Amazon Brand Registry in the EU: The Complete Guide for Sellers
14 December 2025
Navigating Amazon Business (B2B) Sales and Fulfillment in Europe
14 December 2025
OUR GOAL
To provide an A-to-Z e-commerce logistics solution that would complete Amazon fulfillment network in the European Union.
For e-commerce brands scaling across Europe, success is a double-edged sword.
One day, you are celebrating a record-breaking month of sales to customers in Germany, Italy, and Spain. The next, you receive a formal letter from the customs administration or a notification from your accountant: you have crossed a "statistical threshold," and your paperwork load just doubled.
Welcome to the world of Intrastat—or, as it is known in France since the 2022 reform, the EMEBI (Enquête Mensuelle sur les Échanges de Biens Intra-Union européenne).
While most online sellers are familiar with VAT returns and the One-Stop Shop (OSS), Intrastat remains a source of confusion. Is it a tax return? Is it a customs declaration? Why do you have to tell the government how much your pallets weigh?
Ignorance here is not bliss. Failing to report can lead to fines, audits, and blocked VAT refunds. Conversely, mastering this flow is a sign that your logistics and data management are mature enough to handle European expansion.
In this article, we will break down exactly what the EMEBI is, how the rules changed in France (replacing the old DEB), when you actually need to file, and how a professional logistics setup can turn this administrative burden into a simple monthly click.
What Exactly Is Intrastat (and Why Does It Exist)?
To understand Intrastat, you have to go back to 1993. Before that date, moving goods from France to Germany required a customs declaration, just like shipping to the US or China today. When the EU Single Market abolished internal borders, customs stops disappeared—but the need for data did not.
Governments still needed to know what goods were moving, where they were going, and how much they were worth to calculate trade balances and economic health. Intrastat was born as a system to collect this data directly from companies without stopping trucks at the border.
The "New" French System: From DEB to EMEBI
For decades, French companies filed a DEB (Déclaration d’Échanges de Biens). It was a unique hybrid form that combined two things:
Fiscal data: Used to track VAT compliance and check for tax fraud (recapitulative statement).
Statistical data: Used by customs to build trade reports.
On January 1, 2022, this system changed. France aligned itself more strictly with EU regulations (specifically the EBS Regulation 2019/2152) and split the DEB into two separate obligations:
The VAT Recapitulative Statement (État Récapitulatif TVA): This tracks intra-EU sales for tax purposes. It is mandatory for every intra-Community dispatch from the first euro.
The EMEBI (Enquête Mensuelle sur les Échanges de Biens Intra-Union européenne): This is the purely statistical survey. Unlike the tax statement, not everyone has to file it. You only file it if you are selected by the administration based on your volume.
This separation is crucial. It means you might be submitting tax data every month but only be asked to provide the heavy statistical detail (weights, codes, transport modes) if you are a "big enough" player.
The Trigger Point: When Do You Have to File?
This is the most common question for growing e-commerce merchants: “My sales are up—do I need to file an EMEBI next month?”
The answer depends on whether you are looking at France specifically or your obligations in other EU countries where you might hold stock (like Germany or Poland).
In France: The "Sample" System
Unlike many other EU countries that have public, automatic thresholds (e.g., "if you sell €400,000, you must file"), France now operates on a notification basis.
At the beginning of each year, the French Customs Administration (Douane) selects a sample of companies to respond to the EMEBI survey.
How they pick you: They look at your VAT returns and past trade volumes. If your intra-EU arrivals (imports) or dispatches (exports) are significant—historically around the €460,000 mark, though this is no longer a strict legal "trigger" in the same way—you are added to the list.
The Letter: If selected, you will receive a registered letter (Lettre Avis) informing you of your obligation.
The Duration: Once selected, you must file the EMEBI every month for the calendar year, even if your volume drops in a specific month.
In Other EU Countries: The Fixed Thresholds
If you use Amazon FBA or a 3PL network with warehouses in Germany, Italy, or Spain, you might have local Intrastat obligations there, too. Most of these countries still use a hard threshold system.
Examples of 2024/2025 Annual Thresholds:
Germany: €500,000 for dispatches / €800,000 for arrivals.
Italy: €0 for dispatches (optional statistical part under certain limits) / €350,000 for arrivals.
Poland: 2.8 Million PLN (approx. €650k) for dispatches / 6 Million PLN for arrivals.
Netherlands: Automatic selection based on VAT data (similar to France’s new logic).
Pro Tip: Never assume the rules are the same across borders. Just because you don’t file EMEBI in France doesn’t mean you are exempt from Intrastat in Germany if you hold stock there.
The Anatomy of an EMEBI Declaration: What Data Do You Need?
If you receive that letter from French Customs, the complexity of your monthly reporting jumps significantly. A standard VAT report just asks for "Total Sales to EU." The EMEBI asks for the DNA of your supply chain.
For every type of product you shipped or received, you may need to report:
1. The Commodity Code (CN8)
This is the Combined Nomenclature code—an 8-digit string that classifies your product.
