- Short answer
- IOSS covers imports in consignments up to €150; OSS covers goods already inside the EU — where your stock sits decides.
- Stock first, establishment second
- Where the goods ship from decides the scheme; where you are established decides who may use which one.
- €150 is per consignment
- One consignment's goods value, before VAT and shipping — not an annual total, not a per-customer figure.
- OSS is two schemes, not one
- The Union scheme covers goods and B2C services; the non-Union scheme covers services of non-EU sellers only.
- Non-EU sellers using IOSS
- A taxable person not established in the EU must appoint an intermediary.
- Law and platform differ
- EU law allows more than one registration; the Shopify admin does not support both.
- Locations on both sides
- Shopify's two pages disagree: the migrate page says set up OSS, the tax reference says OSS skips non-EU stock.
- €10,000 can mean no OSS
- Below the combined €10,000 a year, the Union scheme is optional — those sales can stay taxable at home.
What IOSS and OSS each cover
Most merchants arrive expecting two schemes. The European Commission describes the enlarged One Stop Shop as covering three special schemes: the non-Union scheme, the Union scheme and the import scheme. In everyday use "OSS" means the first two (most often just the Union scheme); IOSS is the third. Each covers a different kind of supply and is open to a different kind of seller.
| Scheme | What it covers | Who can use it |
|---|---|---|
| Non-Union scheme | Cross-border B2C services sold to EU consumers — no goods at all | A business with no place of business or fixed establishment in the EU |
| Union scheme (the OSS people mean) | Intra-Community distance sales of goods, and B2C services taking place in a Member State where the seller has no establishment | A business established in the EU; a non-EU business may use it for certain supplies of goods |
| Import scheme (IOSS) | Distance sales of goods imported from outside the EU in a consignment not exceeding EUR 150 and not subject to excise duties | A business established inside or outside the EU; a non-EU seller must appoint an intermediary |
Which one your Shopify store needs
The test is where your stock physically sits when an order ships — not where your company is registered, and not which EU country the customer is in, though stock and customer in the same Member State makes the sale domestic rather than an intra-Community distance sale.
Sell from a warehouse in Poland to a consumer in Spain and the sale is an intra-Community distance sale, which is Union-scheme territory. Ship the same product in from a supplier outside the bloc and it is a distance sale of goods imported from a third territory or third country, which the import scheme covers as long as the consignment does not exceed EUR 150 and the goods are not subject to excise duties.
The European Commission draws that dispatch line explicitly.
Please note that the goods have to be dispatched/transported from a third territory/third country to fall under this definition. Goods already stored in a warehouse in the EU are not covered
Where you are established matters later, and differently. A business established inside or outside the EU can use the import scheme, but a taxable person not established in the EU who wants to use it needs to appoint an intermediary. If the import scheme is your answer, the next question is who actually holds that registration.
Can you use both IOSS and OSS?
EU law and the Shopify admin answer this differently, and both answers apply to you. The Commission's registration page asks whether a taxable person can register for more than one scheme and answers yes, because the schemes cover different supplies and are open to different taxable persons: a business established in the EU can use the Union scheme and the import scheme, and one not established in the EU could possibly use all three. The Shopify admin does not follow that.
Using OSS and IOSS at the same time isn't supported, so the option to collect VAT on orders shipped from outside the EU to customers within the EU using the IOSS is disabled.
That has a practical shape for stores holding stock on both sides of the border. Shopify states that if you have locations both inside and outside the European Union, then you can't use both OSS and IOSS in Shopify simultaneously, and in that case you should set up OSS, and VAT is applied on all orders to European Union customers regardless of the fulfillment location.
Shopify's EU tax reference page says the opposite for goods shipped in from outside the EU: there, OSS registrations don't apply and you should use an IOSS registration instead. Confirm which behaviour your store gets with a test order or with Shopify support.
The two thresholds that get mixed up
€150 and €10,000 are not two versions of one limit. The €150 is the intrinsic value of the goods in a single consignment, calculated before VAT and shipping: the import scheme covers goods imported in a consignment of a value not exceeding EUR 150, provided they are not subject to excise duties. It is not an annual total, it is not a per-customer figure, and it does not accumulate across a year of orders.
€10,000 is annual, and it belongs to the Union scheme. The Commission is explicit that the number is combined: the threshold of EUR 10 000 is not counted separately for cross-border TBE services and intra-Community distance sales — the sum of all of these supplies must not exceed EUR 10 000, without VAT, in the current and the preceding calendar year. Below that figure those supplies can remain taxable in the seller's own Member State, and the Union scheme is optional — but only where the supplier is established in one single Member State and the goods are dispatched from that same Member State.
The import scheme and the Union scheme are VAT machinery — the Commission describes IOSS as simplifying the declaration and payment of VAT — while customs duty on EU imports is a separate charge with its own rules.
This article was written entirely by AI under human editorial direction. The editor sets the topic and structure, runs multi-stage validation on facts, links, and interactive elements, and verifies the output is useful from a business perspective. All claims are checked against official Shopify sources. Details may change — always confirm critical data at shopify.com.
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