Amazon and Brexit: What You Need to Know in 2021

If your Amazon business sells to customers in Europe, or you are considering expanding to Amazon UK or any of the European marketplaces, it's important to understand how Brexit impacts your business in 2021. In this webinar, Amazon experts Jérôme de Guigné of e-Comas and Carina McLeod from eCommerceNurse discuss the changes with Amazon fulfillment effective January 1, 2021, and provide strategies for FBA sellers to succeed in a post-Brexit world.

Watch the webinar to learn:

Trade challenges from the separation of the UK and EU
Tips for navigating changes with Amazon fulfillment and logistics in the EU and UK
VAT implications
Differences in product compliance in the EU and UK
How to protect your brand with a UK trademark
Resources to help sellers with the Brexit transition

You can watch the webinar above or check out the show notes below for the recap and a full transcript.

Webinar Recap

How well do you understand Brexit? If you’re considering expanding to Amazon UK or any of the European marketplaces, or you’re already selling to customers in Europe, you need to understand how your business will be impacted in 2021.

eComEngine hosted Amazon experts Jérôme de Guigné of e-Comas and Carina McLeod from eCommerce Nurse to discuss changes to Amazon fulfillment in Europe effective January 1, 2021. Plus, they cover strategies for FBA sellers to succeed in a post-Brexit world. You don’t want to miss this!

Brexit Trade Challenges

Before Brexit, Amazon Europe was like one big family that included the UK, Germany, France, Italy, Netherlands, Spain, and Sweden. Now, sellers will have to view them separately as Amazon UK and Amazon Europe.

As McLeod explained, “Where businesses before were able to take advantage of this European fulfillment network and the single market within the EU and the free movement of goods, that's no longer...that's the biggest challenge now that businesses are hit with, which then brings in a number of different challenges when it comes to trade.”

Things are changing every day. According to de Guigné, “It's very important to be agile to be successful on Amazon, but even more today...we don’t know how things will react. The complexity of doing business in Europe has grown. The companies which thrive today are the ones which are able to change quickly. And to that extent, the bigger companies are suffering more than the smaller companies.”

Due to the ambiguity that still exists, some businesses have stepped away from Amazon Europe right now to focus solely on Amazon UK. “At the same time, there are businesses that have fully invested and have already planned for Brexit, setting up and making sure that they can manage their business within the UK and within Europe,” said McLeod.

Brexit's Impact on Amazon Fulfillment

There is a lot of uncertainty surrounding fulfillment options for Amazon UK and Amazon Europe sellers. Whereas businesses could rely on the European fulfillment network and its free movement of goods before Brexit, it’s now unclear how that free trade agreement will work.

As McLeod pointed out, “There are borders now, there’s still customs. That free movement that [allowed customers to receive] a product from Germany the next day, we don't know if that's going to happen. That's a bit of the unknown. And the biggest challenge for businesses right now is that effectively there's a border between the UK and Europe.”

On top of that, there may also be tariffs and customs when importing between Europe and the UK. As a result, you may have to split your shipments if you choose to remain in both markets. The problem? “Now, you have to have two stocks,” says de Guigné. “More stocks means more costs. Brexit, from a business point of view, means a lot of costs. And most probably, you will have to look at your pricing — the logistics cost of Amazon or moving things around will impact your margins.”

Editor’s note: Amazon is reactivating the European Fulfillment Network (EFN) between the UK and the EU starting in May 2022. Cross-border orders of eligible FBA products will once again be fulfilled, subject to EFN fee changes.

How UK Trademarks Protect Your Brand

If you thought trademarks were a headache before, they’ve become even more complicated now. McLeod explained that brand registration will be separate for the UK and EU; businesses will need to get each trademark if they plan to sell in both markets — which can be an additional cost.

The good news, she noted, is that “for businesses that already have an EU trademark, the UK will automatically be creating a UK trademark. Amazon Brand Registry has also said that they'll automatically manage all of that in the background.” Of course, things may not transition smoothly; it’s important to verify that your UK trademark is in the Brand Registry.

“To be clear, the system hasn't been changed per se,” said de Guigné. “It's just the recognition of the old trademark system that has to change because the law has changed.” You always had the option to register your UK brand, French brand, and also the EU one. It’s just that the process of securing the new UK and European trademarks will take more effort.

Watch the Webinar

While this recap has touched on some of the most important highlights, there’s so much more to learn from watching the webinar. One major topic discussed is compliance. Will you need UK-specific compliance marking as well as European marking? What about fines? There’s so much to consider!

Selling in Europe has definitely become more complicated, but if you’re flexible and prepared, you can be successful. Trying to understand everything can be overwhelming, but the guidance from these Amazon experts in this informative webinar can help. You’ve got this!

May 2021 update: Chris MacNeil of ResilienceHelp.com wrote an article about customs challenges that sellers are facing post-Brexit.

