What are the obligations of a fulfilment service provider under the PPWR?

A fulfilment service provider is usually not the manufacturer, but not always

A fulfilment service provider that only stores, packages and ships on behalf of a brand owner usually does not fall under the definition of manufacturer in Article 3 of Regulation (EU) 2025/40. The brand owner determines the design and composition of the packaging and places it on the market under its own name; the fulfilment service provider merely executes that decision. In this relationship, the core obligations of the PPWR — the EU declaration of conformity in accordance with Annex VIII, the name and postal address on the packaging, the limit values for heavy metals and the PFAS ban, and registration in the producer register — remain with the brand owner, not with the logistics service provider.

This picture changes as soon as the fulfilment service provider itself takes on the role that the guidelines link to the concept of manufacturer: for example, when it is the first to place goods from a seller outside the EU on the market of a Member State without another responsible party being present, or when it has the packaging made under its own name. The guidelines cite for these situations the conditions under which the role shifts; in case of doubt about a specific chain, they refer to the competent authority. Anyone who supplies to end users at a distance in a Member State where the responsible party is not established must also appoint an authorised representative on the basis of Article 45.

What this is based on: Article 3, Article 44 and the guidelines on manufacturer

The allocation of roles follows from the definitions in Article 3 of Regulation (EU) 2025/40 and from the Commission guidelines (C/2026/3084) on the concept of manufacturer, which specifically address chains with intermediaries such as fulfilment service providers. The registration obligation itself follows from Article 44: anyone who first places packaging on the market of a Member State registers there, and packaging from an unregistered producer may not be traded. For the Netherlands, Verpact applies a threshold of 50,000 kg per year, which is expected to be removed once the PPWR producer register becomes operational, at the earliest 12 August 2027. Germany has no threshold at LUCID: anyone who places even a single package on the market there via a fulfilment centre registers there from that moment on.