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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.
From 1 April 2026 — one week from today — non-EU businesses filing VAT refund requests in the Netherlands under the EU Thirteenth VAT Directive must use the Dutch tax authorities' online portal exclusively. Paper submissions will no longer be accepted. This is not an extension of an existing deadline: it is a hard cutoff on a previously accepted submission method. Non-EU sellers who have been filing paper VAT refund requests to the Belastingdienst (Dutch Tax and Customs Administration) and have not yet registered for the online portal face a situation where their 2025 refund claims — due by 30 September 2026 for calendar year 2025 — cannot be submitted through the channel they have been using, and where obtaining the digital access credentials required for the new portal takes time that the deadline does not accommodate if registration is not started immediately.
For Amazon sellers and EU e-commerce importers who route goods through Rotterdam — one of the most common entry points for containerised cargo destined for German and Central European FBA fulfillment centers — this change is operationally relevant. Rotterdam-routed shipments that incur Dutch import VAT generate a 13th Directive refund entitlement for non-EU businesses that do not have a Dutch VAT registration. Those refunds are now exclusively available through the online portal, and the digital credential process has a lead time that the 1 April deadline makes urgent for any non-EU seller who has not yet begun the registration.
Who Is Affected: Non-EU Businesses with Dutch VAT Refund Entitlements
The Netherlands 13th Directive VAT refund scheme applies to businesses established outside the EU that incur Dutch VAT on goods or services purchased in the Netherlands — without being VAT-registered in the Netherlands themselves. The most common situation for e-commerce importers is Dutch import VAT incurred when goods enter the EU through Rotterdam and the customs entry records the Netherlands as the country of import. Non-EU sellers (US, UK post-Brexit, Chinese, and other third-country businesses) who use Rotterdam as their EU entry port and whose customs declarations record Dutch import VAT may have a 13th Directive refund entitlement that they have been claiming annually through paper submissions to the Belastingdienst.
EU-established businesses do not use the 13th Directive — they reclaim Dutch VAT through the EU 8th Directive refund mechanism (the Belastingdienst's 'teruggaaf' online portal) or through their own Dutch VAT registration if they have one. The 1 April change specifically affects non-EU businesses — those outside the EU VAT refund system who must use the third-country (13th Directive) channel. If your business is established in the US, UK, Canada, Australia, China, or any non-EU country and you have incurred Dutch import VAT on Rotterdam-routed shipments in 2025 or prior years, the 1 April portal-only rule applies to your refund claims. Dutch import VAT refund eligibility assessment for non-EU e-commerce importers assesses whether Rotterdam-routed inbound shipments to the seller's EU supply chain have generated Dutch import VAT that qualifies for 13th Directive refund — reviewing customs entry records for Netherlands import VAT documentation and confirming the seller's non-EU establishment status that makes the 13th Directive mechanism applicable.
What the Portal Requires: DigiD, eHerkenning, and the Registration Lead Time
The Dutch tax authority's online portal for non-EU VAT refund requests requires digital identity credentials to access. For individuals acting on behalf of a non-EU business, the relevant credential is eHerkenning — the Dutch government's business digital identity system. eHerkenning is not a free registration: it requires purchasing access from a recognised eHerkenning provider (a list of approved providers is maintained by the Dutch government), completing an identity verification process, and linking the credential to the business entity that is filing the VAT refund claim. The commercial eHerkenning providers charge annual subscription fees ranging from approximately EUR 50 to EUR 150 per year depending on the assurance level required.
The registration and verification process for eHerkenning typically takes 5 to 10 business days from application to credential issuance — a timeline that, measured against the 1 April 2026 deadline, means that non-EU sellers who have not yet begun registration have approximately 5 working days remaining before the deadline to initiate the process if they want to guarantee credential availability by the portal's effective date. Sellers who miss the 1 April implementation date will not lose their 2025 refund entitlement immediately — the 2025 refund deadline is 30 September 2026 — but will be unable to submit through either channel (paper now discontinued, portal not yet accessible) until eHerkenning registration is complete. eHerkenning registration support and Dutch VAT portal access for non-EU businesses supports non-EU sellers in initiating the eHerkenning registration process with an approved Dutch provider — identifying the correct assurance level for 13th Directive portal access, coordinating the identity verification documentation, and confirming portal access capability before the refund submission deadline for 2025 claims.