Recommended Resources From This Webinar

Amazon’s Brexit Selling Partner Guide and Checklist
New UK VAT rules effective Jan 1, 2021
Talk to a tax expert such as Avask, Global e-Commerce Experts, or Simply VAT
Manage your FBA inventory in the UK, EU, and beyond with RestockPro

Colleen: Okay, good morning and good afternoon, depending on where you are located in the world. Thank you so much for joining us today for our webinar on Amazon and Brexit, What You Need To Know In 2021. So now that the UK and EU have separated, there are a lot of changes that Amazon sellers need to know about. There are trade challenges, there's still a lot of ambiguity. And of course, Amazon fulfillment has changed as well in addition to all the changes that have taken place with the UK and EU separation. So luckily, we have two of our good friends in the industry and Amazon experts with us today, Carina and Jérôme. So just to give you a little bit of background of our friends, Carina is an Amazon consultant and expert. She actually spent about seven years at Amazon in the retail and vendor management space. And she's the founder of eCommerce Nurse and vendor society where she and her team helped both the Amazon sellers and vendors to grow their business on Amazon.

Colleen: And Jérôme has a lot of experience in brand management and distribution. He has 20 years of sales and international distribution experience in Europe, Asia, and North America. And he is the founder of eCommerce which specializes in helping major multinational brands to grow their brand and sales on Amazon. My name is Colleen Quattlebaum from eComEngine. I'm the Marketing Manager here. And so we have a couple different tools that I'll just briefly tell you about before we jump into the meat of our presentation today.

Colleen: Two of our tools that are available to Amazon sellers in many different marketplaces; FeedbackFive is a feedback and review management tool available in 16. Amazon marketplaces, and RestockPro is an FBA inventory management software tool that supports sellers in nine Amazon marketplaces. It allows sellers to do everything from inventory forecasting, profit management, shipments, stickers and labeling, carting, really just the whole Start to Finish of your whole FBA inventory management process. So two great tools. If you want to learn anything more about them, please just let me know. But today's agenda includes again, our experts, Carina and Jérôme who are here to talk about the changes that went into effect January 1st. We're obviously at what today is January 7, so about a week in already. But with the holidays, and New Year's and we wanted to make sure we could get as much attendance as possible.

Colleen: So today is our webinar, but we're already a few days in and we will give you an update on some of those changes that have gone into effect, regarding fulfillment and logistics, also, just the trade challenges that come along with Brexit: the implications and what you can do as an Amazon seller or brand owner to make sure that your products are compliant in both the UK and the EU. So there's several things that you need to do to make sure you're protecting your brand in both areas. And then we have some helpful resources to help you with this transition.

Colleen: Before we get started, I would like to just launch a quick poll. We want to just find out a little bit more about where you are located, so we can understand our audience a little bit more and make sure that we are speaking to the group appropriately and making sure that we can answer questions that might be more relevant based on where you're located. Okay, so it looks like 65% are based in the US, 21% on this call are based in the UK, 6% in the EU, and 9% in other areas. Thank you all so much for just taking that poll. We certainly appreciate it. And now we will go ahead and jump into the first question. I'm going to go ahead and close my slides, because this is going to be more of a casual conversation. We really just want to hear from Carina and Jérôme directly and see their faces as we're talking.

Colleen: So let's kick this off with our first question. Again, a lot of changes went into place, January 1st. So can you tell us a little bit about the trade challenges that have come along with Brexit for Amazon sellers and any fulfillment changes that we need to know about?

Carina: Really, I think the first thing to really highlight with Brexit and the way businesses are now working with Amazon, is that before businesses, we're looking at Amazon Europe, and that included the UK, Germany, France, Italy, Spain, and all the new marketplaces. Now it's about looking at Amazon, as in Amazon UK, and Amazon Europe, and that's a key thing to highlight where there's this. Unfortunately, there's this separation now. And so where businesses before were able to take advantage of this European fulfillment network and the single market within the EU and the free movement of goods, that's no longer. So that's something that's the biggest challenge now that businesses are hit with, which then brings in a number of different challenges when it comes to trade. But before we probably go into more trade, I don't know, Jérôme, if you want to add to that, in terms of the overall hit that sellers are finding right now.

Jérôme: Yes, it's like we tend to say the Amazon is a complicated beast and to do business with Amazon is always a challenge, and if you're doing business on Amazon, you know that. Usually, the rest of the world is more simple and Amazon is complex. And this situation has made the outside world actually has been more complex than Amazon itself. And it's, to be fair, there's a few things which are clear for today. But it's unclear if the clarity of today will be the clarity of tomorrow, if that makes sense. And that, it's very important to be agile, to be successful on Amazon, but even more today. So it means a lot.

Jérôme: Some things are, we believe are clear, but we don't know how things will react. And the deal which has been done is clear, to some extent, but very unclear to a lot of extent. So it's the complexity of doing business in Europe has grown, that's for sure. And more than a given truce, which will be true for a long time. It's more about, okay, today's truce, and taking decision with the right information for today, but also being ready to change that. The companies which thrive today are the ones which are able to change quickly. And to that extent, the bigger companies are suffering more than the smaller companies, that's for sure.

