Who is liable for the goods, which numbers and charges apply at the border, what has to be on the label and in the listing, and how the same requirements look on Allegro, Amazon, Zalando and Kaufland. Every requirement comes with its source and the date we read it. Valid as of 29 October 2026.
Author: Borys Terlecki · Global Business Development, Marketing at Commercraft · updated: 7 November 2026
In short
A product made in China needs an economic operator established in the EU who is responsible for its compliance; for imports from China this is usually the importer [1][2].
Since 1 July 2026 consignments up to EUR 150 are no longer duty-free: until 1 July 2028 a duty of EUR 3 applies to each item in the consignment [8][9].
Import VAT is paid on top, and distance sales in consignments up to EUR 150 can use the IOSS special scheme [10][11].
For buyers in Poland, warnings and safety information must be in Polish [1][12], and packaged products need an entry in BDO, the Polish waste register, before sales start [14].
Allegro, Amazon, Zalando and Kaufland collect these details in dedicated fields of the listing or the seller profile [16][17][18][19].
Legal disclaimers
Legal position and rates as of 7 November 2026. This guide is information, not legal or tax advice; Commercraft is neither a law firm nor a tax adviser. Check the sources listed at the end or ask your adviser before you act.
Goods bought in China and sold to consumers in Poland fall under the same rules as goods made in the EU. One thing is different. The manufacturer sits outside the EU, so the manufacturer’s duties pass to whoever places the product on the EU market, usually the importer.
Below are five areas to close before the first listing goes live: liability for the product, customs duty and VAT, the label and the listing, packaging, and finally the requirements of the marketplaces themselves. Every requirement carries a source number, and the list of official texts with the date we read them is at the end of the page.
The General Product Safety Regulation (GPSR) has applied since 13 December 2024. Every product placed on the EU market must have an economic operator established in the Union who is responsible for its compliance. Without that operator there is no sale [1].
Who can take that role is set by the Market Surveillance Regulation. The list is closed:
For goods imported from China this is in practice the importer [2].
The responsible person regularly checks that the product matches its technical documentation and carries the required markings, and hands the evidence to market surveillance authorities on request. Its name, postal address and e-mail address go on the product, its packaging, the parcel or an accompanying document [1].
For products covered by CE marking rules (toys, electronics, radio equipment, machinery or personal protective equipment, among others) the same duty follows directly from the Market Surveillance Regulation. The list of acts it covers is in Art. 4(5) [2].
A business established in the EU that lodges customs declarations has to be registered with the customs authorities. In Poland you get the EORI number through PUESC, the electronic platform of the customs and tax administration [3][4].
The import customs debt arises when the customs declaration is accepted, and the debtor is the declarant. With indirect representation the person on whose behalf the declaration is made is a debtor too. In plain terms: if a customs agency acts in your name, the duty is still yours to pay [3].
The tariff code of the product decides the duty rate, quotas and any anti-dumping duties. You check it in the EU TARIC database, and the Commission’s Access2Markets portal walks an importer through the steps [5][6].
The duty exemption for consignments up to EUR 150 ended on 1 July 2026. Until then goods with an intrinsic value of up to EUR 150 per consignment entered duty-free [7]. Now a temporary duty of EUR 3 per item applies. An item means goods in the consignment that share the same tariff classification, description and, where applicable, origin; with today’s IT systems the duty is charged per line of the customs declaration [9]. It covers consignments up to EUR 150 in distance sales to consumers (B2C) and is set to run until 1 July 2028. IOSS changes nothing here [8][9].
Import VAT is due on every consignment. There is no threshold. For distance sales of imported goods in consignments up to EUR 150 (excise goods excluded) the VAT Directive provides the IOSS special scheme. VAT is then declared in one return. The import itself is exempt, provided customs received the IOSS number no later than in the import declaration [10]. In Poland the Ministry of Finance explains registration and returns under IOSS [11].
One distinction matters. IOSS covers sales shipped to the consumer straight from a warehouse outside the EU. If you bring a batch into a warehouse in Poland and sell from there, you settle import VAT at clearance under the general rules, and IOSS does not apply.
Example. An online shop selling accessories ships a parcel from a warehouse in China to a buyer in Poland. The parcel is worth EUR 120 and goes on a simplified H7 declaration, where goods are grouped by their six-digit HS code. It holds three different products, each with a different HS code: that makes three declaration lines, so the duty is 3 × EUR 3 = EUR 9 [9]. If the same parcel held three identical T-shirts with one code, it would be one line and the duty would be EUR 3 [9]. The difference is EUR 6 on a single parcel. Assumptions: the parcel value stays within EUR 150, import VAT and shipping are left out, and amounts are in euro because the regulation sets them in euro [8]. Our calculation.
