What sellers should know about P2B dispute resolution for sellers now

The notice arrives in your Seller Central inbox on a Tuesday. Your Amazon DE listings are restricted, a payment hold is in place, and the stated reason is a platform-policy violation you may not have anticipated. The question that follows is not abstract: what procedural rights do you actually have under EU law, and what sequence of steps gives you the best chance of reversing this before inventory costs overwhelm the account?

TL;DRThe Platform-to-Business (P2B) Regulation gives EU marketplace sellers enforceable procedural rights against platforms – including the right to a statement of reasons for any restriction, access to an internal complaint-handling system, and, in many cases, access to mediation. On Amazon DE, those rights layer on top of the Amazon Business Solutions Agreement and sit alongside the Digital Services Act framework that applies to Amazon as a designated Very Large Online Platform (VLOP). The path to using them is procedural and sequential, and getting the order wrong early limits what is available later.

This briefing explains what P2B dispute resolution actually is on Amazon DE, the realistic procedural path sellers can follow, the decision points along the way, and what remains uncertain. It is aimed at sellers who have received a restriction notice or are trying to understand these mechanisms before one arrives.

What the P2B Regulation actually requires from Amazon DE

The P2B Regulation imposes concrete process obligations on platforms – and Amazon DE must comply with each of them as a condition of operating in the EU market.

The Regulation – formally Regulation (EU) 2019/1150 on promoting fairness and transparency for business users of online intermediation services – applies to any platform that offers services to business users established in the EU, regardless of where the platform itself is headquartered. Amazon DE falls squarely within its scope. The rules require platforms to provide, at a minimum, a written statement of reasons whenever they restrict or terminate a business user's access, advance notice before restrictions take effect (except in defined urgent circumstances), and an internal complaint-handling system that is accessible, fair, and transparent.

A statement of reasons is not a courtesy. It is a legally required explanation that must identify the specific facts or circumstances that triggered the decision, and the applicable ground from the platform's terms. In matters we handle, sellers frequently receive notices that describe a policy category without identifying the specific conduct or listing that caused the flag. That gap between what the P2B Regulation requires and what the platform actually provides is often the first leverage point.

The internal complaint-handling system must be free of charge and must result in a reasoned outcome within a reasonable period. The Regulation also requires platforms to identify, in their terms of service, at least two mediators they are willing to use if the internal complaint process does not resolve a dispute. Amazon's terms for its EU-facing business include references to mediators for this purpose, though the specific names and terms are subject to change and should be checked in the current version of the agreement applicable to the account.

What the P2B Regulation does not do is require a platform to reinstate every seller who complains, or to give sellers substantive rights over the platform's commercial decisions. The leverage is procedural: if the platform fails to follow the required process, that failure is itself actionable – either through the internal complaint mechanism, through mediation, or, in some cases, through national enforcement bodies or civil litigation.

How does this interact with Amazon's VLOP status under the Digital Services Act?

Amazon's designation as a Very Large Online Platform (VLOP) under the Digital Services Act adds a parallel set of obligations that sellers can, in some circumstances, invoke alongside P2B rights.

The DSA requires VLOPs to provide a statement of reasons for any content moderation or restriction decision, to maintain an internal complaints mechanism that allows recipients to challenge those decisions, and to offer access to out-of-court dispute settlement bodies certified under the DSA. For sellers, this matters because a listing restriction or account deactivation on Amazon DE can constitute a content moderation decision within the DSA's scope, not only a contractual dispute under the BSA.

The practical result is that a seller on Amazon DE may have parallel procedural claims: a P2B complaint based on the adequacy of the statement of reasons and the internal complaint process, and a DSA complaint about the platform's content moderation procedure. These are not mutually exclusive, and running them in parallel – or sequencing them carefully – is one of the strategy questions we work through with sellers early in a matter.

The Digital Markets Act (DMA) gatekeeper framework adds a third layer for sellers affected by practices that go beyond a single account decision and into Amazon's structural behavior as a gatekeeper. For a detailed look at how DMA gatekeeper obligations affect sellers and their accounts, see our analysis on that specific question. The DMA is not a substitute for P2B complaint handling, but understanding where the frameworks overlap matters for sellers facing systemic rather than isolated restrictions.

