Rising Fuel Surcharges in 2026: How Cross-Border E-Commerce Sellers in the EU Can Protect Margins
6 April 2026
Cross-border vs EU warehousing: which is more cost-effective?
7 April 2026
FLEX. Logistics
We provide logistics services to online retailers in Europe: Amazon FBA prep, processing FBA removal orders, forwarding to Fulfillment Centers - both FBA and Vendor shipments.
Belgium has announced an increase of its VAT exemption threshold for small businesses from EUR 25,000 to EUR 30,000 — a legislative change pending formal amendment that is directly relevant to small and mid-sized e-commerce sellers and DTC brands selling into Belgium from German or Polish warehouses. While tax advisory content will eventually cover this change from a Belgian law perspective, the cross-border e-commerce seller implication — specifically how this interacts with the EU OSS scheme, Amazon Pan-EU FBA, and the VAT position of sellers fulfilling Belgian B2C orders from German or Polish inventory — has not yet been addressed. This article explains what the change is, when it takes effect, how it interacts with OSS and IOSS for sellers already using those mechanisms, and what e-commerce sellers shipping into Belgium from German or Polish 3PL locations need to review before the legislation is enacted.
What Belgium's VAT Threshold Increase Actually Changes
Belgium's VAT exemption for small businesses (vrijstelling voor kleine ondernemingen / franchise de la taxe pour les petites entreprises) allows Belgian-established businesses with annual turnover below the threshold to trade without charging Belgian VAT and without filing Belgian VAT returns. The increase from EUR 25,000 to EUR 30,000 raises the ceiling at which small Belgian businesses must register for Belgian VAT — meaning Belgian sellers with turnover between EUR 25,000 and EUR 30,000 may be able to deregister or remain unregistered for Belgian VAT once the legislation takes effect.
Critically: this threshold applies only to businesses established in Belgium. It does not apply to non-Belgian businesses selling into Belgium. A German-established e-commerce seller, a Polish prep centre acting as importer, or a non-EU brand selling to Belgian consumers from a German or French 3PL warehouse is not eligible for the Belgian domestic small business exemption — regardless of their Belgian sales volume. The change is relevant to sellers in a more indirect way: it affects the competitive landscape (small Belgian domestic sellers gain a compliance cost advantage), and it has a specific interaction with the EU cross-border small business VAT scheme that does affect non-Belgian EU sellers.
The EU cross-border small business scheme — introduced alongside OSS in 2021 — allows businesses established in one EU member state to apply a VAT exemption in other member states where their cross-border sales do not exceed that member state's domestic threshold, provided their total EU cross-border turnover does not exceed EUR 100,000. When Belgium raises its domestic threshold to EUR 30,000, the cross-border exemption threshold for Belgium also rises from EUR 25,000 to EUR 30,000 — meaning EU sellers from Germany, Poland, France and elsewhere can sell up to EUR 30,000 per year to Belgian consumers without Belgian VAT registration, provided they meet the other conditions of the cross-border scheme. EU customs clearance and cross-border compliance at FLEX. tracks VAT threshold changes across EU member states and advises clients on registration review timing.
How This Interacts With OSS for Sellers Already Using One-Stop Shop
The vast majority of e-commerce sellers shipping B2C orders to Belgian consumers from German or Polish 3PL warehouses are already using the EU OSS (One-Stop Shop) scheme — filing a single quarterly OSS return in their country of establishment (typically Germany or Poland) that covers cross-border B2C sales to all EU consumer markets including Belgium. For these sellers, the Belgium threshold change has a specific and somewhat counterintuitive implication:
Sellers enrolled in OSS are explicitly excluded from using the cross-border small business VAT exemption for the same transactions. You cannot simultaneously use OSS for Belgian sales and claim the cross-border exemption for Belgian sales — the two mechanisms are mutually exclusive. If you are enrolled in OSS, the Belgium threshold increase from EUR 25,000 to EUR 30,000 does not reduce your Belgian VAT obligations — you continue to charge and report Belgian VAT (21%) on all Belgian B2C sales through your OSS return, regardless of the threshold level.
