The fulfilment service provider role in EU product compliance
A fulfilment service provider stores, packs, addresses or dispatches products it does not own, and EU product law counts it among the economic operators. Where no manufacturer, importer or authorised representative is established in the EU, a fulfilment service provider established there is the responsible person for the products it handles, under the GPSR and the CE acts named in Regulation (EU) 2019/1020: it keeps the documentation available, answers the authorities and cooperates on corrective action. The way to avoid surprises is to know, per client, who fills that role.
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Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice
Am I the fulfilment service provider?
- Yes
A warehouse that stores, packs and dispatches orders for web shops
You offer at least two of warehousing, packaging, addressing and dispatching on a commercial basis and do not own the goods. That is the definition (GPSR Article 3(12)).
- Yes
A client outside the EU with no importer and no authorised representative
For that client's products you are more than a warehouse: a fulfilment service provider established in the Union is the responsible economic operator for the products it handles where no manufacturer, importer or authorised representative is established in the Union (Regulation (EU) 2019/1020, Article 4(2)(d)).
- No
A carrier that only delivers parcels
Postal, parcel delivery and freight transport services are excluded from the definition.
- No, you are the importer
Goods you buy from a supplier outside the EU and resell from your own warehouse
A fulfilment service provider does not own the products it handles. When you are established in the EU, buy the goods and are the first to make them available in the EU, you place them on the market, which makes you the importer of those goods.
See the importer → - You are also the online marketplace
A marketplace that also stores and ships its traders' goods
A provider of an online marketplace that offers fulfilment services can be a fulfilment service provider for those products. The GPSR says this is assessed case by case (recital 46).
See the online marketplace →
What the law asks of you
The references name the General Product Safety Regulation (GPSR) and, as the example of a CE act, the Low Voltage Directive (LVD). For products under a product-specific harmonisation act, such as the Low Voltage or Toy Safety Directive, the GPSR's Chapter III, Section 1 (Articles 9 to 18) does not apply, and the act's own duties take its place (Article 2(1), third subparagraph, point (b)). The GPSR's safety requirement still covers risks the act does not (point (a)), and Articles 19 to 22, on online offers, accidents and online marketplaces, apply to all products, as do the recall rules in Articles 35 to 37. REACH restrictions and labelling rules do not take a product out of Articles 9 to 18. Whoever places on the EU market a product not designed for it, or a used product from outside the EU, takes on the manufacturer's role (Blue Guide, section 3.1); a used CE product resold inside the EU falls under the GPSR in full. The regulation guides list the article for each act.
Before the product is placed or sold
- Know, for every client, who the economic operator responsible for the product in the Union is. Where no manufacturer, importer or authorised representative is established in the Union, you are the responsible operator for the products you handle. Regulation (EU) 2019/1020 Art. 4(2)(d); GPSR Art. 16(1)
- As the responsible operator, verify that the technical documentation and, where one is required, the EU declaration of conformity have been drawn up. Regulation (EU) 2019/1020 Art. 4(3)(a)
On the product and in the offer
- As the responsible operator, make sure your name, registered trade name or registered trade mark and your contact details are on the product, its packaging, the parcel or an accompanying document: the postal address under Regulation (EU) 2019/1020, the postal and electronic address under the GPSR. Regulation (EU) 2019/1020 Art. 4(4); GPSR Art. 16(3)
Records to keep
- As the responsible operator, keep the declaration of conformity at the disposal of the market surveillance authorities and make sure the technical documentation can be made available to them on request. Regulation (EU) 2019/1020 Art. 4(3)(a)
- Be able to say who supplied the products and whom you supplied, on an authority's request. GPSR Art. 15(3) and 15(5)
While it is on the market
- As an economic operator under the GPSR, have internal processes for product safety in place. GPSR Art. 3(13) and 14
- As the responsible operator for a product under the GPSR, check regularly that the product matches its technical documentation and carries the required identification, contact details and instructions, and keep evidence of the checks. GPSR Art. 16(2)
When something is wrong
- As the responsible operator, give the authority the information and documentation that show the product's conformity on a reasoned request, inform the authorities when you have reason to believe that a product presents a risk, and cooperate on corrective action. Regulation (EU) 2019/1020 Art. 4(3)(b), (c) and (d)
- As the responsible person for a product whose manufacturer is outside the EU, make sure that an accident you know of is notified through the Safety Business Gateway. This applies to CE products too. GPSR Art. 20(4)
EU product law counts the fulfilment service provider among the economic operators. The General Product Safety Regulation (EU) 2023/988 defines it as any person offering, in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing and dispatching, without having ownership of the products involved, excluding postal, parcel delivery and freight transport services (Article 3(12)).[1]
The consequence sits in Regulation (EU) 2019/1020, for products under the harmonisation acts listed in its Article 4(5). The economic operator responsible for a product is the manufacturer established in the Union, the importer, or an authorised representative with a written mandate. Where none of these is established in the Union, it is the fulfilment service provider established in the Union, with respect to the products it handles (Article 4(2)(d)).[2]
That operator verifies that the documentation has been drawn up and keeps it available, provides information to authorities on a reasoned request, informs them when it has reason to believe a product presents a risk, and cooperates on corrective action (Article 4(3)). Under Article 16(1) of the GPSR the same applies to the products it covers, and Article 16(2) adds regular checks that the product matches its technical documentation and carries the identification, contact details and instructions required by Article 9(5), (6) and (7).[1][2]
The role does not turn the warehouse into the manufacturer. Design, the risk analysis or conformity assessment and the technical documentation stay with the manufacturer; the fulfilment service provider answers for the tasks of the responsible operator, and only for the products it handles.[2]
What Conphora does for the fulfilment service provider
What the platform does today for a company in this role.