What is the realistic procedural path after a restriction on Amazon DE?

The procedural sequence moves through defined stages, and each stage has its own timing considerations and strategic trade-offs.

Stage 1: Obtaining and reviewing the statement of reasons. The first step is to obtain a complete statement of reasons if the initial notice does not provide one. Under the P2B Regulation, the platform is required to provide this. If the notice received is a templated policy citation without specific factual grounding, a formal written request for a fuller statement of reasons is appropriate at this stage. The response – or the failure to respond adequately – shapes everything that follows.

Stage 2: The internal complaint-handling system. Amazon's internal complaint-handling system for EU business users is the required next step before mediation is available. In our practice, sellers sometimes skip this step or conflate it with the general Seller Central appeals process. They are not the same thing. The P2B internal complaint mechanism is a distinct, legally required channel, and submitting through it – with a clear invocation of the Regulation – creates a record that is relevant if the matter goes to mediation or litigation. The substance of the complaint matters as much as the channel: a clear identification of the P2B ground, the specific factual gap in the platform's decision, and the requested remedy.

Stage 3: Mediation. If the internal complaint does not resolve the matter, the P2B Regulation requires platforms to identify mediators they are willing to engage. Mediation under the P2B Regulation is non-binding: neither party is required to accept a mediator's proposed resolution. The costs of mediation are to be shared between the parties, with the platform bearing a reasonable proportion. Mediation is not always the right tool – it depends on what the seller is actually seeking and whether the platform is likely to engage constructively. We assess that question case by case.

Stage 4: Enforcement bodies and civil litigation. National enforcement bodies designated under the P2B Regulation (which varies by EU member state) can investigate systemic violations by platforms. For individual sellers, the more direct route is civil litigation in the competent national court. The Regulation gives business users and representative organizations the right to bring proceedings before national courts to stop or remediate violations. This is a realistic option in appropriate cases, and the record built through stages 1 to 3 is directly relevant to any civil claim.

For a fuller treatment of how to structure a response to Amazon as a VLOP, including the sequencing of DSA and P2B mechanisms, see our piece on responding to Amazon as a Very Large Online Platform.

Who is actually affected, and when does P2B dispute resolution become relevant?

P2B protections apply to business users established in the EU – and the scope is broader than many sellers initially assume.

The Regulation covers any restriction on a seller's ability to offer goods or services through the platform, including: account-level deactivations, listing suspensions affecting a category or ASIN, restrictions on Buy Box eligibility, and removal of seller-fulfilled prime status. It also covers modifications to the contractual terms under which the seller operates, where those modifications are applied unilaterally by the platform. Termination of the relationship – complete removal from the platform – triggers the most stringent notice and statement-of-reasons requirements.

Sellers outside the EU who sell into the EU market through Amazon DE should seek specific advice on whether the Regulation's protections extend to their situation; the territorial analysis depends on facts specific to each account. In our experience, the framework is primarily designed to protect sellers established in EU member states, though the analysis does not always end there.

Where P2B dispute resolution becomes most relevant, in practical terms, is when: the platform's stated reason for a restriction does not match the facts of the account; the internal appeal process has produced a form rejection without substantive engagement; or the restriction is causing ongoing financial harm – frozen disbursements, inventory stranded in an FBA warehouse, or lost revenue from a critical sales season.

A seller in any of those situations is not without options. The myth that EU sellers have no leverage once a platform restricts them is exactly that – a myth. The P2B Regulation exists precisely because the EU legislator recognized that the power imbalance between large platforms and individual business users creates a structural enforcement gap that contractual terms alone do not fix.

What are the practical trade-offs at each decision point?

Choosing how to proceed involves weighing a set of trade-offs that are specific to each situation. A decision matrix helps frame the options.

If the restriction is recent and the internal appeal channel has not been used as a P2B mechanism – the realistic route is to start there, framing the submission explicitly under the Regulation. This preserves all later options and is low cost. The risk of not doing this is that a later mediator or court may ask why the internal process was not completed. The timeline for this stage is variable: the Regulation requires a "reasonable period" without specifying a number, and in our experience the response time varies considerably across cases.