Carina: Yeah, definitely. And just to sort of jump on to that we've companies, what we're finding is that there are businesses that because of that ambiguity that still exists, some businesses have decided to step away from Amazon Europe right now, and solely focus, maybe UK businesses, and maybe some of those listening today are businesses that were in Europe, in other parts of Europe, but have decided to pause on that, and just focus on the UK for now, because of not really being sure of what that really means. At the same time, there's businesses that have fully invested and have already planned for Brexit, setting up and making sure that they can manage their business within UK and within Europe.

Carina: And I guess then that moves on to Colleen, what you mentioned about trade, and that the real impact here, as I mentioned with the European fulfillment network, is this free movement of goods, where before a business might have been holding their inventory in the UK, and then listing their products on France, Italy, and Spain. And then when a customer, for example, in Spain places an order, the inventory is then pulled from the UK, over to Spain. And so that's been great for businesses, because it really holds minimum risk, they've been holding inventory in one location. If they're under a certain threshold, they've only, let's say been VAT registered in one country. And it's been less complicated. And of course, that changes. Although, there's been this free trade agreement, we're still unclear what that free trade agreement really means. But there's still an element of bureaucracy.

Carina: There's still borders now, there's still customs. And so that free movement that was just could be like you almost received a product from Germany the next day, we don't know if that's going to happen, and that's a bit of the unknown. And the biggest challenge for businesses right now is that effectively there's a border between the UK and Europe.

Jérôme: Yeah, and the funny thing is that you have a border but no customs and so no customs duty or no tariffs. So basically, for products, you have to make a difference. Products which are produced in either the UK or Europe will have no customs tariffs. However, if you import a product from outside of Europe, then if you import it in the UK for example, you will have to pay for customs in the UK. And then if you want to move them again to Europe, then you will have to pay customs for the rest of Europe. So it does like if you are bringing products from China for example, then you will have to probably split your shipments if you've kept those two operations, not to be able to pay two times the customs. And that obviously, before you could one stock which would fulfill all the demand from Europe.

Jérôme: Now, you have to have two stocks. And like everyone knows in logistics, more stocks means more costs. The Brexit from a business point of view means a lot of costs. And most probably, you will have to look at your pricing. And like for sure, the logistics cost of Amazon or moving things around will impact your margins. What we expect is the main effect is first is increased costs in the UK, and probably some of the UK goods being increased in Europe. So it's not a very good news for brands or for consumers at least in the short term.

Colleen: So with all of those costs that you're speaking out with fees, and shipping, and logistics, what other costs or implications do you see that sellers should be thinking about when they're trying to decide where they should invest? Whether it's UK, EU, or both, what other cost considerations are there?

Carina: Yeah, I mean, there's the first whatever, a couple of things. It comes to the compliance, there's the tax compliance aspect of if you then decide that you want to be in the UK, and then you want to be in Europe, and let's say hold your inventory in Germany, then, of course, then there's a VAT implication, and so then you've got to go through being VAT registered, and so forth. There's also this compliance part where before, you would be able to have, for example, if you're selling toys or electronics, your products would have a CE marking, they then need to now have not only a CE marking, but a UKCA marking as well. And so there's all these parts, which always makes you smile, because it's the same thing to some extent. But now it's that sort of segregation of, okay, then you need a UK specific compliance marking, and you need a European marking.

Carina: And then of course, you've got this part where it just becomes a lot more complex and bureaucratic as well. So there's that double resource like you were mentioning, Jérôme, you're going to have to start thinking about splitting those shipments having inventory stored in two locations. And it just becomes... Some businesses are already managing that. It's the businesses that have been taking advantage of Amazon's European fulfillment network by having inventory in one location that are going to feel the most pain from this, I would say.

Jérôme: Yes, in the old days, which was one week ago, we would say okay, in Europe, look at Europe, the UK and Germany. So Germany is the biggest Amazon market. UK comes second. And then far away you've got France and Italy, Spain, the Netherlands, and now Sweden and Poland will come in the coming months now. So it was very clear, if you want to address really Europe, you wanted to have at least UK and Germany. If not, you're losing probably one third to one fourth of the total market of the Amazon market, let's say.

Jérôme: Nowadays, it's becoming a bit more complex because it's exactly, where are you strong. So where is your brand strong. So if it's strong everywhere, and you've got a strong presence everywhere, then you probably want to get organized and have two fulfillment sets. So two warehouses, one in the UK, one in Germany, where you can put your projects in FBA or if you're a vendor to fulfill orders, and that's okay. If you're a smaller brand or your results are not so good in every country, then you might want to take a decision and like Carina said, there's some strong European, continental Europe-based brands which have said, "Okay, we pause UK for now." And we have been bigger brands which have said that Exactly. "Okay, we pause UK, we want to see how it's going. And then we'll start again. We take that cut."