What Happens If You Miss the 1 April Deadline
Missing the 1 April portal transition does not mean losing the VAT refund entitlement for 2025 — that entitlement survives until the 30 September 2026 claim deadline. What it means is a gap in submission capability: from 1 April, paper submissions are rejected, and without eHerkenning credentials the portal is inaccessible. The practical consequence is that 2025 VAT refund claims for Rotterdam-routed import VAT cannot be submitted until eHerkenning registration is completed, and the registration process itself may take 5 to 10 business days from the point it is initiated. A seller who realises the deadline has passed in late April and begins eHerkenning registration immediately may have portal access by mid-May — still well within the 30 September 2025 claim deadline, but with 6 weeks of unnecessary delay that could have been avoided by registering before 1 April.
The more significant risk is for sellers who are unaware of the change entirely and continue expecting paper submissions to be processed. A paper VAT refund claim submitted after 1 April 2026 will not be processed by the Belastingdienst — it will be rejected and returned, or simply not acknowledged. Sellers whose Dutch VAT refund claims represent material amounts — Dutch import VAT at 21 percent on Rotterdam-routed container cargo generates EUR 21,000 of refundable VAT per EUR 100,000 of customs value — should treat the portal registration as an urgent compliance action rather than an administrative detail. Netherlands 13th Directive VAT refund claim management and portal submission support manages the annual Netherlands 13th Directive VAT refund claim process for non-EU sellers with Rotterdam-routed import VAT — compiling the Dutch import VAT documentation from customs records, preparing and submitting the refund claim through the Belastingdienst online portal within the 30 September annual deadline, and tracking the Belastingdienst's processing of the claim through to payment.
Rotterdam-to-Germany Supply Chain: The Import VAT Optimisation Decision
The Netherlands 13th Directive refund change is also an appropriate moment to review whether Rotterdam is still the optimal EU entry port for Asia-bound cargo destined for German FBA fulfillment centers — and whether the Dutch import VAT refund process is the right VAT optimisation mechanism for the seller's supply chain or whether alternative customs and VAT structures would be more efficient.
Non-EU sellers who import through Rotterdam and then transport goods to Germany incur Dutch import VAT (21 percent) that they can reclaim through the 13th Directive mechanism — but this requires annual claim administration and a waiting period of up to 12 months for the refund to be processed. An alternative structure for sellers with sufficient import volume is to use German import entry (Hamburg) rather than Dutch import entry (Rotterdam), incur German import VAT (19 percent — two percentage points lower than Dutch) that is reclaimable through the German §21a Aufschubkonto deferment mechanism with same-month offset rather than an annual refund cycle. The 13th Directive refund and the German §21a deferment serve the same underlying purpose — recovering import VAT on goods that will be sold from the EU — but the German mechanism operates as a same-month offset while the Dutch mechanism operates as an annual claim. For sellers importing multiple container loads per month, the cash flow difference between monthly offset and annual refund is material. Rotterdam vs Hamburg import VAT structure comparison for non-EU FBA sellers models the import VAT cash flow comparison between Rotterdam-entry with 13th Directive annual refund and Hamburg-entry with §21a monthly deferment — calculating the working capital cost of the Dutch annual refund wait against the German same-month offset, the duty rate differential between Dutch and German import entries, and the transport cost differential between Rotterdam-to-German-3PL and Hamburg-to-German-3PL routing, to identify the import structure that minimises total landed cost and maximises import VAT cash flow efficiency for the seller's specific volume and supply chain configuration.
Dutch 13th Directive Portal Change Makes Rotterdam VAT Refunds an Immediate April Compliance Action
The Netherlands 13th Directive VAT refund portal change on 1 April 2026 is a narrow but time-sensitive compliance action: non-EU businesses with Rotterdam-routed import VAT refund entitlements have approximately 5 working days to initiate eHerkenning registration if they want to guarantee portal access before the paper submission deadline expires. The refund entitlement itself — Dutch import VAT at 21 percent on Rotterdam-routed customs value — does not expire until 30 September 2026 for 2025 claims, but the submission channel does. Act now on the registration; use the additional time to review whether the Rotterdam import VAT structure is the most efficient mechanism for the scale and frequency of your EU import programme.
FLEX Logistics provides EU-wide customs clearance, import VAT management, and compliance support for non-EU Amazon sellers importing through Rotterdam and Hamburg — including eHerkenning registration coordination for the Netherlands 13th Directive portal, German §21a deferment account management, and the import structure review that identifies whether Rotterdam or Hamburg entry optimises import VAT cash flow for each seller's specific supply chain configuration.
Located in the center of Europe, FLEX Logistics provides import VAT compliance support, customs clearance, and Netherlands 13th Directive refund management for non-EU Amazon sellers importing through Rotterdam and Hamburg.
Get in touch for a free quote and import VAT structure assessment — and confirm your eHerkenning registration before the 1 April deadline.
