GPSR and Dropshipping on Allegro: Who's Responsible

The model looks perfect: you list a product on Allegro, the customer pays, you forward the order to a Chinese supplier on AliExpress, and they ship the parcel directly to the customer. No warehouse, no stock on hand. Until 13 December 2024, this was a comfortable grey area. Since Regulation (EU) 2023/988 (GPSR) came into force, this model stopped being safe — because GPSR doesn't care that you're "just an intermediary". If a product reaches a Polish consumer from your listing, someone in the EU must be responsible for it.

This article shows why dropshipping from China on Allegro in the "no EU operator" model is a real risk today, and what you need to change so you don't lose your account.

Key takeaways

• GPSR requires that every product have an economic operator established in the EU responsible for it (manufacturer, importer, authorised representative, or fulfilment provider).

• In classic dropshipping from China, no such operator exists — and by listing the product, you usually become the importer.

• Allegro's GPSR form requires naming a responsible operator with an EU address; without it, the listing is hidden.

• You're responsible for technical documentation, risk assessment, and warnings, even though you never physically handle the goods.

Why dropshipping isn't "just intermediation"

Dropshipping sellers like to say: "I'm just connecting the customer with the supplier". GPSR sees it differently. The key question is: who places the product on the EU market? If you bring goods in from outside the EU and make them available to consumers in Poland — you're the importer, regardless of whether the parcel passes through your warehouse or flies straight from Guangzhou to Kraków.

The fact that you never physically touch the product doesn't release you from responsibility. What matters is that your listing triggered the goods being brought to a consumer in the Union.

The EU responsible operator model

GPSR Article 16 requires that a product be covered by the responsibility of one of these operators:

Operator	Location	Realistic in dropshipping from China?
Manufacturer	China (outside EU)	No — not subject to GPSR
Importer	EU (e.g. you)	Yes — the most common scenario
Authorised representative	EU	Rare — requires an agreement with the manufacturer
Fulfilment service provider	EU	Only when it genuinely stores/ships from the EU

In practice, for a dropshipper from China, there's really only one realistic option: become the importer and take on the duties. Details are covered in Allegro — local responsible operator (GPSR).

What you specifically need as a dropshipper

Since you're the importer, the duties are the same as classic importing, despite having no warehouse:

• Technical documentation for the product — description, specifications, test results, declarations.

• Risk assessment for every product category you sell.

• Warnings and Polish instructions — supplied to the consumer with the product.

• A label with your name and address as importer (traceability).

• The ability to identify who you bought from (supplier) and who you sold to — traceability through the chain.

The problem: in dropshipping, the Chinese supplier packs the parcel, so you don't control what's inside or what label it carries. This is the main flashpoint of this model.

Three ways to run legal dropshipping from China

• Supplier with an EU warehouse — if the product has already been placed on the EU market by an EU operator, you're buying from a distributor rather than importing. Your duties are then lighter (distributor role).

• Limiting your range — sell only products for which you have complete documentation and can provide Polish warnings and an importer label.

• Importer + own repackaging model — bring goods in by batch, inspect them, label them in the EU, and only then ship. This isn't pure dropshipping anymore, but it's safe importing.

Risks you don't see at the start

Dropshippers often only find out about GPSR when Allegro hides the listing or when a letter arrives from UOKiK. Real consequences:

• listings hidden for lacking a named EU operator,

• a recall order and an entry in Safety Gate,

• liability for harm caused to a consumer by a product you never even saw,

• no traceability = a presumption that you are the manufacturer.

How to get documentation when your supplier is in China is covered in How to get documentation from a Chinese manufacturer.

Frequently asked questions

Is dropshipping from China even legal under GPSR?

Yes, but not in the classic "no EU operator" model. There must be a responsible operator established in the Union — usually you, as importer. If you meet the importer's duties (documentation, risk assessment, label, warnings), the model is legal.

Am I responsible for a product I never keep in stock?

Yes. GPSR ties responsibility to placing the product on the EU market, not to physical possession. If your listing triggers shipment from China to a Polish consumer, you're responsible as the importer.

What if I name the Chinese manufacturer as the responsible operator?

That doesn't meet the GPSR requirement. The responsible operator must be established in the EU. A Chinese manufacturer is outside the regulation's scope, and Allegro won't accept it in the GPSR form.

Can I avoid the importer role by buying through an EU wholesaler?

Yes, if the product has already been placed on the EU market by an EU operator (an importer or EU manufacturer) and you're buying as the next link in the chain. You then act as a distributor, with lighter duties — but you must have documentation to prove it.