Jérôme: Other brands, which were very strong in the UK have said, "Okay, we pause it in the rest." So it's basically taking a decision and the risk of, how much were you making? And how much will you be losing? For sure, a lot of things are a bit unclear in terms of costs. My point is that you want to test things, and you want to see how that costs goes out. And if you want to prepare too many things in advance, it will be very difficult, because there's so much on clarity, so you might as well test in smaller quantities and see how things goes. That the thing which Carina said is that obviously the VAT impact is that if you have a warehouse located in a country, you need to pay VAT in that country. So if let's say you're a brand based in the US, you already got an operation in the UK, and you had a VAT number in the UK, if you want to duplicate that, there is some investment at least in getting a VAT number, which is not a huge investment, but you need to get to the paperwork and those things.

Colleen: Yep, got it. And when you were mentioning compliance, are there any fines involved? Or what's the risk if you're not compliant? What do you see, the UK or the EU or Amazon, doing for those who are not conforming? Or any advice that you have there?

Carina: Jérôme, I'll let you jump in with a CE marking because I know that from your brand management experience you mentioned-

Jérôme: Exactly. This is typical. For example, CE marking, and now UKCA markings, but I believe it's the same for the UKCA, it's for brands to certify themselves, that their products are CE compliant, or UKCA now. So you don't have to go through paying a lot of agencies, but you take the risk of certifying yourself, your product. So from what we understand is at least for the next six months, because the CE marking is still valid, at least for the next six months, I believe so, a minimum. And then the UKCA will have to be implemented. So like in terms of fines and so on, I think that the governments at least will be maybe a bit comprehensive and will understand that you need some time to adapt.

Jérôme: We're not sure about what types of fines you would get on that. I've never seen anyone from the government go and test your CE product. What happens is if a consumer gets hurt by your product, that's when you get a problem where if your CE marking was not correct. So I don't see the issue mostly on the regulations, per se, outside of the customs thing of okay, when are you due to pay customs? Or when do you have to pay VAT? So it's more of a fiscal thing than a regular mentation thing.

Colleen: Right. And we do have one attendee is asking what is the difference between CE and the UKCA mark? UKCA stands for UK Conformity Assessment. Is that right?

Carina: Yeah.

Jérôme: Yeah. Well-

Colleen: Just to clarify the difference between those two was the question.

Jérôme: It smells the same, it tastes the same. It's the same shape, but it's not exactly the same. Honestly, looking from outside it looks a bit foolish. It's exactly the same from what I can say or see, but it's just one is UK, one is Europe. So it's like, go figure.

Carina: Yeah, unfortunately. And that's the same with a lot of things. So if we go over to talk about trademarks, so those businesses that have an EU trademark, an EU trademark is no longer going to be the case within the UK. You now need, if you're filing, if you want a trademark, you're going to have to get a trademark for the UK and for the EU. So that's an additional cost as well. Now, for those businesses that already have an EU trademark, the UK will automatically be creating a UK trademark and Amazon Brand Registry have said that they'll automatically manage all of that in the background. Now, I'm always a bit not 100% sure how that will work. So it is always good not to rely on that. And you as a business, just make sure you do end up with that UK trademark, and that you go into the Brand Registry and you do make sure that that UK trademark is within there.

Carina: That's not going to cost businesses that have already gone with a trademark, it's adding bureaucracy as the UK separates itself from the EU, but for businesses going forward, then of course, that's going to be the case. And it also goes again, with the importing. Before, when you're importing goods, you get a VAT number and you get an EORI number that you can use across Europe when importing goods. Now as a business, you're going to now need a UK EORI number to import products into the UK. And then you're going to need one to import into Europe which would then be your EORI number. And so it just really there's this theme here of duplication, I think, that nothing's really too different, it's just adding. So you've not the single mark, you've got the UK with all their requirements and you've got the EU with their requirements, which are all pretty similar, but they are separate and they are different in the sense of they're asking for one and the other as well.

Colleen: Is there any benefit in...oh, go ahead.

Jérôme: Yes, sorry, Colleen. One thing I wanted to know on that is actually in the deal they've agreed between Boris Johnson and the EU, is that they've agreed that actually the UK has to follow more or less the EU rules. It's like it can be slightly different, but not too much, which, like in law terms, probably difficult to define. But basically, they've said, okay, we can only have no tariffs if you follow more or less our rules. So the UK said, "Yeah, we'll follow your rules, but with our own thing."

Jérôme: So basically, that ends up being having CE and UKCA, which is the same, but with different names, because actually the UK if they don't want to have custom tariffs, they need to be the same as the EU. So they most probably, they will replicate what's already existing in Europe. So for companies, that means that most of it is bureaucracy and papers, but actually, it's if your products are compliant in the UK or in Europe, then it will be true in both sides. You just need to make sure that the markings and the logo and the labels are following those new rules. But most probably you won't have to do anything on the product itself.