If the internal complaint has been submitted and returned with a rejection that does not engage with the substantive grounds – the decision is between mediation and direct civil action. Mediation is faster and cheaper; it is also non-binding, and a platform that rejected the internal complaint without engaging may not engage differently in mediation. Civil action creates a binding outcome, but at greater cost and on a longer timeline. The strength of the record built in stages 1 and 2 directly affects the cost-benefit of moving to litigation.

If the seller's primary goal is to restore cash flow and get disbursements moving – the fastest resolution is almost always to resolve the underlying restriction. Parallel P2B and DSA tracks can apply pressure on the platform to engage, but they do not themselves release held funds. The P2B and DSA channels are strongest as leverage tools when combined with a direct substantive response to whatever the platform's stated reason is.

As enforcement automation has tightened on Amazon DE, we regularly see sellers whose account health flags were triggered by algorithm-driven decisions rather than human review. The P2B Regulation's requirement for a specific factual statement of reasons – not a generic policy citation – is particularly valuable in those cases, because it forces the platform to articulate the actual basis for the decision in terms that can be examined and challenged.

For sellers dealing with related account flags, IP complaints, or simultaneous suspensions across multiple EU marketplaces, the picture is more complex. Our broader EU marketplace regulation guide for sellers addresses the interaction of P2B rights with the DSA, the DMA, and national enforcement regimes across key EU markets.

What remains uncertain, and what to watch

Sellers should understand that several aspects of P2B dispute resolution remain in flux, and the practical operation of these rules continues to develop.

The certification of out-of-court dispute settlement bodies under the DSA is ongoing across EU member states, and the practical availability of certified bodies varies by jurisdiction. The national enforcement bodies designated under the P2B Regulation have differing levels of activity and resource, which affects how meaningful a referral to them is in any given case. Sellers should not treat the enforcement landscape as uniform across the EU.

The relationship between P2B mediation and the arbitration or dispute-resolution terms in Amazon's Business Solutions Agreement is also a live question. The path depends on the BSA version that applies to the account, which we check first – and the interaction between the contractual dispute resolution mechanism and the Regulation's mediation requirements is an area where the law is still developing. A seller who moves to mediation under the P2B framework is not necessarily waiving contractual dispute resolution rights, but that analysis is fact-specific.

National courts in EU member states have begun to develop case law interpreting the P2B Regulation, but the body of decided cases is still limited. The General Court and the Court of Justice of the EU have addressed aspects of the P2B and DSA regimes in the context of broader platform regulation proceedings, but seller-specific precedents remain sparse. This means that well-constructed arguments have genuine room to operate – but also that sellers should not assume a predictable, well-worn path.

What is not uncertain is the basic structure of the rights. The statement-of-reasons requirement, the internal complaint mechanism, the mediation access, and the civil enforcement right are in force and enforceable. Sellers who know how to use them have options that sellers who don't know about them do not.

The steps above describe the standard procedural path. Your situation turns on the exact wording of the restriction notice, the account history, which BSA version applies, and whether a DSA or P2B ground – or both – is in play. That is what we review first.

To discuss your Amazon DE situation, email info@tutamenlaw.com for a short review.

A note on how these matters proceed in practice

If a first P2B complaint or internal appeal has already come back with a form rejection, a fresh read of the submission can often identify the specific reason it did not engage the platform's process – and whether anything remains open. The most common issue we see is that the complaint was framed as a general appeal rather than as a specific invocation of the P2B ground, which allows the platform to route it through the standard appeal track rather than the legally required complaint mechanism.

One matter we handled involved a consumer-electronics seller on Amazon DE (spring 2026) whose account-level restriction notice cited a policy category without any specific factual grounding. We built a P2B statement-of-reasons request, filed a formal complaint through the internal mechanism citing the Regulation explicitly, and applied parallel DSA pressure through the VLOP internal complaint channel. The platform engaged substantively – something it had not done during the seller's earlier unassisted appeal – and the restriction was reviewed. The account returned to full access. The specific factual basis for the original flag had been an automated review of a single ASIN that had since been corrected; without the P2B framing, there was no mechanism forcing the platform to articulate that basis.

