The one-sentence answer

The €10,000 threshold only exists for businesses established in a single EU member state; if your business has no EU establishment at all — you're based in the UK, the US, or anywhere else outside the EU — there's no threshold and no grace period, and which scheme you use instead (Union OSS, Non-Union OSS, IOSS, or standard import VAT) depends on what you sell and where it ships from.

This is a self-check aid, not tax advice. See the disclaimer at the bottom before you act on anything here.

The €10,000 threshold is an EU-establishment perk

Every other page on this site — the calculator, the decision guide, the worked examples — describes the €10,000 threshold as a simplification: while your combined cross-border B2C sales to other EU countries stay at or under €10,000, you can keep charging your home country's VAT rate instead of the destination country's. That simplification exists specifically for sellers established in the EU. It's how the Netherlands' Chamber of Commerce (KVK) describes it for Dutch sellers, and it's consistent across every VAT-compliance source that covers the rule: the €10,000 figure only ever appears alongside "EU-established" as a precondition.

If you run a Shopify or WooCommerce store from London, Los Angeles, or anywhere else outside the EU's 27 member states, that precondition simply isn't met — and no amount of low sales volume changes that. From the very first B2C sale you make to an EU consumer, EU VAT law treats you the way it treats an EU seller who's already crossed €10,000: destination-country rules from day one.

The threshold calculator and decision guide both assume you're an EU-established seller working out whether you've crossed €10,000. If you're not EU-established, that's the wrong question — the right one is which scheme below applies to you instead.

Four situations, four different routes

"Non-EU seller" isn't one scenario — which mechanism replaces the €10,000 threshold for you depends on what you're selling and where it physically ships from:

Your situation What applies Where you register
Digital/telecoms/broadcasting (TBE) services — SaaS, e-books, streaming, online courses — sold B2C to EU consumers Destination VAT from sale one, via the Non-Union OSS scheme Any one EU member state of your choosing
Physical goods dispatched from stock you already hold inside the EU (e.g. a UK or US brand using an EU fulfilment centre) Destination VAT from sale one, via the Union OSS scheme The member state the goods dispatch from (locked in for that year + the next two if you hold stock in more than one)
Physical goods shipped directly from outside the EU, €150 or less per consignment (typical dropshipping/POD) Destination VAT collected at sale via IOSS — not OSS, and not this calculator's threshold at all Via an EU-based intermediary you appoint (you can't self-register for IOSS without an EU establishment)
Physical goods shipped from outside the EU, worth more than €150 Standard import VAT and customs declaration — no OSS/IOSS simplification available Typically via a customs broker or local VAT registration at import

Notice what's absent from every row: a €10,000 figure. That's the point — the threshold isn't a lower-tier version of these rules, it just doesn't exist for this list of sellers.

UK sellers specifically

This trips up a lot of formerly-EU sellers: since Brexit took full effect on 1 January 2021, the UK is a "third country" for EU VAT purposes — the same category as the US, Canada, or anywhere else outside the EU's 27 member states. The EU-wide distance-selling thresholds UK businesses could rely on while the UK was still an EU member no longer apply to them at all. A UK-based seller today is in exactly the same position as any other non-EU seller in the table above: no threshold, destination rules (or IOSS) from the first sale, and — for digital services — the Non-Union OSS scheme rather than the Union scheme most of this site's other pages describe.

Don't confuse this with the guide's "established in one country" question

The decision guide's fifth question asks whether you're established in a single EU member state, and warns that sellers spread across several member states (the classic multi-country Amazon FBA case) lose access to the €10,000 threshold too. It's easy to read that and assume it covers the situation on this page — it doesn't. That question is about EU businesses whose EU footprint happens to be fragmented across more than one country. This page is about businesses with no EU establishment at all. Both groups end up without the €10,000 buffer, but for different reasons, and they land on different registration routes (a fragmented EU seller still can't avoid destination VAT, full stop; a non-EU seller has the Union/ Non-Union/IOSS menu above to pick from depending on what and how they sell).

What to do right now

Sources

Disclaimer

This page and the calculator are a self-check aid, not tax advice. Non-EU VAT obligations depend heavily on your specific supply chain, what you sell, and which platforms or intermediaries you use — the general routes above can differ by member state and change over time. Verify your own situation against the EU Commission's One Stop Shop portal or an accountant before relying on anything here.