including the size of the pallets and the type of truck that can deliver to the fulfillment center. The How to Ship Inventory to Amazon guidelines provide information needed for preparing your shipment to an Amazon fulfillment center. Paying attention to these requirements and best practices will help avoid delays in getting your inventory to the fulfillment center and into your customers' hands.

    Using standard postal services
    Using postal services such as China Post, Royal Mail, Parcelforce, and Deutsche Post to send your shipments to Amazon fulfillment centers is not recommended. Postal services may have different importer of record requirements for their shipments than for freight or express carrier shipments. It is possible that by using postal services to ship your goods, you could not ship to an Amazon fulfillment center as the IOR. If you are considering a postal service as a shipping option, you should consider sending the shipment to the address of your representative in the country of import and, after the shipment is delivered, forward the goods to the Amazon fulfillment center address. Prior to shipping, you may want to check with the postal service that your company or representative can be the importer of record.

    For additional information regarding FBA imports and exports, please read the Importing and exporting inventory page.

    Intellectual property rights

    You should ensure that you have all intellectual property rights (such as patents, trademarks, or copyrights) necessary for listing your products in Europe or selling them cross-border within Europe. You may need to have the permission of the brand owner to sell their products in a given European member state in order to avoid an infringement of intellectual property rights (as in the case where your license to the intellectual property is only valid for a specific country). In particular, your products must not be counterfeit or illegal parallel imports.

    You should investigate the law governing intellectual property for every country where you want to list your products because your rights in intellectual property may only be valid for a particular country.

    In addition, you may want to protect your own intellectual property in Europe.

    Parallel importation

    Trademark owners may be able use their trademark rights to prevent re-sale in the European Economic Area (EEA) of genuine branded goods sourced from outside the EEA 2, even if the non-EEA seller has purchased the goods outside the EEA from an authorized distributor or the trademark owner.

    However, the trademark owner’s rights may generally be “exhausted” (for instance, the trademark owner can no longer rely on its trademark rights) in respect of goods placed within the EEA by the trademark owner or with the trademark owner’s "consent."

    The "consent" must in principle relate to each individual product imported and sold in the EEA. Trademark rights may therefore generally not be exhausted simply by the proprietor having consented to the sale of other, identical branded goods within the EEA.

    Even when the goods have been placed in the EEA by the trademark owner or with the trademark owner’s consent, the trademark owner may have "legitimate reasons" for objecting to the re-sale of the branded goods.

    Situations that may qualify as “legitimate reasons” include, but may not be limited to any of the following:

    • The branded goods have been altered by the reseller.
    • The branded goods have been repackaged by the reseller.
    • The reseller’s advertising of the goods in some way denigrates the goods or the trademark.

    Whether trademark owners may use their trademark rights to prevent re-sale in the EEA depends on the specific circumstances of each case, and we strongly recommend that you consult legal counsel to determine whether your products may be legitimately sold in the EEA.

    Markings and labels

    The “CE” mark is a mandatory conformance mark on many products (such as low-voltage equipment, medical devices, toys, personal protective equipment, and so on). By attaching the “CE” marking, the manufacturer declares that the product is in conformity with the requirements of the applicable European directives.

    There are many other marks and labels in Europe (for example, textiles, products in contact with food, recycling, and so on), which you may be required to display on your products or packaging. Often product labelling is required to be in the language of the European member state where the product is sold.

    Environment, health and safety

    Chemicals – REACH/CLP
    REACH is the European regulation on chemicals and their safe use. It deals with the Registration, Evaluation, Authorization and Restriction of Chemical substances. Under the REACH regulation, one of the things manufacturers and importers may be required to do is to gather certain information on the properties of the chemical substances in their products, and to register the information in a central database run by the European Chemicals Agency (ECHA).

    In addition to REACH, the Regulation for Classification, Labeling, and Packaging of Substances and Mixtures (CLP Regulation) may apply to your products. The CLP Regulation incorporates the classification criteria and labeling rules agreed at the United Nations level, the so-called Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS is based on the principle that the same hazards should be described and labeled in the same way all around the world.

    Electrical and electronical equipment – WEEE / RoHS
    If you are selling electrical or electronic equipment, you may be subject to the European legislation concerning Restrictions of the Use of Hazardous Substances (RoHS) and/or the collection and recycling of Waste Electrical and Electronic Equipment (WEEE).

    The following are examples of requirements in the WEEE regulations that you may be subject to:

    • Displaying the “crossed-out wheeled bin” symbol on your products. The symbol indicates that the product should not be disposed of as normal waste, but rather in specific recycling centers.
    • Joining an authorized WEEE collection and recycling scheme in any European member state in which you sell applicable products.