Colleen: Okay. We have a few questions, so I'll go ahead and address these. I'll mention these. A couple folks here. Any tips on going through the process of getting a VAT number for various EU countries? Is this where you would recommend a tax expert? Or?

Jérôme: Well, yeah. You have very good companies, and we can name a few in Europe, which are doing a great job. They're very good in doing that, and they will do it very efficiently, and they will send you tons of documents you have to sign and tell you, "Okay, sign this little box here, this little box here." And Poland needs 20 documents, France needs five, and this one... there's no chance you can learn this thing, the cost is not very big. The only things you can notice, for example, Italy is a country, which is the easiest to get VAT number. You can get it in a matter of days/one week, two weeks to get a VAT number.

Jérôme: UK is probably one which is quite quick. Germany is very long. So Germany takes between three months to six months. It shows you already the impact is, if you want to move and to do business and have stock in Germany, that means you probably have a lead time of six months already.

Colleen: Okay. Let's see, a couple other questions here. What happens if you import a product from outside the EU in bulk, packet in the UK, and put the product on Amazon to sell throughout UK and EU? Do you need to pay customs duties twice?

Jérôme: That's a tricky one. Basically, there's a rule, and I'm not sure about percentage, we could check that. It's basically, if you have, I don't know if it's half of the value added or half of the value has been given in locally, then it's deemed as British. Now, each country's probably got a different rule on that. I know, for example, there was a lot of discussion in Germany for the Made in Germany thing, because there was a lot of discussion even with a government were saying, some products were imported in from China, painted, and then made in Germany. So there is an element of you need to check country per country what's the exact rule. You need to be careful probably and make sure that it's really for the UK specifically or there's a rule of when you can say it's a British product. And to be honest, I would need to check the exact details.

Jérôme: So yes, it's possible, but you have rules to be able... Having only on zipper polythene bag and put it on its own is probably not enough to say it's British.

Colleen: Okay. One seller here has both of that in the UK and in Germany. How can they ship products to Germany, not through UK? I think the seller might be located in the US or another area and they're trying to ship products to Germany but not through the UK.

Carina: I think that goes back still down to the start of this whole split shipments of that if you've got, before, you might have probably been sending inventory and then sort of redistributing it, it then becomes that challenge that you've probably then want to actually split that shipment before. So you've got one shipment going to Germany and then you've got one shipment going to the UK.

Jérôme: Yeah, it goes down to the EORI number, you need to have import numbers. It's not only that, you need also the EORI, E-O-R-I number, which you need to do the import. The best idea, if you have one big shipment is that you talk with your logistics company and say how can they handle shipping in two ways? But obviously, it doesn't make sense to have it go to UK first and then to Germany, you probably have to split them maybe from the beginning.

Colleen: Okay. I think you touched on this earlier that some sellers and brands are delaying selling in the UK or EU till they kind of figure this all out. So one seller here is in Canada, said that they're considering limiting their Amazon business to the EU so they can fully understand all the implications from doing business from Canada, the UK. Is this a common go forward strategy? And if so, what is a reasonable timeframe do you think, for them to revisit the option of going into the UK or EU?

Carina: I think this is very subjective, and a lot of it depends on you as a business and really where your revenue is coming from and your revenue stream. Because I think this goes back to what is the overall EU strategy, even pre Brexit where we've had this conversation with businesses as in when a number of business, when we talk about Amazon Europe, does it make sense for a business that's going into Europe to go into all marketplaces from day one? Is that the right strategy, or is the right strategy to go into one market, get yourselves established into that one market, and then expand into additional markets? So I would say that defining that EU strategy shouldn't necessarily be changed by Brexit, it's of course, going to create a few more hurdles. But it's about thinking, first off, what is the best market and doing that research? Where's the biggest opportunity?

Carina: Yes, the UK and Germany are the biggest markets within the EU marketplaces that Amazon's in, but is there that opportunity as well? Because of course, there's got to be opportunity, depending on that product type within that market and really defining, is it Germany where that opportunity is? Or is it the UK? Or it might even be both of those. And I would always say do that sort of homework first to define what the best EU marketplaces would be and define your EU strategy, even pre sort of considering the Brexit challenges.

Colleen: Okay. A question about stranded inventory here. So if, for example, you have a product that goes down to the EU, and the inventory becomes stranded, they can't pull it out and send it to the UK. But can they pull it out and send it to another EU country? Like if it's stranded in Germany, can they send it to Poland, or somewhere else, but just not the UK?

Jérôme: Normally, yes. Yes, you need to be careful that if it's stranded, Amazon might not want to make it move at all, but normally, yes, movements between inside EU, the new EU without UK it's possible, for sure.

Carina: Yeah. It's just the removals to the UK, Amazon put a stop to it. I think it was around October, November, that Amazon stopped that. So if there are any people listening that do have inventory, let's say stuck in the UK, we've had a few inquiries, actually, that have come our way as in, how do we get... We can't pull our UK removals to the Netherlands, for example. Unfortunately, there is no answer to that. It's about finding a business or somebody in the UK that you've got an address where you can send that removal to. And then it's about sending that removal back over to the country that you need it to be in, unfortunately.

