I am a fulfilment service provider in the EU – what do I do? (example)

A practical checklist would include the following: — make existing and potential clients aware that, if any products covered by Article 4 they are selling must be linked to an economic operator referred to in Article 4. Point them to Article 4 and these guidelines, — indicate to clients that you will be the economic operator referred to in Article 4 if there is no manufacturer, importer or authorised representative established in the EU (or, if you do not want to, make this clear and indicate that they cannot use your fulfilment services for those products unless there is a manufacturer, importer or authorised representative in the EU), — if clients want you to act as the economic operator referred to in Article 4, check whether you are already performing this role for the same type of product for another client – if so, you already have everything you need; if not, decide the extent to which you will arrange what you need and the extent to which you want the client to do this for you, — tell clients who want you to act as the economic operator referred to in Article 4 what they have to do before they can start using your fulfilment services, e.g. provide the manufacturer’s contact details, declarations of conformity/performance, etc., — inform the clients once all arrangements have been made for you to act as the economic operator referred to in Article 4, so that they can start offering the products for sale.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07