    If you sell batteries or products that contain batteries, you may be subject to the Battery Directive. The Battery Directive imposes specific obligations on producers and distributors of batteries.

    The following are examples of requirements you may be subject to:

    • Displaying the “crossed-out wheeled bin” symbol on your batteries. The symbol indicates that the battery should not be disposed of as normal waste, but rather in specific recycling centers.
    • Joining an authorized battery collection and recycling scheme in any European member state in which you sell your batteries.

    Packaging and packaging waste
    Packaged products you sell in Europe must comply with the European Packaging and Packaging Waste regulations.

    The following are examples of requirements you may be subject to:

    • Joining an authorized packaging collection and recycling scheme in any European member state in which you sell your products.
    • Displaying recycling symbols on your packaging (for example, the “green dot” symbol).
    Product compliance

    Plugs and voltage
    Countries in Europe use different types of plugs—for instance, the U.K. 3-pin rectangular plug and the continental European 2-pin round plug. In addition, products you import into Europe might work on a different voltage.

    Please ensure that you comply with the regulations on plugs and voltage in any European member state in which you list your products. In particular, your customers should be able to safely use your products. For more information regarding what plugs and sockets are accepted in EU fulfillment centers, visit the Electrical Goods Requirements: Plugs and Sockets help page (Seller Central Europe account required).

    The European Toys Safety Directive requires, among others things, that it must be possible to use a toy without any danger to one’s health or safety during the toy’s foreseeable and normal period of use. You may also be required to place warnings on the products that specify the appropriate conditions and limitations of use.

    Medical devices
    Medical devices range from simple products like bandages to the most sophisticated life-supporting products. If your product is considered a medical device, you may be subject to the European Medical Devices Directive. The Directive requires, among other things, that medical devices shall not compromise the safety and health of patients, or users and other persons when properly implanted, maintained, and used.

    Pharmaceuticals and cosmetics
    Pharmaceuticals and cosmetics are subject to various regulations in Europe, including special labeling and packaging requirements. The regulations are only partially harmonized. For example, a product may be sold over-the-counter in some European member states, while in others it may only be legally sold in pharmacies.

    Food and food products are subject to many regulations in Europe. European food regulations in particular aim at establishing high-quality standards for food and food product hygiene, animal health and welfare, and plant health, and prevent the risk of contamination from external substances.

    European food regulations include, among many other things, the following:

    • Specifying rules on appropriate labeling for food products. Often product labeling is required to be in the language of the European member state where the product is sold.
    • Establishing mandatory refund and recycling schemes for beverage packaging in several European member states.

    More: Restricted products for import into the United Kingdom

    Consumer rights

    Please note that these consumer rights are described for illustrative purposes only and do not constitute any legal advice or substitute for any contractual obligation that you may have agreed upon with Amazon or directly with the consumer. To learn more about rules that apply to international sellers, check out Global Selling International Seller Rules here.

    Rights of cancelation
    With some exceptions, consumers in the European Union have the right to cancel a purchase of a product bought online within 14 days of receiving the final item of the order, if they purchased multiple items together that were delivered separately. Even when there is no error from your side, you must refund the item and the shipping costs. You may not have to refund all costs unless one of the following is true:

    1. There is an error on your side.
    2. You agreed to bear all costs for the consumer.
    3. You failed to disclose or inform the customer about the costs that you are legally required to disclose.

    For example, you must refund the normal cost of sending the item to the consumer but not any extra costs for services that the customer chooses, such as expedited delivery or gift-wrapping. Similarly, when you expressly inform the consumer, you don't have to bear the cost of returning the product to you.

    Please note that these consumer rights are in addition to any contractual return rights that you may have agreed upon with Amazon (e.g. 30-day return guarantee) or directly with the consumer.

    Legal warranty
    In the EU, you are required by law to give customers a warranty stating that the products you sell are free from faults and are as advertised (i.e., conformant with the contract). Standards exist to assess when products do not conform to the contract. If the products do not conform, customers can request a free repair, replacement, or refund following a sale. The warranty period will vary depending on the country. Most EU countries provide for a minimum period of two years from the date the customer received the product. The United Kingdom, however, requires a "reasonable time" following the sale that will vary depending on the product and its value.

    The period during which you can receive a warranty-related claim from a customer also varies by country. For example, parties to a contract in England and Wales have up to six years to bring a claim from the date on which their rights were infringed; a customer thus may claim that a product is faulty six years after receiving it.

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