Example: A cotton t-shirt is
6109 10 00. A polyester one is6109 90 20.The Challenge: If you sell 5,000 SKUs, you need 5,000 accurate codes. Using a generic "clothing" code is a fast track to an audit.
2. The Net Mass (in kg)
You must report the weight of the goods excluding packaging.
This sounds simple until you realize your e-commerce platform often only stores the gross weight (product + box) for shipping labels. You need clean data on the product itself.
3. Supplementary Units
For certain goods (like shoes, liters of wine, or pieces of electronics), Customs wants the quantity in units, not just weight.
4. Country of Origin
Not the country of shipment. This refers to where the product was manufactured.
If you import goods from China, store them in France, and ship them to Belgium, the Country of Origin is CN (China), not FR. This is a common error on Intrastat forms.
5. Nature of Transaction
Are you selling the goods? Moving your own stock to another warehouse (Amazon FBA transfer)? Processing them? Returning them? Each scenario has a specific 2-digit code (e.g., Code 11 for outright purchase, Code 21 for return).
6. Mode of Transport
Did the goods leave the border by truck, train, plane, or ship? For most intra-EU e-commerce, this is "Road" (Code 3), but it must be specified.
Why This Breaks Manual Workflows
For a small merchant shipping 50 orders a month, looking up a few HS codes is manageable.
For a scaling brand shipping 5,000 orders a month to 15 different countries, doing this manually is impossible. The data lives in different places:
Sales value is in Shopify/Magento.
VAT IDs are in the order confirmation.
Weights and dimensions are in the WMS (Warehouse Management System).
Country of Origin is often buried in a supplier spreadsheet.
The "Excel Nightmare": We often see brands trying to cobble this together on the 8th of every month. They export a CSV from Shopify, realize half the products have missing weights, guess the HS codes, and pray the total matches their VAT return.
This approach is risky. Discrepancies between your VAT return (ERTVA) and your statistical return (EMEBI) are the #1 trigger for tax audits.
The Role of Your Logistics Partner
This is where your choice of logistics partner moves from "operational" to "strategic."
A standard warehouse moves boxes. A tech-enabled 3PL manages data. When your fulfillment provider understands the compliance landscape, they structure your inventory data from day one to make reporting effortless.
Data Hygiene at Reception
At FLEX. Logistique, we know that you can't report what you don't measure. That is why during the Inbound (Reception) process, we don't just count items. We can verify master data such as net weight and dimensions. If your supplier says a box weighs 0.5kg but it actually weighs 0.7kg, we catch it. This ensures your Intrastat mass declarations are accurate to the gram.
Seamless WMS Reporting
The "Nature of Transaction" is often the hardest part for e-commerce sellers. Was that shipment a sale to a consumer? A B2B transfer to a retailer? A stock transfer to Amazon Germany? Because our myFLEX WMS integrates directly with your sales channels, we can distinguish these flows. You can generate reports that segment orders by destination country, carrier mode, and SKU details, giving your accountant exactly what they need to file the EMEBI without the guesswork.
Consequences of Non-Compliance
What happens if you ignore the letter or file "garbage data" just to make the deadline?
Direct Fines: In France, the fine for a missing declaration starts at €75 per return, increasing to €150. If you persist after a reminder, it can go up to €2,250 per month.
Per-Error Penalties: There is a potential fine of €15 for every error (e.g., wrong HS code) up to a cap. If you have the wrong code on 1,000 lines, the math gets ugly.
VAT Refund Blocks: This is the "hidden" penalty. If you are a net exporter requesting a VAT refund from the French state, they will check if your statistical obligations are up to date. No EMEBI? No refund check.
The "Black Mark": Consistent non-compliance flags your company for broader tax audits. If they can't trust your statistical data, they won't trust your profit and loss statement either.
Strategic Tips for Managing EMEBI
If you are approaching the volume where EMEBI is likely (approx. €460k/year in intra-EU flows), take these steps now:
Audit Your HS Codes: Do not wait for the deadline. Review your product catalog. Do you have a valid 8-digit CN code for every SKU? Are they updated for 2025? (Codes change every year!).
Centralize Data: Ensure your ERP or WMS is the "source of truth." Do not keep weights in one app and origin countries in another.
Monitor "Arrivals" vs. "Dispatches": Remember that buying goods from a supplier in Poland and bringing them to France counts as an "Introduction." You might trigger the obligation purely on your sourcing volume, even if your sales are domestic!
Automate: Use software that scrapes your order data and formats it for the customs portal (DEBWEB2 in France).
The transition from a small local seller to a pan-European brand is marked by milestones. The first 1,000 orders. The first international carrier contract. And yes, the first Intrastat/EMEBI declaration.
While it feels like red tape, it is actually a sign of growth. The key is not to let the administrative weight slow down your commercial momentum.
By understanding the rules—and partnering with a logistics provider like FLEX. Logistique that treats data with the same care as your physical products—you can ensure that when the Customs Administration sends you that letter, your answer is already ready.
Your focus should be on opening new markets, not weighing t-shirts. Let your systems handle the rest.