Every online offer must show, clearly and visibly, at least four things:
Warnings and safety information must be in a language easily understood by consumers, as determined by the Member State where the product is made available [1]. In Poland the Polish Language Act settles this. In consumer transactions Polish is the language to use. The duty covers in particular product names, offers, warranty terms, warnings and consumer information, user manuals and information on product properties. Advertising too [12].
The conclusion is simple. A Chinese or English factory label is not enough. Before the sale the product gets a Polish label with the responsible person’s details, and the same details and warnings go into the listing. If a product is found unsafe, it appears in the EU Safety Gate system, which is worth watching for your own categories [13].
Whoever places packaged products on the Polish market, as well as electrical equipment, batteries or packaging as such, has to be entered in BDO, the Polish database on products, packaging and waste management. The application is filed before the activity starts [14].
Since 12 August 2026 the EU Packaging and Packaging Waste Regulation (PPWR) applies. A producer is a manufacturer, importer or distributor, regardless of the selling technique, distance contracts included. Producers bear extended producer responsibility for the packaging they make available for the first time in a Member State. Each Member State is to set up a national producer register within 18 months of the Commission’s first implementing act, and a producer registers in every Member State where it first makes packaging available [15].
For a seller shipping from Poland to other EU countries this means a separate packaging registration in every country of sale. Some marketplaces already ask for these numbers when you open an account, as the next section shows.
Allegro. Since 13 December 2024 every new listing in the categories covered by the GPSR needs the manufacturer’s details (name, address, e-mail) and the responsible person’s details where the manufacturer is established outside the EU. On top of that come safety information: a manual, label photos or warnings as PDF, JPG, PNG or text. A filter for incomplete product details in the My Assortment tab finds listings with gaps [16].
Amazon. For non-food products in the EU stores Amazon requires a responsible person established in the EU and the details of the manufacturer and importer. Warnings and safety information have to be on the product and in the listing. You enter the data in the compliance dashboard in Seller Central. Non-compliant listings risk removal or losing access to flash sales [17].
Zalando. Manufacturer, importer and responsible person details are entered once at partner level in zDirect (business profile, compliance details) and apply to all articles, new and existing. At article level Zalando requires a model number and warnings that match the ones on the product and packaging, and for articles launched before 13 December 2024 the attributes cannot be updated retroactively [18].
Kaufland. Seller registration requires, among other things, an official EAN (GTIN) for all products [19]. Packaging EPR registration numbers (extended producer responsibility) are mandatory on Kaufland.de, Kaufland.pl, Kaufland.fr and Kaufland.es, and numbers for other EPR categories depend on the product range [19]. Sellers from outside the EU complete a tax registration in each country and upload a VAT ID for each sales channel; sellers from the EU provide the VAT ID of their home country and an OSS number [19].
We can prepare your listings on Allegro, Amazon and Kaufland so that the GPSR fields (manufacturer, responsible person, safety information) are complete and say the same as the label on the product.
The numbers you already hold (EORI, IOSS, BDO, EPR in the countries of sale) we can keep in one product record that feeds every channel. For larger catalogues we fill in manufacturer and responsible person data in bulk through the marketplace APIs, so one correction reaches every listing.
If you plan further markets after Poland, such as DACH, CEE, Benelux or the Nordics, we can prepare listings in each market’s language. Customs clearance, registrations with the authorities and legal or tax advice stay with your customs agent and adviser.
Where we can help:
Regulation 2019/1020 leaves four options: an EU manufacturer, an importer, an authorised representative with a written mandate, or a fulfilment service provider when nobody else is available [2]. If the Chinese manufacturer has no representative in the Union, the importer usually takes the role. Its name, address and e-mail then appear on the label and in the listing [1].
A company placing packaged products on the Polish market applies for a BDO entry before it starts operating [14]. The PPWR, which applies from 12 August 2026, requires producer registration in every Member State where you first make packaging available. Member States set up the national registers within 18 months of the Commission’s first implementing act [15]. When you sell to several EU countries, plan a separate registration in each of them.
Borys Terlecki, Global Business Development, Marketing at Commercraft. He is responsible for business development and marketing, including relationships with marketplace operators. He previously worked at Mirakl in Munich, on the operator side.
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