Colleen: Okay. And then, in regards to really just changes to the UK with day to day operations with Amazon, are there any changes to order processing, the detail pages, Amazon advertising, product upload. Any other day to day operations that are changing for UK Amazon sellers?

Jérôme: No, it's as complicated as before. That hasn't changed that. It hasn't simplified.

Carina: It hasn't simplified, yeah. I mean, Amazon will always be evolving, but it's almost like, at the same time, Amazon like to treat the way they work as global as possible. And you'll see that with Europe, although Europe sort of is behind the US. Most pilots schemes or new features will appear in the US first and then come to Europe, apart from advertising, which seems quite clean across the whole of the globe. But yeah, very much as you say, the standard Always, but it's always important anyway, to just keep yourself in tune because Amazon's changing by the day, regardless of Brexit.

Jérôme: Yeah, and to be fair, Brexit is not an Amazon thing. So Amazon just hasn't changed. Amazon has adapted and just said, okay, "We won't." Because they could have kept in a way if there is no fees and no customs or no tariffs, they could have said, okay, "We keep one system working," which they might implement in the future, we don't know. But they just said, okay, "Because of Brexit, we're just changing the logistics part, that's all." But for Amazon, they will lose a lot of money because of that, for sure. Because on the vendor side, with Amazon, they were moving stock around very freely. Now, they won't be able to do so.

Colleen: And what about brand registration? Will they separate the UK from the EU?

Carina: Yes. Well, that's where you need to make sure that if you have an EU trademark, that you have an EU trademark and a UK trademark. Now, that's where, as I mentioned earlier, it's more making sure that you do end up, if you've got an EU trademark, that you have been presented a UK trademark as well, and that that is logged in the Brand Registry and going in there and logging it in and enrolling it, if it hasn't separated out. I say if it hasn't, we haven't seen that yet. This is all pretty new. We're in the first week of January, so still it's seeing what is... And I think even Amazon are trying to figure it all out as well.

Carina: It's just more that if you are then going to apply for a trademark in the future, you need to apply for a trademark in the UK and Europe.

Jérôme: And to be clear, here again, the system hasn't been changed per se. It's just the recognition of the system of the old trademark has to change because the law has changed. But the brand registration database, there was always you could have registered your UK brand and also your French brand and also the EU one. The thing is now EU ones are not recognized. For old one, yes. But for new ones, the EU ones will not be recognized. That's extra paperwork also.

Colleen: Okay, so two questions that I'm going to kind of put together here. One is about that, do I have to add 20% in terms of that to my final sales price in the UK? So if my starting point is 10 US dollars, should I have to sell it at 12 US dollars? And then kind of to piggyback on that, do you anticipate that we'll see an overall increase in retail pricing on Amazon UK as a result of Brexit? I think you kind of already mentioned that earlier too, that you'll probably see pricing increases, so it's not great for consumers or other sellers in a lot of ways. But should the sellers be increasing their pricing to accommodate for that?

Jérôme: I'll jump onto that. The main difference on prices online between the US and Europe, all countries in Europe in the US, your prices are without tax. In Europe, always all our prices are with VAT. So obviously, if your price without VAT is 10, you need to show 12 on your seller account. You need to put 12 because you will have to pay 20% on your selling price to the government. So if you put 10, then the government will take 20. So if you're like 12, 20% of 12 is not too bad, right? You get my point, is that you need to show on your customer facing prices, the price with VAT. So depending on the country, now it's more or less aligned, it's more or less 20% everywhere. Germany, for example, went down to 19% during the COVID just to support as you can see even lower, I can't remember, it's changing all the time anyway.

Jérôme: So you have changes in Germany. They decided during COVID to reduce VAT to support the car industry, mainly, but it applied to everything, so you need to follow up. And that's why having a tax advisor or someone who helps you with the VAT is also helpful to keep track of what's happening on all those VAT stuff because it can become a bit tricky because if your stock is in Germany, but you sell to Albania, for example, or you're selling on Amazon, Germany with a stock which is based in Poland, and it's someone from Spain who is buying, where do you pay your VAT? And those things can become a bit of a nightmare. If you have someone who's helping you, he will know where to recall which VAT.

Carina: Yeah, and to add to that, actually Amazon made an announcement. Well, made a few announcements of that they're going to be collecting. Usually, you as a seller would have to collect your own VAT and file your VAT to let's say, the UK Tax Office.

Carina: Amazon is now going to be collecting tax. And they're going to be collecting tax on goods delivered from inventory that have been stored outside of the UK with a parcel value of up to 135 pounds. And also, they're going to be collecting VAT, and they're going to be responsible for collecting the UK VAT on goods delivered from inventory stored in the UK, irrespective of value where the seller isn't established in the UK. So we're already seeing a bit where Amazon's having to take some element of responsibility there, as well. So it's always good to make sure that you are receiving all those notifications. And I think that's a notification that we share with everyone as well.

