What is my role as a dropshipper under the GPSR?

With your own brand, the dropshipper is a manufacturer, not a distributor

What role a dropshipper holds depends on whose name the product is sold under — not on whether the inventory was ever physically held. If the online retailer sells the product under its own name or brand, the online retailer is considered a manufacturer under GPSR, even if the product never passes through its own warehouse and is shipped directly from the supplier to the consumer. This is the surprise many dropshippers encounter: they think they are merely intermediaries, but whoever carries the brand bears the obligations of a manufacturer — including the risk analysis and technical documentation.

If, on the other hand, the dropshipper sells the product under the original manufacturer's brand, the role becomes less clear-cut. If that manufacturer is located outside the EU and no importer or authorized representative has been appointed, the question arises who first places the product on the EU market — and that party could be, even without the dropshipper ever physically holding the product, the one arranging the order with the EU consumer. This is precisely the point where the regulation leaves room for interpretation: it describes roles based on what someone does, not on who manages the inventory. A pure distributor — who merely resells a product already placed on the market without adding its own brand or making changes — does not need to prepare a risk analysis or technical documentation; that obligation rests with the manufacturer or importer. Without an identifiable EU manufacturer, importer, or authorized representative, a product may not be offered at all, and particularly with dropshipping from a third country, that identifiable party is often absent.

Where that appears in the regulation: Articles 3 and 4

The definitions of manufacturer, importer, and distributor are set out in Article 3 of Regulation (EU) 2023/988; Article 4 governs distance sales and requires that when offering a product online, it must be clear who the manufacturer is and, where applicable, who the EU responsible party is. NVWA points out on its product safety page the connection between role and obligation, and notes that supervision takes place as soon as a product appears on the Dutch market — regardless of where it was shipped from.