EU product law recognises a role that logistics people rarely think of as regulatory: the fulfilment service provider. Warehouse, package, address and dispatch goods you do not own, and you are an economic operator — with duties narrower than a manufacturer or importer, but real. Meanwhile the online sellers using those services often assume the opposite of the truth: that outsourcing storage and shipping also outsources compliance. Both sides of that contract need to be clear about where the Digital Product Passport duty actually sits.
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The fulfilment service provider entered EU product law as a response to e-commerce: goods arriving from outside the Union, stored in an EU warehouse and shipped to consumers, with no obvious EU-based party answerable for them. The market-surveillance framework closed that gap by treating an operator that warehouses, packages, addresses and dispatches goods it does not own as an economic operator in its own right.
The duties attached to that role are deliberately narrower than a manufacturer's. Broadly they run to cooperating with market-surveillance authorities, providing information about the goods and the parties behind them, and not continuing to handle goods once there is reason to believe they are non-compliant. How the DPP specifically maps onto fulfilment providers is still being worked out — the ESPR phases in per product group through delegated acts, and the detail of who must check what will firm up as those acts land. Treat what follows as the direction of travel, not as an article-level obligation list.
None of this asks a 3PL to author passports. It asks the 3PL to notice when something is missing and to know who to point authorities at.
Whatever the delegated acts eventually say, fulfilment operators are already being asked to evidence compliance — by clients running supplier due diligence, by marketplaces tightening listing requirements, and by authorities that find the warehouse easier to visit than a seller in another jurisdiction. Warehouses are where goods physically are, and that makes them a natural inspection point.
For a 3PL this cuts both ways. It is a cost — intake checks, staff training, carrier-preservation rules — and a differentiator. Providers that can answer "show me your DPP handling process" in a tender will win regulated categories from providers that cannot. The operators taking this seriously early are treating passport checks as an extension of goods-in QC rather than as a new department.
The assumption to kill first: using an FBA-style service or a 3PL does not move the passport duty. If you buy from a non-EU factory and have it shipped into an EU fulfilment centre, you are the importer placing those goods on the EU market — the passport must exist, be accurate, be reachable through the carrier and stay current, and that is yours. Your fulfilment provider stores boxes; it does not hold your bill of materials and it has not agreed to answer for your data.
Read your fulfilment contract on this point specifically: most disclaim product-compliance responsibility outright and put the indemnity on you. The practical fix is to arrive at the warehouse compliant. A free readiness check will tell you which of your lines are heading into scope and what data you are missing before a consignment is sitting in someone else's racking.
Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.