Milyen kötelezettségei vannak egy teljesítési partnernek a PPWR szerint?

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

A fulfillment service provider that merely stores, packages and ships on behalf of a brand owner will in most cases not fall within the definition of manufacturer under 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 fulfillment service provider merely executes that decision. In that relationship, the core obligations of the PPWR — the EU Declaration of Conformity under Annex VIII, the name and postal address on the packaging, the limits 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 fulfillment 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 in a Member State without another responsible party present, or when it has the packaging made under its own name. The guidelines cite for those situations the conditions under which the role shifts; in case of doubt about a specific supply chain, they refer to the competent authority. Whoever supplies end users through remote selling in a Member State where the responsible party is not established must also appoint an authorised representative under 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's guidelines (C/2026/3084) on the concept of manufacturer, which specifically address supply chains with intermediaries such as fulfillment service providers. The registration obligation itself follows from Article 44: whoever places packaging on the market of a Member State for the first time 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: whoever places even one package on the market there via a fulfillment centre registers there from that moment on.