Status of “fulfilment centres” with regard to the economic operators under the New Legislative Framework

Published: 1 October 2015

Policies & Issues: Internal Market - Compliance, Standards & Enforcement

The deployment of e-commerce has contributed to generalising the possibility for both consumers and professionals to directly import products from a vendor established outside of the EU without the intervention of an importer.

In such cases, products are often supplied by the vendor to the end users with the support of a third party carrier that provides so-called ‘fulfilment’ services. ‘Fulfilment’ refers to the process initiated in a company when an order for the shipment of a product is received. This may include warehousing, finding the item ordered, packaging it, and shipping it to the correct address.

While the use of fulfilment centres is not new, Orgalime understands that it may appear challenging for market surveillance authorities faced with the development of cross-EU border e-commerce.  However, we consider that instruments currently exist to stop rogue trading practices without imposing obligations on fulfilment centres which would be inappropriate with regard to their role in the supply chain of products. 

We call on the European Commission and member states to clarify in the revised version of the Blue Guide 2014 the status of fulfilment centres with regard to the existing legal framework.

Authors

Portalier
Philippe Portalier
Director - Better Regulation, Compliance and Standards

Related Position Papers

Orgalim Key Recommendations on the Single Market [30 May 2024]

Internal Market: Orgalim response to the European Commission Call for Evidence for an evaluation of Regulation 1025/2012 [28 September 2023]

Internal Market: Join Statement on the Right to Know [11 September 2023]

Internal Market: Enhancing EU manufacturing competitiveness with a future-proof approach to placing products on the Single Market [27 June 2023]

Internal Market: Orgalim Position on the Single Market Emergency Instrument (SMEI) proposal [20 March 2023]

Internal Market: Securing Europe’s industrial competitiveness – An agenda to recommit to the Single Market [15 February 2023]

Digital Transformation: Industry calls on EU legislators to respect principles of the New Legislative Framework in the AI Act [30 September 2022]

Internal Market: Criteria for common specifications [27 September 2022]

Internal Market: Joint industry statement – Feedback on the Standardisation Strategy [6 April 2022]