In a case where an item's box is known, it should be put as the front art. The only way it wouldn't was if the outer box is generic (say this guy sells many things and uses this one box size for multiple things) and the thing inside the box has some other packaging (such as a plastic bag) then the plastic bag is considered the container. Then an image of the item in its original bag can be the front art.
It is rare for this situation to occur. It is usually third-party or bootleg items, notably those generic controllers you can find on Ebay or Alibaba or wherever.