PURPOSE AND OBJECTIVE
German online retailers have spent years building their consumer compliance around the OSS. One registration and one return cover VAT on sales to consumers in every EU country. For many finance teams that has made cross border selling feel solved.
However, it is solved only inside the EU and only for VAT. As retailers grow their own web shops into the UK and the US, take on new packaging rules across the EU and process a high volume of returns, obligations build up outside the system they have put in place. This report sets out four areas where that happens, what each one means for margin and cash and what the finance team should check now.
SECTION 1
Who tracks your online sales outside of your marketplace
| £0 UK VAT registration threshold for sellers established outside the UK | £135 Consignment value (roughly €155) up to which UK VAT is charged at the point of sale | 13 July 2026 UK confirms removal of customs duty relief on consignments of £135 or less |
The OSS does not cover the UK or the US. In both markets a marketplace accounts for tax only on orders placed through it.
In the UK a seller established outside the UK has no registration threshold, so VAT is due from the first taxable sale. For goods of £135 (roughly €155) or less sold through the retailer’s own web shop, the retailer must charge and account for UK VAT at the point of sale. Above that value normal VAT and customs rules apply on importation instead. On 13 July 2026 His Majesty’s Revenue and Customs (HMRC) and HM Treasury also confirmed that customs duty relief on consignments of £135 or less will be removed.
In the US marketplace facilitator laws require platforms like Amazon and Etsy to collect and remit sales tax on their orders. Those laws do not reach orders placed on the retailer’s own web shop.
A retailer growing direct sales in either market takes on an obligation no platform is covering. Unregistered sales then build up as back tax and penalties on revenue already booked.
Where the obligation sits by sales channel
| Sales channel | UK | US |
| Marketplace order | Marketplace accounts for VAT on goods of £135 or less | Marketplace collects and remits sales tax under facilitator laws |
| Own web shop order | Retailer charges and accounts for UK VAT from the first sale | Retailer registers and collects once a state threshold is met |
| Covered by OSS | No | No |
SECTION 2
Every US state is a separate sales tax registration with its own threshold, rates and returns
| 45 + DC States plus the District of Columbia that levy sales tax | $100,000 Most common annual sales threshold for remote sellers | $500,000 Threshold in California and Texas |
There is no federal VAT in the US and no equivalent of the OSS. Sales tax is levied by 45 states and the District of Columbia, plus thousands of local jurisdictions that add their own rates. Each state decides when a remote seller must register. Most use a $100,000 annual sales threshold while California and Texas set $500,000.
The tests are also changing. Illinois removed its 200 transaction threshold on 1 January 2026 and Kentucky did the same on 1 August 2026. Once registered, the retailer files returns in each state on that state’s own schedule. Product taxability differs too. Clothing, for example, is exempt in some states and taxable in others.
German consumer prices include VAT, whereas US sales tax is added at checkout and calculated on the customer’s delivery address. The web shop therefore has to apply the right rate to every order. A retailer that registers late owes sales tax it never collected from the customer, paid out of margin.
Remote seller thresholds and recent changes
| State | Annual sales threshold | Recent change |
| Most states | $100,000 | Varies by state |
| California | $500,000 | No recent change |
| Texas | $500,000 | No recent change |
| Illinois | $100,000 | 200 transaction test removed 1 January 2026 |
| Kentucky | $100,000 | 200 transaction test removed 1 August 2026 |
SECTION 3
Every parcel you ship abroad is packaging placed on that country’s market
| 12 Aug 2026 New EU packaging regulation and German VerpackDG take effect | 27 EU member states, each with its own producer register and fees | €500+ Reported cost of registering separately in each country |
On 12 August 2026 the EU Packaging and Packaging Waste Regulation (PPWR), together with the new German VerpackDG law, replaced the German VerpackG. Packaging used for online orders now counts as e-commerce packaging.
A German registration covers Germany only. Every EU country has its own producer register and fees. An online retailer based in Germany that sells to consumers in Austria must appoint an authorised representative there, register and pay fees.
The requirement is live now. The proposed suspension for EU established producers has stalled, because the Council dropped the Extended Producer Responsibility (EPR) provisions from its mandate in June and nothing has been adopted. One trade press report puts the cost of registering separately in each country at over €500.
For a retail CFO EPR becomes part of cost per order in every market. Packaging data by material and weight also has to be available country by country.
SECTION 4
Every cross border refund is a VAT correction that has to match the original sale and its rate
| 1 in 4 Online orders in Germany that are returned | Up to 50% Return rate in fashion |
About one in four online orders in Germany is returned. In fashion the rate can reach 50%. Each refund on a cross border sale has to be corrected through the OSS return and matched to the original sale.
Destination rates keep changing. Estonia rose to 24% on 1 July 2025 and Romania to 21% on 1 August 2025. Finland’s main reduced rate fell to 13.5% on 1 January 2026. A refund therefore has to be traced back to the rate that applied when the sale was made, not the rate on the day of the refund.
Consumer prices include VAT, so a retailer has to keep price lists and refund workflows current. Otherwise VAT is over or under declared on the return while margin per order slips.
Recent VAT rate changes in EU destination markets
| Country | Rate | Previous | New | Effective |
| Estonia | Standard | 22% | 24% | 1 July 2025 |
| Romania | Standard | 19% | 21% | 1 August 2025 |
| Finland | Main reduced | 14% | 13.5% | 1 January 2026 |
SUMMARY
Four areas outside the system you have built
| Area | Impact for the finance team | How Tax Desk can help |
| Own web shop sales into the UK and US | Back tax and penalties on revenue already booked | UK VAT registration and returns; US sales tax registration and filing |
| US state sales tax | Sales tax paid out of margin after late registration | US sales tax registration and filing |
| EU packaging EPR | Packaging fees become part of cost per order in every market | EPR compliance across markets |
| Cross border refunds | VAT over or under declared; margin per order slips | OSS returns and corrections |
What well prepared retailers do differently
They map tax by sales channel as well as by country, rather than assuming marketplace collection covers the whole business. They track direct US sales state by state and register before a threshold is crossed, not after. They hold packaging data by material, weight and destination country so EPR reporting is a routine task. And they link every refund to the date and rate of the original sale before it reaches the OSS return.
CFO checklist
- Split UK and US revenue by sales channel and confirm who accounts for tax on each
- Check whether the business has made UK web shop sales of £135 or less without a UK VAT registration
- Track direct US sales state by state against current thresholds, including the Illinois and Kentucky changes
- Confirm the web shop calculates US sales tax on the customer’s delivery address
- List every EU country receiving parcels and confirm producer registration and an authorised representative where needed
- Confirm packaging data by material and weight is available for each country
- Check that refund workflows apply the VAT rate from the original sale date
- Confirm price lists reflect current destination VAT rates
For German retailers weighing how these four areas apply to their own cross border sales, please speak to the Tax Desk team.
www.taxdesk.com This report has been prepared by Tax Desk for general information purposes and does not constitute tax or legal advice. Thresholds, rates and regulatory details are drawn from publicly available sources. The euro equivalent of £135 is approximate and depends on the exchange rate. All details should be independently verified before making registration, filing or pricing decisions.