The threshold change is therefore most relevant to two specific categories of seller: (1) sellers who are not yet enrolled in OSS and are considering whether to register for Belgian VAT directly versus using OSS, and (2) sellers who enrolled in OSS specifically because their Belgian sales exceeded the old EUR 25,000 threshold and who would not have enrolled if the threshold had been EUR 30,000 — these sellers may wish to evaluate whether deregistering from OSS and using the cross-border exemption for Belgium is commercially worthwhile, recognising that this affects all EU markets simultaneously, not just Belgium. Pre-Amazon storage in Europe at FLEX. supports sellers reviewing their VAT position across Germany, Poland and Benelux as part of inbound logistics onboarding.
The Amazon Pan-EU FBA Dimension: When Belgian Storage Triggers Belgian VAT
For Amazon sellers using Pan-EU FBA, the Belgian VAT position is determined not by their sales volume into Belgium but by whether Amazon places their inventory in Belgian fulfilment centres. Amazon operates the BRU1 (Brieselang area) and LGG1 (Liège) FCs in Belgium as part of the Pan-EU network. When a Pan-EU FBA seller's inventory is placed in a Belgian FC by Amazon's distribution algorithm, the seller has a physical presence of goods in Belgium — which triggers a Belgian VAT registration obligation regardless of the Belgian domestic threshold and regardless of the cross-border exemption. The threshold and exemption are irrelevant once goods are physically stored in Belgium.
This is a common compliance gap for Amazon Pan-EU sellers: they assume that low Belgian sales volume means no Belgian VAT obligation, not realising that the obligation is triggered by storage, not by sales. If you are enrolled in Pan-EU FBA and Amazon is distributing inventory to BRU1 or LGG1, you have a Belgian VAT registration obligation that exists independently of the threshold change. The Belgium threshold increase to EUR 30,000 does not affect this obligation. Check your Seller Central inventory placement data to determine whether your goods are currently in Belgian FCs — if they are and you do not have Belgian VAT registration, this is a retrospective liability that needs to be addressed. Amazon FBA prep services in Europe at FLEX. can advise on the VAT registration implications of specific FC placements for Pan-EU sellers during inbound planning.
What Sellers Shipping to Belgium From German or Polish Warehouses Should Review
For e-commerce sellers fulfilling Belgian B2C orders from FLEX.'s German or Polish locations — without storing goods in Belgium — the Belgium threshold change creates a specific review opportunity depending on their current Belgian sales volume and VAT registration status:
Sellers with Belgian annual B2C sales below EUR 25,000, currently using OSS: Your current position is compliant. The threshold increase to EUR 30,000 does not change your OSS obligations — you continue reporting Belgian sales through OSS at 21% Belgian VAT. No action required, but note that if your Belgian sales were approaching the EUR 25,000 threshold and you enrolled in OSS specifically to handle that growth, the threshold increase gives you more headroom before cross-border OSS would have been required anyway.
Sellers with Belgian annual B2C sales between EUR 25,000 and EUR 30,000, currently using OSS: Once the Belgian legislation takes effect, your Belgian sales level would fall under the new threshold — but you are already enrolled in OSS and must continue using it for all EU markets or deregister entirely. Deregistering from OSS to use the cross-border exemption for Belgium specifically is not possible — it is all-or-nothing. If Belgian sales represent a large share of your total OSS-covered sales and your total EU cross-border volume is below EUR 100,000, a VAT advisor review of whether OSS remains the optimal mechanism is worthwhile.
Sellers not yet enrolled in OSS with Belgian B2C sales approaching EUR 25,000: The threshold increase gives you more time before Belgian VAT registration becomes mandatory under the cross-border exemption scheme. However, if your total EU cross-border sales across all markets exceed EUR 100,000, the EU cross-border small business exemption does not apply regardless of Belgian threshold — OSS is mandatory in that case. B2C and B2B fulfillment in Europe at FLEX. covers Belgian B2C delivery from German and Polish locations, with carrier access to Belgian consumers at domestic Benelux rates.
