Outsourcing storage and shipping to a fulfilment partner does not in itself change who is responsible for the packaging. The regulation looks at who places the product on the market under their own name, not at who actually fills the box or hands the parcel to the carrier. If your brand name appears on the product, the invoice or the shipment, that role usually remains with you, even if an external company does the physical packing work.
There are situations where this is different. If the fulfilment partner sells under their own name to the consumer, for example in certain marketplace constructions where the platform acts as the seller, responsibility may shift. Also, when you supply exclusively to another company that then serves the end customer itself, the situation changes. Which role exactly applies to you depends on the specific agreements and the packaging layer in question; you can find that out in a few questions.
What a fulfilment company does and does not handle
A fulfilment partner typically handles storage, order picking, packing and handing over to the carrier. That is operational service provision. The obligations that follow from the packaging regulation, such as registration in a national register, maintaining a packaging file or drawing up a declaration of conformity, usually do not automatically form part of this. Contracts with fulfilment partners generally cover delivery times, storage costs and return processes, not who has which role under the packaging regulation. It is therefore important not to assume that as a matter of course, even when the fulfilment partner themselves procures or designs the packaging.
Where it does make a difference: the country where storage takes place
A point that is often overlooked is that using a fulfilment centre in another country can have consequences for registration obligations in that country, even if you yourself never set foot there. As soon as products are delivered to consumers from a warehouse in another EU country, in practice you are placing packaging on the market there. National registers and obligations differ by country, and it is therefore possible that a fulfilment choice in, for example, Germany or France brings a registration obligation there with it, separate from your registration in the Netherlands. An overview of what applies per packaging type and country can be found in the knowledge base by topic.
What you can practically check
To determine whether fulfilment changes your situation, it is useful to check three things: whose name appears on the shipping label and invoice, in which country the fulfilment partner actually stores the inventory, and whether the contract says anything about packaging obligations. Often the latter is not mentioned anywhere, which does not mean the obligation is not there, but it does mean that responsibility usually remains with the brand owner. In case of doubt about the precise role in a borderline case, guidelines and supervisors refer to the text of the regulation itself; there is not always a clear answer for every situation.
The background to how this assessment is built up is explained in the page on our working method. If you are unsure whether your fulfilment arrangement has consequences for a specific country, it is advisable to look at each country separately rather than assume that one registration is sufficient everywhere.
In short
Fulfilment is a logistics choice, not a legal one. The role you have under the packaging regulation follows from who puts the product on the market and in which country that happens, not from who seals the box. For most webshops selling under their own name, a fulfilment partner therefore changes little about your own obligations, but the country where that partner holds inventory can mean an additional registration.
Do you want to quickly see whether your situation, including any fulfilment partner abroad, has consequences? Take the free quick-scan or browse through the topics in the frequently asked questions to see which situation comes closest to yours.