We store and ship for others and may be responsible

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).^[2][1]