Selling in Germany: business registration, taxes, LUCID & GPSR
- You know which registrations must be completed BEFORE the first sale on amazon.de — and in which order.
- You can make an informed decision on Germany's small-business VAT rule for an FBA import business.
- You know the packaging register (LUCID) and GPSR — the two duties where Amazon blocks listings without mercy.
- You know where you need a professional and where your own research is enough.
This lesson is carefully researched education, but not legal or tax advice. Numbers and thresholds change; binding answers come from the tax office and a tax advisor. If you're setting up in Germany, one initial session with a German tax advisor (Steuerberater) is money well spent.
The least popular part of starting on Amazon — and the one where mistakes are most expensive. The good news: it's a manageable checklist you can complete in two to three weeks, most of it online. This lesson focuses on Germany (amazon.de), the market this academy is built around; other EU countries have similar structures with different names.
1Step 1: register your trade (Gewerbe) — before the first sale
Anyone selling regularly with the intent to profit runs a trade in Germany — from day one, not from a revenue threshold. The registration:
- Where: the local trade office (Gewerbeamt), in many cities online. Costs roughly €15–60 depending on the municipality.
- What: a sole proprietorship is fully sufficient at the start. A GmbH/UG (limited company) only pays off later — it costs ongoing money and administration.
- What follows automatically: the tax office gets involved — you complete the questionnaire for tax registration via ELSTER and receive your tax number and, importantly, your VAT ID (USt-ID).
- Side effects: chamber of commerce (IHK) membership is mandatory (often free or cheap for small businesses). If you're employed, check your contract about side businesses.
Amazon's verification asks for proof of your business — without trade registration and VAT ID you won't pass as a business seller (details in lesson 3).
2Step 2: the small-business VAT question — the answer is usually no
Germany's small-business rule (§ 19 UStG) exempts you from charging VAT while your revenue stays under €25,000 (previous year) and €100,000 (current year) — thresholds since 2025. Sounds like less bureaucracy, but for FBA importers it has heavy downsides:
| Small-business rule | Standard VAT | |
|---|---|---|
| VAT on sales | none | 19 % to remit |
| Input VAT deduction | no — import VAT, Amazon fees, equipment: no refunds | yes — you reclaim VAT on imports and costs |
| Bureaucracy | less (no VAT returns) | periodic VAT returns (easy with accounting software) |
| Growth | crossing the threshold changes your pricing logic mid-year | scalable from day one |
For an import business, standard VAT is almost always the better choice: you pay import VAT on your goods — under standard VAT you reclaim it, under the small-business rule it's a real cost. Two extra traps: fees from foreign providers (e.g. Amazon billing from Luxembourg) trigger reverse-charge VAT that small businesses still owe — many don't know this. And the exemption only works domestically; EU-wide selling gets complex. Discuss this once, properly, with a tax advisor.
You order 500 AURELO spice grinder sets at €4.50 each — €2,250 in goods, plus €550 freight. On import, simplified, about €530 of import VAT falls due (19 % on goods plus freight). Under standard VAT you reclaim those €530 as input tax. Under the small-business rule you don't — each set effectively costs a good €1 more, almost a quarter on top of your €4.50 unit cost.
For standard-VAT sellers, VAT is a pass-through item: you collect it from customers on behalf of the state and get back what you paid yourself on imports and purchases. Small businesses stand outside this loop — they collect nothing, but they also get nothing back. If you import goods, the 19 % paid at the border simply sticks with you.
3Step 3: VAT on EU sales — OSS in one paragraph
As long as your stock sits in Germany and you sell less than €10,000 net per year to consumers in other EU countries, everything is taxed in Germany. Above that, the One-Stop-Shop (OSS) applies: one registration, one consolidated VAT return for all destination countries. The topic becomes serious when Amazon relocates your stock to other countries (PAN-EU) — that even requires local VAT registrations. For the start: restrict storage to Germany (a setting in Seller Central!) and it stays simple. More in the Growth track.
Your AURELO mills are stored only in Germany. Over the year, Austrian customers order €4,000 net and French customers €2,000 net. That's €6,000 of cross-border EU revenue — the €10,000 threshold isn't crossed, so everything simply runs through German VAT. Only once those foreign sales together grow past the threshold do you register for OSS — a one-time online registration, no drama.
4Step 4: packaging law & LUCID — Amazon checks this automatically
Everyone selling packaged goods to German consumers must, before the first sale:
- register in the LUCID packaging register (free, online, 20 minutes),
- license their packaging volumes with a dual system (paid — for starter volumes usually under €100/year), and
- report those volumes in LUCID.
Amazon matches your LUCID number automatically: no valid registration, no active listing. This covers your product packaging even with FBA (Amazon's shipping box is Amazon's duty, your product box is yours). Similar registers (the EPR family) exist for electronics (WEEE) and batteries — if your product falls into those categories, plan the registration and its costs from the start.
5Step 5: GPSR — the EU product safety regulation
Since December 2024 the EU General Product Safety Regulation applies to practically all non-food products. For a private-label seller this means:
- There must be a responsible person in the EU (if you import yourself into the EU, that's you — name and address on the product or packaging; non-EU sellers need an EU responsible person).