When Does the Belgian Threshold Change Take Effect — and What to Do Before Then
The Belgian threshold increase from EUR 25,000 to EUR 30,000 has been announced but requires a formal legislative amendment to take effect. As of early April 2026, the amendment is pending — it has not yet passed through the Belgian parliament. The expected timeline for passage is Q2 or Q3 2026, with an effective date that may be retroactive to 1 January 2026 or prospective from the date of royal decree publication. This legislative ambiguity means:
Sellers who are currently charging Belgian VAT on sales below EUR 30,000 (but above EUR 25,000) should not unilaterally stop charging Belgian VAT until the legislation is formally enacted and the effective date is confirmed. Acting on an announced but not-yet-enacted threshold change creates a compliance gap if the legislation is delayed or amended before passage.
Sellers who are planning their Belgian VAT position for the second half of 2026 should build the EUR 30,000 threshold into their planning assumptions as the likely operative threshold from H2 2026 — but should confirm the effective date with a Belgian VAT advisor before making registration or deregistration decisions.
Sellers who are not yet enrolled in OSS and are watching the Belgian threshold as a trigger for OSS enrolment should note that the EUR 10,000 EU cross-border threshold that triggers OSS is separate from the Belgian domestic threshold — the EUR 10,000 threshold applies across all EU cross-border B2C sales combined, not per country. Sellers whose total EU cross-border B2C sales across all markets exceed EUR 10,000 per year are already past the OSS enrolment trigger, regardless of Belgian threshold. EU cross-border compliance and customs clearance at FLEX. can assist sellers reviewing their VAT registration position across Germany, Belgium and other EU markets as part of the logistics onboarding process.
Three Actions for E-Commerce Sellers Now
1. Check whether your goods are currently in Belgian Amazon FCs. Log into Seller Central, navigate to Inventory → FBA Inventory → Manage FBA Inventory, and filter by fulfilment centre location. If any of your ASINs show stock at BRU1 or LGG1 and you do not have Belgian VAT registration, this is an immediate compliance issue that is independent of the threshold change and requires a VAT advisor consultation.
2. Review your Belgian B2C sales volume for the past 12 months. Pull your sales data by destination country from Seller Central or your marketplace platform. If Belgian annual B2C sales are between EUR 20,000 and EUR 35,000, you are in the range where the threshold change has a direct effect on your VAT position options — get a VAT advisor review before the legislation takes effect.
3. Do not act on the threshold change until the Belgian legislation is formally enacted. The announcement is credible and the change is expected to pass, but the effective date is not yet confirmed. A Belgian VAT advisor can monitor the legislative progress and notify you when the effective date is confirmed — at which point any registration or deregistration decisions can be made on a firm legal basis rather than on an announcement that has not yet become law.
Pre-Amazon storage in Europe and B2C fulfillment in Europe at FLEX. support sellers managing Benelux B2C delivery from German and Polish locations, with documentation that supports multi-country VAT compliance regardless of which Belgian threshold applies.Belgium’s Higher VAT Threshold Helps Some Sellers, but Changes Nothing for Others
Belgium's VAT exemption threshold increase from EUR 25,000 to EUR 30,000 is a meaningful regulatory change for cross-border e-commerce sellers — but its practical impact varies significantly depending on whether the seller is already enrolled in OSS, whether they have goods stored in Belgian Amazon FCs, and what their total EU cross-border sales volume is relative to the EUR 100,000 cross-border scheme ceiling. Sellers already using OSS are largely unaffected operationally but should review whether OSS remains optimal at their specific Belgian sales level. Sellers with goods in Belgian FCs have a Belgian VAT obligation that exists independently of any threshold. Sellers not yet enrolled in OSS and below EUR 10,000 in total EU cross-border sales have the most direct benefit from the threshold increase. The timing issue — pending legislation with an uncertain effective date — means the correct posture is to plan for the change, not to act on it unilaterally before it is law.
Located in Central Europe, FLEX. Logistics provides B2C fulfillment and customs clearance for e-commerce sellers shipping into Belgium and the Benelux from German and Polish locations — with documentation that supports multi-country VAT compliance across Germany, Belgium, Netherlands and France.
Get in touch for a free logistics and VAT documentation assessment.
