The assumption that often turns out to be wrong
A webshop outsources storage, packing and shipping to a fulfillment partner and then assumes that the partner also takes on the packaging obligations. The reasoning sounds logical: the fulfillment partner buys the boxes, packs the products and puts the label on them. Who else would be responsible for registration and reporting, if not the one who physically handles the packaging?
This assumption is one of the most common misunderstandings about the European packaging regulation. In most cases, engaging a fulfillment partner does not change who is responsible for registration: it typically remains the company that places the products on the market under its own name or brand, even if someone else handles the logistics.
What fulfillment does and does not change
A fulfillment partner is essentially a logistics service provider. They receive inventory, store it, pack orders and ship them on behalf of the client. That role touches on the packaging regulation, but does not automatically make the fulfillment partner the party responsible for the packaging under the rules. What matters is who places the products on the market and under what name, not who seals the box.
This distinction resembles the question of who counts as a manufacturer when a party has its packaging filled by a third party. Fulfillment is a specific case of that: the fulfillment partner fills and ships, but acts on behalf of and under the name of the client. As a result, responsibility in practice rarely shifts to the logistics partner.
Who then remains responsible?
The company that sells the products under its own brand or name typically remains the one that must register and report, even when it does not touch a box itself. That applies to its own webshop, but equally to brands and importers that sell via a marketplace and have fulfillment handled by an external party or by the platform itself.
The confusion usually arises because contracts with fulfillment partners do include agreements on packaging material costs, but say nothing about who bears the legal obligations. Both parties then tacitly assume the other will handle it. The result is that nobody registers at all, until a register or supervisory authority asks about it.
Cross-border fulfillment makes it more complex
Many growing webshops choose a fulfillment center in another EU country, for example to deliver faster to customers in that country. This has consequences separate from the question of who is responsible for the packaging: it can also mean that separate registration is required in that country, with its own register, its own deadlines and sometimes a mandatory local representative. This is a separate consideration alongside the question of who within your own supply chain is responsible for the packaging file.
Entrepreneurs who expand their fulfillment structure across multiple countries often underestimate how many registers are added. It is therefore useful to review separately for each country where inventory is held or from which shipments are made what applies. see in a few questions which registration suits your situation provides an initial direction there, per packaging type and per country.
How you prevent this
The core of this error does not lie in the law itself, but in the agreements between the client and the fulfilment partner. Document who maintains the packaging file, who submits the annual report and who handles registration in each relevant country. Do not assume this will automatically be included in the logistics agreement, as fulfilment contracts are typically written from the perspective of storage and shipment, not packaging legislation.
It is also wise to review these agreements periodically, especially when the number of countries in which you use fulfilment grows or when you switch fulfilment partners. In the knowledge base with explanations per situation you will find more about how responsibility and registration relate to each other, and the frequently asked questions about registration and roles addresses similar borderline cases.
If you are unsure whether your own fulfilment setup falls under this rule, that is precisely what the free role finder is for: not a legal judgment, but a concrete indication based on your situation. If you then also want to see how the file, the registration and the annual report work around it, you can read that at the page that explains where the information comes from.