Colleen: Okay, and regarding that, Jérôme, you mentioned that the UK, it's usually a fairly quick process to get that in the UK. Someone said that they have a product stuck in the UK, and they're considering getting a VAT over removing the product. Is that something that you would recommend?

Jérôme: Well, it is typically you will have to pay the warehouse in the customs or the harbor. So it's the Mirage fee. And so it's you have to check how much they charge you every day. And it depends on the value of the goods, and the cost. The cost of having a VAT number is not very big, but it can take you up to three weeks, three, four weeks. So you need to be ready for that. And it depends on, if it's two or three containers, maybe it's okay, that's probably costly. If it's three containers of something which is coming from China, and you can't ship it anywhere, so just get a good VAT customer agent, which will try to speed up the process. In good days, it probably can take less than that, so having a good partner, that could be the best option, I would say. And we'll list that thing at the end of the discussion, right? The partners we would recommend.

Colleen: Yeah. Okay, here, we have a question about restock rates. They are currently the same across the UK and EU, which is odd. For example, if the restock limit is 1000 units, that is across UK and EU countries, do you think that will change? So regarding, I think maybe in relation to IPI units you can stock.

Carina: I believe that that will then also... I mean, it's hard to say whether it was specifically change. I mean, a lot then is actually what we're finding, is changing at seller level as well down to your demand of your products. But yeah, hard to say again, there's a lot of things that haven't changed, it might not change right now. The biggest changes overall are a lot more fiscal and down to trade. But yeah, I won't say I'll be able to speculate on that one. Unless, you see anything there, Jérôme?

Jérôme: Yeah, the thing you need to be careful is you're comparing EU with UK as in EU one thing. It's like seller accounts, which for each country are different. The limit is not for the EU, it's for your account in Germany, your account in France or your account in Spain or in Italy. So actually, you're comparing apples with apples, not all the apples against one apple. Yeah, the limit is not for them. They're not looking at it as EU versus UK. They're looking at it, okay, your seller account in Germany, or your seller account in France, or your seller account in the UK. So the rules, once again, the Brexit is not an Amazon thing, so the Amazon rules within the whole of Europe, including the UK should remain the same more or less in terms of internal Amazon rules.

Colleen: Okay. We'll take one more question, then we'll share some of the resources that we talked about, and then circle back to any other questions that come up. So this seller currently sells an electronic product in the US and is looking to expand to the EU and UK. He's wondering if he's allowed to list products under the same UPC even though the product is different because they have the different electronic plugs for the US, UK, and EU. So will there be any negative implications across all three marketplaces? And can he use the same UPC?

Carina: Really, you've got to think okay, because you're going to have a different plug for the UK than you are for the EU. So you're going to have a three-pin plug versus a two-pin plug. Now, you want to be very careful there from a customer experience point of view, because if all of a sudden you've got the same product and it gets into the UK market with a two-pin plug, or vice versa, a three-pin plug in a two-pin plug, that's not compliant for those markets. And I don't believe it's legally compliant as in not being able to sell an electronic UK plug in the EU. So you've got to be careful there because for a couple of reasons. One, in terms of customer feedback and negative feedback, but also if Amazon and that's reported to Amazon, and a customer makes a complaint, the last thing that you want is your listing being pulled or suspended.

Carina: Now, I know a lot of businesses prefer to do that, you've already accumulated those reviews, right? In the US. And that's a lot of the time where we're having the same item across Europe helps but not something that's... You've got to be careful there. Jérôme, my guess you've had experience with that as well.

Jérôme: Yes. That's tricky. Like, you don't want to have the same essence, same Amazon product codes for different products. If that, you're heading for trouble. Even though specific now the UK is unplugged from the rest of Europe, you could say okay, I don't really care. Knowing how Amazon works and their logistics, is you might well end up with a UK product, which ends up in a European warehouse. If UK British citizen buys a product and it's actually located in France, and you get to chip back, but he returns it and it's returned to Amazon, France, and then sold to a French customer, then that's where you start to be in trouble. So you have to be clean on that part. And we would recommend to make different essence.

Colleen: Thank you. Okay, so we already did the poll. So here, we just wanted to share some of the resources that we've kind of been touching on that there are some resources out there. Of course, our awesome consultants here, Carina and Jérôme, their companies, our eCommerce and eCommerce Nurse. But Amazon does have a lot of information on Seller Central, they also have a Brexit selling partner guide. But again, keep in mind, a lot of the regulations and everything are not an Amazon thing. It's a UK EU thing. So Amazon shares how it's impacting things on Amazon, but they also reference a lot of the legislation pages as well, if you need to take a look at those.