A second matter involved a fashion-category seller on Amazon DE (fall 2026) facing a disbursement hold tied to a related-account flag with no clear P2B violation notice – the hold appeared to originate from account-health data rather than a formal restriction decision. We mapped the applicable P2B grounds, assessed whether the hold itself constituted a "restriction" triggering the Regulation's notice requirements, and built the statement-of-reasons and DSA internal complaint records in parallel with a substantive response to the account-health issue. The matter resolved through the internal channel without proceeding to mediation.

Both situations underscore the same point: the procedural record matters, and the framing of the initial submission shapes whether the platform engages or routes the complaint around its own required mechanisms.

If your matter has already reached the rejection stage and you are weighing whether mediation or a direct civil claim is the right next move, a second review of the record can clarify what is still available. Reach out to info@tutamenlaw.com to discuss next steps.

Related areas

• EU Marketplace Regulation – complete guide for sellers – how P2B, DSA, DMA and GPSR interact for Amazon DE and EU marketplace sellers
• DMA gatekeeper obligations and sellers – structural gatekeeper rules that affect seller access and account decisions

Frequently asked questions

How long does resolving P2B dispute resolution for sellers usually take on Amazon DE?

There is no single answer because the timeline depends on which stage the matter reaches and how quickly the platform engages. The P2B Regulation requires the internal complaint-handling system to produce a result within a "reasonable period" – a deliberately flexible standard that the Regulation does not quantify in days or weeks. In our experience, internal complaint outcomes on Amazon DE arrive across a wide range. Mediation under the P2B framework, if it is reached, typically takes longer than the internal complaint stage. Civil proceedings in a national court operate on that court's own timetable, which varies significantly by jurisdiction and case complexity. The most durable thing a seller can do to compress the timeline is to submit a well-framed, factually specific complaint at the internal stage – a weak submission invites a form rejection, which adds time.

What are the main risks if I handle P2B dispute resolution for sellers alone?

The primary risk is framing a P2B complaint as a general Seller Central appeal, which allows the platform to route it through the standard appeal mechanism rather than the legally required internal complaint-handling channel. A submission that does not explicitly invoke the Regulation, identify the specific P2B ground, and request a remedy tied to the Regulation's requirements is unlikely to be treated as a P2B complaint at all. The second risk is building a weak procedural record at stages 1 and 2, which directly weakens any later mediation or civil claim. The Regulation's leverage comes from the record: a platform that failed to provide an adequate statement of reasons, or that rejected a properly filed complaint without substantive engagement, has a more difficult position in mediation or before a court than one that was never formally put on notice. Sellers who handle these submissions without legal input often produce records that do not capture these gaps.

Do I need a lawyer for P2B dispute resolution for sellers?

Not every P2B dispute requires legal representation, but the cases where legal input adds most value are those where the restriction has a significant commercial impact, where the platform's stated reason does not match the account facts, or where the matter may need to proceed past the internal complaint stage. The P2B Regulation is a specialist area: it interacts with the DSA, the DMA, national enforcement law, and the contractual terms of the platform in ways that are not intuitive. The difference between a complaint that creates useful procedural leverage and one that is routed around the required mechanism often comes down to framing and sequencing. We offer a fixed scoping engagement to review the restriction notice, the account history, and the applicable grounds – so sellers can make an informed decision about whether and how to proceed before committing to a longer engagement.

About Tutamen

Tutamen is an independent law firm for online marketplace sellers. We represent Amazon, Walmart, Etsy and eBay sellers in account deactivations, frozen-funds recovery, intellectual-property disputes, arbitration and Notices of Dispute, and US federal Schedule A defense, plus EU marketplace regulation. Our work is attorney-led and confidential, with fees quoted up front. We act for founders, brand owners and in-house teams who need a specialist for a marketplace dispute. Our EU marketplace regulation practice is attorney-led from initial review through to mediation or court proceedings, with a fixed scoping fee to start. All matters are handled in strict confidence. To discuss your situation, email info@tutamenlaw.com.

By Claire Donnelly – arbitration & disputes analyst, Tutamen.

Page authored by Claire Donnelly, Arbitration & Disputes Analyst, Tutamen.

Disclaimer: This article is general information, not legal advice, and does not create an attorney-client relationship. Marketplace policies and the law change, and every account and case is different. For advice on your situation, contact Tutamen at info@tutamenlaw.com.