Are you importing a product from outside the European Union and selling it to consumers in Poland or another EU country? In that case, you are not just a recipient of goods. The GPSR assigns importers their own obligations relating to product safety, identification, documentation and responding to problems.
First, establish whether you are actually an importer
Under the GPSR, an importer is an entity established in the European Union that places a product originating from a third country on the EU market. The job title or the wording used on the invoice does not decide this. What matters is the company's actual role in the supply chain.
If you place a product on the market under your own name or trade mark, or make a substantial modification affecting safety, you may be regarded as the manufacturer. In that case, the scope of responsibility will be broader than the standard obligations of an importer.
Before you start work, record the following for the product in question:
- the country of origin and the entity from which the product was purchased,
- the manufacturer and its postal and electronic address,
- the entity established in the EU responsible for the product,
- your role in the supply chain,
- the markets in which the product is to be offered,
- the sector-specific rules applicable to that type of product.
The GPSR acts as a general safety net. If a specific risk is already regulated by particular EU rules, those rules must be taken into account, and the GPSR applied to the appropriate extent. A single universal checklist therefore does not replace the legal classification of the product.
1. Identify the product unambiguously
The documentation cannot concern only a general commercial name such as "bottle", "lamp" or "toy". It must be linked to the actual product variant.
Prepare at least:
- the product name and its intended purpose,
- the model, type, batch or serial number,
- the internal SKU number,
- photographs of the product, label and packaging,
- a description of the materials, components and relevant parameters,
- a list of variants that differ in a safety-related characteristic,
- the date or range of deliveries to which the collected evidence relates.
This is also important operationally. If a test report concerns model A, it should not automatically confirm model B merely because the two products look similar. In the documentation, you must be able to show why a given piece of evidence was assigned to a specific SKU or to an entire product family.
2. Check the manufacturer's and EU responsible person's details
The product should bear details identifying the manufacturer, including a postal and electronic address enabling contact. Where the manufacturer is established outside the EU, the product must be linked to a responsible person established in the Union.
As the importer, you also provide your own details. The information should be placed on the product, its packaging or in a document accompanying the product, in accordance with the conditions laid down in the rules. An additional importer label should not obscure or alter the manufacturer's information.
Do not limit the check to the presence of any website address. UOKiK explains that the electronic address should give the consumer a real possibility of contact, for example by e-mail or an appropriate form.
3. Obtain the technical documentation and risk analysis
Before placing a product on the market, the manufacturer should carry out an internal risk analysis and draw up technical documentation. The importer should verify whether the manufacturer has performed those obligations, keep a copy of the technical documentation for 10 years from the placing of the product on the market and ensure that the required documents can be made available to the supervisory authority.
In practice, it is worth collecting:
- a general description of the product and the characteristics relevant to safety,
- an analysis of possible hazards and foreseeable ways of using the product,
- the solutions adopted to eliminate or reduce risk,
- test reports, if any were carried out,
- a list of the standards applied or other assessment criteria,
- instructions, warnings and safety information,
- identification of the author, the date of drawing up and the version number of the document.
A file named "certificate" is not automatically sufficient evidence. Check the issuer, scope, product model, date, method used and any exclusions. A document concerning a different variant or an outdated design may not correspond to the product you are actually importing.
4. Verify the marking, instructions and warnings
Before making the product available, check not only the documents in the folder but also the product itself, the packaging and the materials included in the shipment.
The check should cover:
- the product identifier,
- the manufacturer's details,
- the importer's and responsible person's details, where required,
- the instructions for use,
- safety information and warnings,
- the language appropriate to the market on which the product is offered,
- the legibility and durability of the information.
In Poland, instructions and safety information should be understandable to the consumer and provided in Polish where they are needed for safe use. A QR code may supplement the information, but according to UOKiK's explanations it should not replace the basic information required on the product, packaging or accompanying document.
5. Prepare a complete set of information for the online offer
The requirements do not end with the physical marking of the product. A distance selling offer should enable the consumer to familiarise themselves with the required information before purchase.
UOKiK points, among other things, to:
- the manufacturer's name and contact details,
- the details of the EU responsible person where the manufacturer is not established in the Union,
- an image of the product and information enabling it to be identified,
- the required warnings and safety information in the appropriate language.
It is safest to prepare one approved set of data for the SKU and then control its use in the shop, marketplace and sales materials. Manually copying content from several spreadsheets quickly leads to discrepancies between channels.
6. Control transport and storage
The importer should ensure that storage and transport conditions do not endanger the safety of the product or its compliance with the requirements. This point is often overlooked, although the manufacturer's documentation may assume a specific temperature, humidity, stacking method or protection against damage.
Record the required conditions, pass them to the logistics operator and keep evidence that they were implemented. If the product was damaged in transport or was stored contrary to the assumptions, the correct original documentation alone does not solve the problem.
7. Establish a procedure in case of a problem
If the importer has reason to suspect that a product is dangerous or does not meet the requirements, it should not place it on the market. Depending on the situation, it may be necessary to inform the manufacturer, take corrective measures, warn consumers and provide information to the competent authorities through the Safety Business Gateway.
Therefore, before selling, it is worth establishing:
- who receives safety reports,
- how batches and recipients are identified,
- who decides to block sales,
- where corrective actions are recorded,
- how the company will prepare communication and notification to the authority,
- how the history of decisions and document versions will be preserved.
A practical importer workflow
Instead of collecting files only before an inspection, you can guide the product through a continuous process:
- Qualification - establish the product, the company's role, the market and the sector-specific rules.
- Identification - link the SKU, model, batch, manufacturer and responsible person.
- Evidence gathering - ask the supplier for documentation, risk analysis, tests and safety content.
- Completeness assessment - check the scope, currency and consistency of the documents with the actual product.
- Completion of sales channels - prepare approved data for the shop and marketplace.
- Approval - assign the person responsible for the decision and record its basis.
- Maintenance - respond to changes in the product, supplier, instructions, market or new risk information.
A GPSR / PPWR system can help link the product, supplier, documents, gaps and subsequent revisions in one place. However, it does not take over the importer's responsibility, does not carry out product testing and does not issue a certificate of conformity.
Most common mistakes
- treating an invoice or supplier declaration as complete documentation,
- failing to link a report to a specific product model and version,
- using one set of instructions for variants with different hazards,
- omitting the details of the EU responsible person,
- lacking a Polish version of the required safety information,
- having different data on the product, in the shop and on the marketplace,
- failing to control changes after the product is first placed on the market,
- treating a completed checklist as automatic confirmation of compliance.
What to do now
Choose one actual SKU and go through the entire list from product identification to the procedure for responding to a problem. Assign each value to a source, mark gaps and record the person who approved the result. Only such a pilot shows whether the process can be safely replicated for the entire catalogue.