GPSR Step by Step: From Product to Compliance

A seller of kitchen accessories asks the question heard on every Allegro forum: "OK, I now know GPSR applies to me. But what exactly do I have to do — where do I start and when can I consider myself compliant?". GPSR is often described in vague generalities, while the seller needs a list of steps. This article is exactly that list — from the product in your warehouse to a finished, compliant listing.

We break down the path to GPSR compliance (General Product Safety Regulation, EU 2023/988) into seven concrete stages, so they can be ticked off one by one.

Key points at a glance

• GPSR compliance is a process, not a single document — but it can be broken down into a few repeatable steps.

• The foundation is determining your role (importer/distributor) and the product's risk assessment.

• You must ensure an EU responsible person, warnings and instructions in Polish, and traceability.

• At the end, you transfer the safety data to your Allegro listing — before the consumer buys.

Step 1: Determine your role

Start with the question: who am I in relation to this product? If you bring it in from outside the EU and are the first to make it available to consumers, you're the importer and take on the manufacturer's obligations. If you buy from a Polish wholesaler, you're a distributor with narrower obligations. This determines how much work lies ahead of you — details in Manufacturer, importer, distributor — your role under GPSR.

Step 2: Carry out a risk assessment

GPSR requires an internal hazard analysis before placing a product on the market. For a small product this isn't a PhD thesis — it's a documented answer to the questions: what hazards does the product carry (mechanical, electrical, chemical, for children), how are they limited, and what warnings are needed. The result is a risk assessment document that you must be able to show the market surveillance authority.

Step 3: Check whether the product requires CE or other regulations

Determine whether your product falls under sector-specific directives (electronics, toys). If so — you need a declaration of conformity and the CE mark alongside your GPSR obligations. We break down the differences in GPSR vs CE marking — differences and what you need.

Step 4: Ensure an EU responsible person

This is one of the hard requirements of GPSR (Article 16). For products whose manufacturer is outside the EU, there must be an entity established in the Union, whose details appear on the product or packaging and who is responsible for, among other things, contact with authorities. If you're an importer based in Poland, you usually fulfil this role yourself. The responsible person's details (name, address, contact) must be available to the consumer.

Step 5: Prepare warnings, instructions and traceability

GPSR requires that a product be supplied with information enabling safe use. In practice this means:

• safety warnings and instructions in Polish,

• traceability: a batch number, type or model allowing the product to be identified,

• manufacturer details (name, brand, address) and the importer's, if the manufacturer is outside the EU.

Step 6: Compile the technical documentation

Gather in one place: a product description, the risk assessment, any certificates/declarations, photos of markings, and supplier data. You don't send this anywhere upfront — you keep it ready in case of an inspection. The authority has the right to request the documentation, and its absence is a separate violation.

Step 7: Complete the data in your Allegro listing

GPSR requires that, in distance selling, the consumer sees the safety data before buying. So you transfer to the listing: manufacturer data, EU responsible person data, warnings and — where applicable — pictograms. We show how to do this in the Allegro panel in GPSR on Allegro — how to add the required information.

Compliance checklist

Step	Result	Where you keep it
1. Role	You know you're an importer/distributor	Internal note
2. Risk assessment	Hazard analysis document	Technical documentation
3. CE	Declaration of conformity (if applicable)	Technical documentation
4. Responsible person	EU entity data	Product + listing
5. Warnings and traceability	Polish texts + batch number	Product/packaging
6. Technical documentation	Full set of compliance evidence	Archive
7. Allegro listing	Safety data in the fields	Allegro panel

How long it takes and where to start with a large product range

For a single product, the whole path is a matter of hours. The problem starts when your range runs into hundreds of SKUs. That's when a "grouped" approach matters: products with a similar risk profile (e.g. all cotton textiles, all USB chargers) can be handled with one risk-assessment scheme and one set of warnings, changing only the identification data.

A practical order for a large product range:

1. Group products by category and hazard profile.
2. Prepare one risk-assessment and warnings template per group.
3. Set one responsible person's data (your company) for the whole range.
4. Complete listings in bulk, assigning the ready-made data profiles.

This turns a seemingly unmanageable project into a few repeatable operations. Start with your best-selling listings — they generate the greatest risk and the greatest loss if they get restricted.

The most common mistake on this path

Sellers most often skip step 2 (risk assessment) and jump straight to writing some warnings into the listing. This reverses the order: without a risk assessment, warnings are arbitrary — either too general or missing a real hazard. The risk assessment is the source of the warning content, not a formality to tick off after the fact. Order matters.

Frequently asked questions

Where should I start implementing GPSR?

Start by determining your role — importer or distributor — because that decides the scope of your obligations. Then carry out a risk assessment of the product, ensure an EU responsible person, prepare warnings in Polish and traceability, and finally transfer the safety data to your Allegro listing.

Is a risk assessment mandatory for a cheap product?

Yes. GPSR requires an internal hazard analysis before placing a product on the market, regardless of its price. For a simple product the assessment is short, but it must exist as a document that you can show the market surveillance authority.

Who can be the EU responsible person?

This can be a manufacturer established in the EU, an importer, an authorised representative, or a designated service provider offering such services. If you're an importer based in Poland, you usually fulfil this role yourself, and your details must be available to the consumer.

Do I have to send documentation to any authority?

Not upfront. You keep the technical documentation and risk assessment ready and provide them on request from the market surveillance authority. What is mandatory upfront is the safety data visible in the online listing before purchase.