With dropshipping, it is not you but your supplier who sends the package directly to the customer. In itself, this does not change the question of whether the PPWR applies to you: the regulation looks at who first makes the product with its packaging available on the EU market, not at who actually fills, seals or ships the box. If you sell to a customer in the EU and the order, payment and customer relationship run through your webshop, you can still be the party responsible for registration under packaging legislation — even if you have never handled the packaging yourself.
Whether that actually applies in your case depends on a few concrete factors: where your supplier is established, under which brand the product is sold, and whether that supplier is already registered somewhere in the EU. These are precisely the questions that determine what role you get; you can see in a few questions whether you are classified as a manufacturer before you read further.
Who is considered a manufacturer in dropshipping
The regulation works with a filler-is-manufacturer principle: the party that brings the product to market under its name or brand typically bears the obligations around packaging, not just the party that physically fills the box. With dropshipping, the webshop is often the only party that the European consumer actually sees — the supplier remains in the background. This makes it plausible that supervisors in such a setup will look to the webshop as the first point of contact, especially when the customer has nowhere else to turn with questions about the product.
If your supplier is outside the EU
A large part of dropshipping runs through suppliers outside the EU, for example in Asia. If that supplier ships directly to a consumer in an EU member state, a situation arises that is comparable to what has long applied to other producer responsibility, such as electronics and batteries: someone within the EU must be accountable for the obligations, and that is usually the person driving the sale. This distinction between a supplier inside and outside the EU is also relevant to the so-called micro-exemption, where the country of establishment of your supplier counts. In the knowledge base this is further explained per situation; the knowledge base with explanations per packaging situation is a logical next step if your supplier is outside the EU.
Own brand makes a difference
If you sell the product under your own brand, the likelihood that you will be seen as a manufacturer is higher: in that case you also determine to some extent how the product and packaging appear to the outside world, even if a third party handles the physical dispatch. If you instead resell an existing brand of a third party without making any changes to it yourself, the responsibility may lie elsewhere in the chain. This distinction is precisely why the role finder can give a different outcome per packaging type and per country — dropshipping of the same product can yield a different role for brand A than for brand B.
What this means for registration per country
If you are identified as the responsible party, in practice the same applies as for a regular webshop that ships itself: registration in each EU country where your end customers are located, with the associated registers, costs and deadlines. The fact that you never packed the box yourself is not the deciding point for that registration obligation. How that guided registration looks per country, including the steps involved, is described on the page about how guided registration per country works.
When dropshipping does not fall under this obligation
There are also situations in which dropshipping does not automatically trigger a registration obligation for you. If your supplier is already registered in the country in question and contractually bears responsibility for the packaging, the obligation may lie elsewhere in the chain. Similarly, a purely affiliate model, in which you only refer to another's webshop without handling the sale yourself, is a different situation from classic dropshipping. Edge cases like these are precisely where the guidelines introduce nuance; for comparable borderline cases, the answers to comparable edge cases are a good starting point, and for a ruling on your specific situation, a lawyer or the competent supervisory authority remains the appropriate contact.
If you recognise your situation in this section, it is worth doing the free quick-scan or carefully reading the relevant topics — in half an hour you will know whether dropshipping in your case triggers a registration obligation, and in which country that applies.