GDPR Compliance for Amazon Sellers

If you sell on Amazon EU marketplaces (Amazon.co.uk, Amazon.de, Amazon.fr, Amazon.it, Amazon.es, Amazon.nl, Amazon.se, Amazon.pl) from outside the EU, GDPR applies to your business. And contrary to a common myth, Amazon does not handle GDPR compliance on your behalf.

Amazon Does Not Provide Your EU Representative

Many third-party sellers mistakenly believe Amazon’s EU entity or its GDPR compliance infrastructure covers them. It does not. Amazon is a data processor; you are the data controller. The obligation to appoint an EU Representative under Article 27 rests with you as the seller.

What Data Do Amazon Sellers Process?

• Customer names and shipping addresses — personal data (Article 4(1))
• Email contact — Amazon provides buyer-seller messaging; these communications contain personal data
• Order histories — purchase records tied to individuals
• Returns and refunds — customer contact data during dispute resolution
• Tax and customs data — VAT numbers, customs declarations, import data

Selling Scenarios

FBA (Fulfilled by Amazon)

Amazon handles logistics but you are still the data controller for customer data. Amazon stores and ships products, but the customer relationship — and the GDPR obligations — are yours.

FBM (Fulfilled by Merchant)

You receive EU customer data directly for shipping. Full Article 27 obligation applies clearly.

Amazon EU Direct

Selling on Amazon Germany, France, Italy, Spain, Netherlands, Sweden, or Poland from outside the EU. You process EU personal data and need compliance.

3-Step Compliance for Amazon Sellers

1. Appoint EU Shield — EUR 490/year, covers all Amazon EU marketplaces
2. Update your Amazon Seller Privacy Policy — include EU Representative contact
3. Document your processing — ROPA covering Amazon customer data flows

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