A supplier request to the seller
One link asks the client or the manufacturer outside the EU for the declaration and the technical documentation. What comes back is filed on the product with the sender's name.
The steps for the role you hold, product by product
The product workspace sets the role for each product and lists the steps that role carries under the regulations that apply to it.
One document when an authority asks
The documents filed on a product are assembled into one technical file, ready to send on a reasoned request.
Radar
Compliance Radar reports Safety Gate alerts for the product types that pass through your warehouse.
Who you share with
-
Seller outside the EU
- You give
- Requests from authorities, and word when you have reason to believe a product presents a risk.
- You receive
- The name and address of the responsible operator in the EU or, where there is none, the declaration of conformity and access to the technical documentation for an authority's request.
-
Shop or consumer
- You give
- The parcel, with the responsible operator's name and contact details on the product, its packaging, the parcel or an accompanying document.
- You receive
- Returns and complaints, which go on to the seller.
-
Market surveillance authorities
- You give
- The declaration and the technical documentation on request, information on risks, and cooperation on corrective action.
- You receive
- Reasoned requests and orders for corrective action.
Regulations that bind the fulfilment service provider
Taken from the regulation guides: 5 acts name this role. The article numbers are those of the role's duties in each act.
Problems people in this role ask about
Problem pages written for this role: 2 in all.
Questions about the role
We only ship parcels. Are we a fulfilment service provider?
Postal, parcel delivery and freight transport services are excluded from the definition. Offering at least two of warehousing, packaging, addressing and dispatching brings you within it.
Does the role make us the manufacturer?
No. The responsible person performs the tasks in Article 4(3) of Regulation (EU) 2019/1020 and, for products under the GPSR, the checks in its Article 16(2). The manufacturer's obligations stay with the manufacturer.
Can the contract with the client move the responsibility back?
A contract can oblige the client to appoint a representative and to indemnify you. It does not change who the authorities turn to while nobody else is established in the Union.
Does the rule cover CE-marked products too?
Yes. Regulation (EU) 2019/1020 created the responsible economic operator for products under the harmonisation acts listed in its Article 4(5), and the GPSR applies the same article to the products it covers (Article 16(1)).
Are we liable for damage a client's product causes?
For products placed on the market or put into service from 9 December 2026 whose manufacturer is outside the Union, the fulfilment service provider is liable for damage caused by a defective product where no importer or authorised representative is established in the Union, as national law transposing the directive provides (Directive (EU) 2024/2853, Articles 2(1) and 8(1)(c)(iii)).
Sources
- Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 5 October 2026
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 5 October 2026
- Directive (EU) 2024/2853 on liability for defective products EUR-Lex · accessed 5 October 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 5 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). The fulfilment service provider role in EU product compliance. Retrieved 13 October 2026 from https://www.conphora.com/roles/fulfilment-service-provider/
Conphora (2026) The fulfilment service provider role in EU product compliance. Available at: https://www.conphora.com/roles/fulfilment-service-provider/ (Accessed 13 October 2026).
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author = {Conphora},
title = {The fulfilment service provider role in EU product compliance},
year = {2026},
url = {https://www.conphora.com/roles/fulfilment-service-provider/},
note = {Retrieved 13 October 2026}
} The other roles
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