C_2021100EN.01000101-g-005-0005__para__5
Step 5: If there is no importer but a fulfilment service provider established in the EU is handling the product, the fulfilment service provider is the economic operator referred to in Article 4 (unless the manufacturer has appointed an authorised representative for the tasks under Article 4). Unlike importers and authorised representatives, fulfilment service providers do not automatically have a formal connection with the manufacturer enabling them to fulfil the tasks of the economic operator referred to in Article 4. Therefore, they will need to make arrangements with economic operators to whom they are providing fulfilment services (‘clients’) to ensure that they first receive from the client, or directly from the manufacturer, the means to fulfil their obligations as the economic operator referred to in Article 4 (see Section 4.4);
Source: EUR-Lex (Cellar) · retrieved 2026-09-25 · Text as adopted (Official Journal); later amendments are not incorporated in this text.