Fulfilment from Poland to Germany: what to verify.

Checklist for Poland to Germany fulfilment

Sellers tend to look at this route as a delivery problem: how far, which carrier, what it costs. Delivery is the part that is easiest to fix. The expensive surprises come from tax set-up, packaging registration and returns, because they surface late and they are your responsibility, not the warehouse's.

First: intra-EU trade is not import

The two are easy to confuse. According to the Commission, no customs duties are paid on goods moving between EU Member States, and goods legally imported into the EU can then circulate without further customs checks. Under the VAT Directive, importation means goods entering the EU that are not in free circulation (Article 30).

One trap for sellers bringing goods from outside the EU: the Commission states that goods already stored in an EU warehouse do not qualify as distance sales of imported goods, so the import scheme of the OSS does not fit stock held in Poland. Importing into a warehouse and then selling are two steps, and each has its own VAT treatment.

Stock location: know exactly where the goods sit

Location decides your VAT position, your delivery options and your returns path, so ask directly where your goods will sit.

• Which country, and which building, holds your stock?
• Could the provider move your goods to another site or another country? If so, who decides, and who is told? A move across a border can have VAT consequences for you.
• Is a German return address a real site with staff or a forwarding point? Neither is wrong, but they work differently.
• How is your stock kept apart from other clients' stock, and what does the stock report show?

VAT: find your scenario first

Your answer depends on where you are established, where the goods leave from and who buys them. The table summarises Commission guidance. That guidance is not legally binding, and national rules still apply.

The OSS return is additional to your normal VAT return and does not replace it. VAT on business costs incurred in another Member State cannot be offset through it.

Stock transfer: the event sellers overlook

Moving your own goods from Germany to a Polish warehouse feels like logistics. No sale, no customer, same owner. VAT law sees something else: Article 17 of the VAT Directive treats the transfer of business goods to another Member State as a supply for consideration, subject to the exceptions in Article 17(2). Article 138(2)(c) contains the exemption framework for such transfers, and Article 262 brings them into the recapitulative statement.

Put the following on your adviser's list before the first truck leaves:

• VAT registration in the country of storage, and in the country of departure if you are not already registered there.
• The transfer value used on documents, and the transport evidence you keep.
• What happens when stock moves back, for instance at the end of a contract.
• Whether the new transfer of own goods scheme, which the Commission says enters into force on 1 July 2028, changes your plans.

Packaging: German rules changed on 12 August 2026

Advice that cites the Verpackungsgesetz as current law needs a second look. The Central Agency Packaging Register (ZSVR) now says the EU Packaging and Packaging Waste Regulation (PPWR) and the German VerpackDG took its place on that date. How the transition works in detail is something to confirm with a lawyer. For a merchant, the practical checks look like this:

• Register in LUCID. The ZSVR states that a producer must register with the LUCID Packaging Register, and VerpackDG section 6 requires this before first making packaging available.
• Join a system. The ZSVR says packaging intended for shipment is always subject to system participation, and it tells sellers to conclude a system participation agreement with a system operator and to file their volume reports in LUCID.
• Establish your role. A name, logo or brand on the packaging makes the ordering company manufacturer and producer. The ZSVR also treats a seller shipping directly from abroad to German end users as, at a minimum, manufacturer and producer of the shipping packaging used.
• Appoint a representative. Since 12 August 2026 the ZSVR says a company without a German branch that sells directly to German end users must appoint an authorised representative. Under VerpackDG section 5 there can be only one, and the appointment must be in writing and in German. Registration remains your own duty.

If you sell electrical goods or anything containing batteries, there are separate regimes. The German ElektroG requires registration by device type and brand before placing devices on the market, and section 8 requires certain producers without a German establishment to appoint a representative. The Federal Environment Ministry says the BattDG replaces the former Batteries Act (BattG), so advice citing BattG needs a second look.

Carriers: what to look at beyond the price

• Which delivery types do your German customers expect: home, pick-up point, parcel locker, signature? Which of those does the carrier service include?
• Weight and size limits, and how surcharges for oversized or non-standard parcels are triggered.
• Tracking events: which ones reach your shop, and in which language do customers see them?
• Claims: who files a loss or damage claim, by when, and with what evidence? Whose contract is it, yours or the provider's?
• Pallets to German trade customers: booking slots, tail lift needs, retailer routing guides and proof of delivery.
• Which delivery promise can your shop realistically make? Base it on the carrier service used and your own test parcels.

Returns: plan the way back before the way out

German customers who withdraw send goods back to wherever your terms point them. If that address is in Poland, ask these questions early:

• Who pays? Under the Consumer Rights Directive, the consumer bears the direct cost of return unless the trader agreed to bear it or failed to say the consumer must pay. If you plan to pay, what does it cost to bring a parcel back across the border?
• Is there a domestic drop-off for German customers, and what does the label look like?
• How does the refund deadline interact with the transit time? The clock in Article 13 starts when you are informed of the withdrawal. It does not wait for the parcel to reach the warehouse. You may hold the refund until you have the goods or proof of sending. See the logic of returns decisions.
• How does returned stock show up in the stock report, and when is it saleable again?

Consumer rights: the merchant's job, not the warehouse's

• Withdrawal. The 14-day right applies to distance contracts (Directive 2011/83/EU).
• Withdrawal button. Directive (EU) 2023/2673 requires a withdrawal function for distance contracts concluded through an online interface, with national rules to apply from 19 June 2026. In Germany, section 356a BGB has applied since that date and requires the label "Vertrag widerrufen" or an equivalent, unambiguous wording. National implementation can differ in timing, so check the position in each country you sell to. This has to be built into your shop. A warehouse cannot do it for you.
• Faulty goods. The seller is liable for a lack of conformity appearing within two years of delivery (Directive (EU) 2019/771, Article 10), and Member States may set longer periods.
• Which national rules apply to your German sales? Ask your adviser, along with what your German terms and notices must say.

A short list before your first parcel

1. Write down your scenario: where you are established, where stock sits, who buys.
2. Have your tax adviser confirm VAT registrations, OSS and threshold position, and shop tax settings.
3. If stock crosses a border, document the transfer before it moves.
4. Register in LUCID, join a system, appoint a representative, and check your role per packaging type.
5. If you sell electrical goods or batteries, check ElektroG and BattDG with an adviser.
6. Check your German terms, withdrawal function and returns address.
7. Send test parcels and test returns, and see what the customer actually sees.

Where ShipRevo stands

Read more on Poland to Germany fulfilment and our warehouse near Wrocław, and see how 3PL pricing is built if you are comparing providers.

Updated: 2026-11-01