- Manufacturer and safety details belong in the listing — Amazon has dedicated fields (manufacturer contact, responsible person, warnings). Missing data blocks the offer.
- Product-level markings (CE for electronics/toys, warnings, instructions in German) must be on or with the product — specifics depend on the category, covered in the import lesson.
6Step 6: the rest of the mandatory program
- Impressum & withdrawal policy: your Amazon seller profile needs a full legal notice (Impressum), withdrawal instructions and privacy info — German law, enforced by competitors via warning letters (Abmahnung). Amazon provides the fields; chambers of commerce and law firms provide generator texts.
- Product liability insurance: selling under your own brand makes you liable like a manufacturer. A policy often costs €100–300/year for standard products — sensible from day one, and Amazon requires proof in some programs and revenue bands.
- Trademark check: before printing a brand name, search DPMA (Germany) and EUIPO (EU) for identical or confusingly similar marks. Registering your own mark comes later (Growth track) — the infringement check comes NOW.
- Bookkeeping from day one: a separate business bank account plus accounting software (or a clean document trail for your tax advisor). Amazon settlements are hard to reconstruct without a system.
“I'll sell for a few weeks first and register afterwards.” Exactly backwards: trade registration, VAT ID and LUCID are prerequisites, not paperwork to catch up on. Consequences range from warning letters (Impressum, packaging law) to blocked listings (LUCID, GPSR) to back taxes with interest. The paperwork costs two weeks — the cleanup afterwards costs months.
- Trade registered, tax questionnaire submitted.
- Tax number and VAT ID received.
- Small-business VAT question consciously decided (importers: usually standard VAT).
- LUCID registration + packaging licensing done, number saved.
- Checked whether my product triggers EPR categories (electronics, batteries) or CE duties.
- GPSR understood: responsible person + mandatory listing data planned.
- Impressum texts prepared, liability insurance quoted, brand name checked against DPMA/EUIPO.
- Business bank account opened, bookkeeping in place.
7Expert insight: reverse charge on Amazon fees
Amazon bills its fees from its Luxembourg entity — the fee invoice arrives net, with a note that the tax liability shifts to the recipient (reverse charge, § 13b UStG in Germany). Meaning: not Amazon but you owe the VAT on these fees. How that plays out depends entirely on your status from this lesson:
- Standard VAT: in your VAT return you declare 19 % on the Amazon fees as tax owed and deduct the identical amount as input tax in the same return. Cash effect: zero. But the declaration duty remains — simply omitting the reverse-charge amounts is a formal error in every single return, and exactly this kind of thing surfaces in VAT audits. Good accounting software books it automatically once Amazon is set up as a reverse-charge supplier.
- Small-business rule: you owe the 19 % just the same — but without input tax deduction. The tax on Amazon's fees is a real cost for you, and despite the exemption you must file returns for it and pay.
250 AURELO spice grinder sets sold per month: per unit €3.75 referral fee plus about €3.70 FBA fulfilment fee = €7.45, so €1,862.50 in fees. 19 % reverse-charge tax on that = €353.88. The standard-VAT seller declares the amount and reclaims it in the same return — net effect zero. The small-business seller actually pays the €353.88: about €1.42 per unit sold. Together with the non-refundable import VAT (a good €1 per unit from the example above), the small-business status costs roughly €2.50 per set here — more than half the €4.50 purchase price added on top.
Three practical details that often go wrong:
- Register your VAT ID with Amazon: only with a VAT ID on file does Amazon treat you as a business and bill net under reverse charge. Small businesses can and should request a VAT ID too — it costs nothing and doesn't affect the exemption.
- Not just Amazon: the same mechanics apply to software subscriptions and services from foreign providers (research tools, freelancer platforms). Every net invoice from abroad is a reverse-charge candidate.
- File the documents cleanly: the fee invoices sit in Seller Central under the tax documents — they are the basis for both the declaration and the input tax deduction.
“I'm a small business, VAT doesn't concern me” is wrong twice over: import VAT and the reverse-charge tax on foreign fees still fall due — just without any refund. Overlook this for years and the first audit brings back taxes plus interest. Your tax advisor settles this bindingly.
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Frequently asked
What does the complete legal setup cost, roughly?
It's manageable: trade registration €15–60, LUCID registration free plus packaging licensing usually under €100/year at starter volumes, product liability insurance often €100–300/year. The biggest item is optional: an initial tax consultation — almost always money well spent.
Do I need a limited company (GmbH) for Amazon FBA?
No. A sole proprietorship is fully sufficient at the start and ready within two weeks. A GmbH/UG only pays off later for liability or tax reasons — it costs ongoing money, accounting duties and founding time.
What happens if I cross the small-business threshold mid-year?
Since the 2025 reform: from the sale that crosses the €100,000 current-year threshold, the exemption ends — from then on you invoice with VAT. For growing FBA sellers that's one more reason to start with standard VAT right away.
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