Direct comparison
Dropship vs Wholesale: Medical and Lab Supplies
Dropship vs wholesale for medical and lab supplies: who is the seller under the FTC rule and how 21 CFR 807 treats the supplier. Sourced 2026-11-01.
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How do Dropship, Wholesale (buy and hold stock) compare side by side?
The table below compares Dropship, Wholesale (buy and hold stock) across 13 procurement-relevant dimensions, from what the model means (as used on this page) through source.
Side-by-side comparison
| Dimension | Dropship | Wholesale (buy and hold stock) |
|---|---|---|
| What the model means (as used on this page) | The seller takes the order and a supplier ships the product to the customer, so the seller does not hold the stock. | The seller buys stock from a supplier, holds it and ships it to the customer. |
| Who is the seller under the FTC Mail, Internet or Telephone Order Merchandise Rule | The person soliciting the order, not the agent fulfilling it, is the seller under the Rule. | The person soliciting the order is the seller; it is also the party shipping. |
| Shipping-time duty | Must have a reasonable basis for any stated or implied shipping time. With no stated time, the FTC guide says to have a reasonable basis to ship within 30 days of a properly completed order (50 days if the order involves a credit application). The seller still owns this duty even though the supplier ships. | The same duty applies, and the seller controls its own stock and shipment. |
| If shipment will be late | Seek the customer's consent to the delayed shipment. The notice gives a revised date and a free way to cancel. | Same duty. |
| Refund for unshipped goods | Must promptly refund, without being asked, all money paid for merchandise that has not shipped. | Same duty. |
| Responsibility for the fulfilling party | The merchant remains responsible for a drop-shipper's violations. The FTC guide says it considers contracts requiring compliance, testing of fulfillment times and monitoring of complaints. | No separate fulfilling party for shipments the seller makes itself. |
| FDA role of the supplier (devices) | Depends on what the supplier does, not on the sales model. A wholesale distributor is any person other than the manufacturer or initial importer who moves a device from the first production point to the final seller or user (21 CFR 807.3(t)). One that does not manufacture, repackage, process or relabel a device is not subject to registration and listing (21 CFR 807.20(c)). | Same test applies to the wholesale supplier. |
| Repackaging or relabeling | Repackaging, or changing the container, wrapper or labeling, is a covered activity under the definitions in 21 CFR 807.3(d)(1). In this model the product ships from the supplier, so whether any of these steps occurs sits with the supplier. | If the seller itself repackages or changes the container or labeling of a device it holds, those definitions are the ones to check. |
| Selling to the end user | 21 CFR 807.65(e) exempts from registration pharmacies, surgical supply outlets and similar retail establishments making final delivery or sale to the ultimate user. | Same exemption text applies to the seller in either model. |
| Laboratory items | 21 CFR 807.65(c) exempts general-purpose articles such as chemical reagents or laboratory equipment not labeled or promoted for medical uses. | Same carve-out text. |
| Questions to put to each supplier | What lead time can be supported and how will delays be notified (the shipping and consent duties stay with the seller); will the contract require compliance and allow fulfilment-time tests and complaint monitoring; does the supplier relabel or repackage any device. | Does the supplier relabel or repackage any device; does the seller's own handling (repackaging, container or label changes) fall under the 21 CFR 807.3 definitions. |
| When to pick each (editorial reading of the rules above) | Fits a seller that accepts that shipping-time, delay-notice and refund duties stay with it while a supplier performs the shipment, and can contract for and monitor that performance. | Fits a seller that wants to control shipment timing and any handling of the product itself, and will check the 807.3 handling definitions for whatever it does. |
| Source | FTC Business Guide to the Mail, Internet or Telephone Order Merchandise Rule (ftc.gov, read 2026-11-01); 21 CFR 807.3, 807.20 and 807.65 (law.cornell.edu, read 2026-11-01). | Same sources. |
Common questions
Common questions about Dropship vs Wholesale (buy and hold stock)
If a supplier ships the order, who is the seller under the FTC rule?
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The FTC business guide says the person soliciting the order, not the agent fulfilling it, is the seller under the Rule. The merchant remains responsible for a drop-shipper's violations (FTC guide, read 2026-11-01).
Does a dropship supplier have to be registered with FDA?
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It depends on what the supplier does. 21 CFR 807.20(c) says registration and listing requirements do not pertain to a wholesale distributor (as defined in 807.3(t)) that does not manufacture, repackage, process or relabel a device (law.cornell.edu, read 2026-11-01).
What must a seller do if a dropshipped order will ship late?
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The FTC guide says to seek the customer's consent to the delayed shipment, giving a revised date and a free way to cancel, and to refund promptly and without being asked if the merchandise does not ship (read 2026-11-01).
Are laboratory supplies covered by the device registration rules?
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21 CFR 807.65(c) exempts general-purpose articles such as chemical reagents or laboratory equipment that are not labeled or promoted for medical uses (read 2026-11-01).