Colleen: So you can find a lot of those links out there on Seller Central, but also that Brexit Selling Partner Guide, there's a Bitly, since it's a very long URL, but you can jot that down. And then some of the tax experts that we recommend that Carina, Jérôme, and I, all of our companies I have worked with and referred, and they're great companies. All three of these are great options if you're looking for a tax expert to consult with, AVASK who's based in the UK, global eCommerce experts and simply that, all three of those are very knowledgeable UK tax experts and can definitely help you. So feel free to reach out to any of them.

Colleen: I'll just keep this screen up, so anybody can write down that Bitly or that URL as needed. And then I'll just circle back, see if there's any other questions that just popped up. Let's see. We have another question again, about Brand Registry. But we've kind of already covered that. Is that, will Brand Registry if your trademark in the UK will be taken care of in the EU? And the answer is no. Correct, you need to take care of your trademarks separately now.

Jérôme: Yeah, you've got two levels. It's like for Amazon to recognize you as a brand owner, the UK, any trademark in anywhere in the world would make the system recognize you're owning the brand somewhere in the world. That probably gives you the first level of access. However, if you would want to fight to get someone who's infringing a patent or copying a product, if your trademark is not local, you can't do anything because the system will say you don't have a local trademark. So it will give you access to Brand Registry but it will not enable you to remove anyone infringing a local patent, for example.

Colleen: Okay, any final words or advice cream, Carina, and Jérôme? Anything else that we didn't touch on that you want to share?

Carina: Yeah. Mainly, it's just sort of what I touched on at the start as really it's about, this is a time when you as a business really need to think about what your strategy is, because before many businesses were sorted, it was quite easy to sell in the UK and then put your products on Germany. In fact, Amazon automatically did it sometimes. If you had the box checked, it would automatically happen. And so a lot of sellers didn't put much thought into it. Products were automatically translated. They just appeared there. They're all of a sudden selling on Germany and Amazon's taking the FBA. Once there's a sale, FBA inventory in the UK automatically to Germany. So no one thought really about, should I or shouldn't I? It's now that point where businesses are actually really thinking about, "Do I invest in this?" It's no longer so easy.

Carina: And every business is different. There's no sort of one box fits all. You've got to think about what your long term goal is. And if you want to expand or is that opportunity already for you to master the UK market first, because a lot of businesses do spread themselves quite thinly at an early stage without really mastering one marketplace. So that's what I would really say is, take a step back, do some research, understand where that real opportunity is. And then consider what is your strategy in the EU? Is it to master one marketplace then move on to the next? Is it to be out there with pan European? Is it to be multi channel where you could say, "Okay, I'm going to be in the UK, and I'm going to be in Germany." I would definitely say that should be your first point of figuring that out.

Jérôme: Totally agree. I think that's very wise advice. On my side, I would say that doing business in Europe is complex, because you've got the languages, you've got the different cultures, all of that. However, you could look at it as an opportunity is that, the one who gets inside the EU today and is successful, the entry barrier is quite high. Like in the US, anyone can take your spot quite easily. In Europe, as soon as you've got a strong presence... you need to build it and it takes time, but once you have it is very difficult to take it back from you. Plus, you've got multiple countries, so it may be you lose a bit on one, but you can still win on the other. I see it as it's a complex exercise, but it's one which is very rewarding with time, because it's much more stable, let's say, for my experience.

Jérôme: The second thing I would say that it's a market way. You need to find the right partners. And you need to find the right partners for the VAT, for example, but you also need some support. And my advice is really look into finding someone which can help you localize your content, help you define your strategy, like Carina was saying, where do you start? How do you do it? Because it is complex. And the ones who will be successful will be the ones which invest at the beginning and spend a bit of money in finding the right people to help them being successful. And you will see in the long term, that will be a very good investment.

Colleen: Great advice. Thank you very much for sharing. So again, thank you so much for joining us today, we do have a few special offers from each of us who are on the call today. From the comments, we have two tools, as I mentioned at the very beginning, FeedbackFive and RestockPro which are available in the UK, and all of the EU markets, as well as many other marketplaces. So you're welcome to sign up with a 30-day free trial. Just use coupon code global or reach out to me if you want to learn more about those tools. And then eCommerce and eCommerce Nurse are both offering free consultations. So Jérôme and his team would be happy to have a 15-minute call with you and share some advice on how to maximize your brand potential on Amazon. And Carina and her team welcomes a call as well, for sellers or vendors on defining your EU strategy.

Colleen: So feel free to reach out to either of them. There's a link there to schedule a call with their team or to contact them. And we will also send this out as a recording and an email shortly this afternoon. So keep your eye out for that. If you or anyone else on your team didn't get a chance to hear the whole thing, you can watch the recording. But thanks so much. Wishing everybody a great 2021. Hopefully, I know this is a lot of challenges for the beginning of the year already. But there's a lot of potential out there on Amazon. So Best of luck to everybody. And thanks again to Carina and Jérôme for joining us today.

Carina: Thank you everyone, and thank you for the invite.

Jérôme: Yeah. Thanks, Colleen. Bye, bye.