Amazon Store
The largest designated marketplace in the Union.
- Tier
- VLOP — very large online platform
- Provider
- Amazon EU S.à.r.l.
- Sector
- Marketplace
- Designated
- 25 April 2023
- Obligations from
- 25 August 2023
- EU users at designation
- 181.3 million
- Formal proceedings
- None to date
- Court challenges
- T-367/23
Designated 25 April 2023 on 181.3 million average monthly active recipients in the Union.
Amazon challenged elements of its designation before the General Court, in particular the Article 39 advertising repository obligation. No formal proceeding has been opened to date.
Where Amazon Store sits in the tier
Designation is not a ranking, and the obligations do not scale with size: the smallest designated service carries exactly the same duties in Articles 33 to 43 as the largest.
Marketplace duties stack underneath the designated tier
A platform that lets consumers conclude distance contracts with traders carries Section 4 of Chapter III on top of everything designation adds. Article 30 is a know-your-business-customer rule: before a trader can offer anything, the marketplace must collect name, contact details, payment account, and trade register information, and make best efforts to assess whether that information is reliable and complete.
Article 31 requires compliance by design — the interface must be built so traders can actually meet their own legal obligations. Article 32 is the right to information: where the provider learns an illegal product was offered, it must tell affected consumers who bought it in the preceding six months, identify the trader, and set out the means of redress.
This is where enforcement against marketplaces has concentrated. Every marketplace proceeding opened to date pairs an allegation about illegal products with an allegation about the systems meant to keep them off the service.
- Article 30
- Trader traceability, with a Commission-run database of trader information under Article 32(3).
- Article 28
- Protection of minors, where the marketplace is accessible to them.
Before the courts
Amazon EU Sàrl v Commission — challenge to VLOP designation
Amazon sought annulment of its designation, arguing among other things that the asymmetric obligations — and the Article 39 advertising repository in particular — infringed rights under the Charter of Fundamental Rights.
On 19 November 2025 the General Court rejected the action in its entirety, finding that none of the invoked Charter rights had been violated and that the Commission’s designation decision was legally sound.
Taken with the Zalando judgment ten weeks earlier, this leaves the designation mechanism itself judicially unshaken at first instance. Both challenges to being designated at all have now failed.
Amazon Store timeline
- 25 April 2023 Designated a VLOP by Commission decision.
- 25 August 2023 Articles 33 to 43 begin to apply, four months after notification.
- 19 November 2025 General Court judgment in T-367/23: dismissed.
What Amazon Store has to do
Designation applies the asymmetric obligations in Articles 33 to 43. They are the same for every designated service, read against a platform surface. Terms used on this page are collected in the glossary.
- Article 34 Systemic risk assessment
- Article 35 Mitigation of risks
- Article 37 Independent audit
- Article 38 Recommender systems without profiling
- Article 39 Advertising repository
- Article 40 Data access for the Commission and vetted researchers
- Article 41 Internal compliance function
- Article 42 Transparency reporting
- Article 43 Supervisory fee
Related designations
Other marketplace services in the tier: Shein, AliExpress, Temu, Zalando, Google Shopping.
Designated on the same day (25 April 2023): Google Search, Bing, YouTube, Google Play, Google Maps, Facebook, Instagram, Wikipedia, TikTok, Pinterest, App Store, X, AliExpress, Snapchat, Zalando, Google Shopping, LinkedIn, Booking.com.