Warnings and Instructions in Your Listing: GPSR
You're selling night lights on Allegro, sourced from Shenzhen. The listing looks great, the photos are crisp, the price is competitive.
You're selling night lights on Allegro, sourced from Shenzhen. The listing looks great, the photos are crisp, the price is competitive. And then your account gets a listing block because the description is missing warnings and instructions compliant with GPSR. This isn't a marketplace whim — it's a hard requirement of Regulation (EU) 2023/988, in force since 13 December 2024, covering practically every consumer product placed on the EU market.
This article explains which warnings and instructions you need in the listing and on the product itself, so your night light (or anything else from China) doesn't come back to you as a claim or a Safety Gate entry.
Key takeaways
- GPSR requires that a product be supplied with safety warnings and instructions in Polish, understandable to the average consumer.
- Warnings and instructions must reach the consumer — partly in the online listing, partly physically on the product or packaging.
- As an importer from China, when there's no manufacturer or authorised representative in the EU, you take on the manufacturer's duties — including drafting the warnings.
- Missing instructions or warnings is grounds for treating the product as dangerous, even if it's technically sound.
What's the difference between a warning and an instruction
These are two different things, and an inspector treats them separately.
A warning communicates a specific risk: "Do not immerse in water", "Not suitable for children under 3 — small parts", "Overheating risk — do not cover". It protects against a specific hazard arising from use.
An instruction describes how to safely install, use, maintain, and dispose of the product. For a night light, this would include the permitted bulb wattage, how to replace it, and cleaning it while unplugged.
GPSR Article 9 explicitly requires that a product be supplied with instructions and safety information. If you're selling without a manufacturer in the EU, this duty falls on you.
What must be in the Allegro listing versus on the product
GPSR distinguishes online and offline sales. For online sales, some information must be visible in the listing before the customer clicks "buy".
| Element | In the online listing | On the product / packaging |
|---|---|---|
| Manufacturer / importer name and address | Yes | Yes |
| Product identification (type, model, batch) | Yes | Yes |
| Safety warnings | Yes (if relevant to the purchase decision) | Yes |
| Instructions for use | Recommended (summary) | Yes (full, in Polish) |
| Warning pictograms | Yes, where applicable | Yes |
In practice: scan or transcribe the warnings into the listing description, plus a physical Polish instruction leaflet in the parcel. Allegro's GPSR form has dedicated fields for this data — if you leave them blank, the listing can be hidden.
Not sure which warnings to add to your product?
GPSRReady's documentation includes ready-made warning templates, Polish safety instructions, and a risk assessment you can use to pick the right messages for your product category. You fill in Allegro's form fields in minutes.
When you're responsible for warnings (importing from China)
A Chinese manufacturer isn't subject to GPSR — it's outside the EU. GPSR requires that an economic operator established in the EU be responsible for the product. If you bring goods in directly from China and there's no authorised representative or European distributor between you, that operator is you — the importer.
This means you must:
- draft or verify warnings and instructions in Polish,
- make sure they match the actual risk (based on a risk assessment),
- put your name and address on the product or packaging (traceability),
- keep technical documentation for 10 years.
Read more about how an importer steps into the manufacturer's role in Importer as manufacturer — when you take on the duties.
Warnings and risk assessment
You don't invent warnings out of thin air. They follow from the risk assessment that GPSR requires for every product. You analyse how the product might be used (including foreseeable misuse), which user groups are exposed (children, the elderly), and what hazards might occur.
For a night light, the risk assessment would flag things like: shock risk when replacing the bulb while powered, overheating risk of the housing, choking risk from small parts for children. Specific warnings follow directly from this. Without a risk assessment, your warnings are guesswork — and an inspector will catch that.
What happens if warnings and instructions are missing
A product without the required warnings and instructions can be treated as dangerous under GPSR — even if it works properly. Consequences:
- Allegro hiding the listing until the data is completed,
- a recall order from UOKiK,
- an entry in the EU's Safety Gate system (formerly RAPEX),
- liability for damages to a consumer who suffers harm.
See also how this looks from the logistics side: Labelling a product from China under GPSR.
Practical checklist before publishing a listing
- I have a risk assessment for this product category.
- The warnings are in Polish, specific, and matched to the risk.
- The Polish instructions are physically in the parcel and summarised in the description.
- My name and address (as importer) are on the product/packaging and in the listing.
- The GPSR fields in Allegro's form are filled in.
- The warning pictograms are legible and standards-compliant.
Frequently asked questions
Can warnings be in English only, since the product is from China?
No. GPSR requires warnings and instructions to be in a language easily understood by consumers in the country of sale. For the Polish market, that means Polish. An English leaflet from the Chinese manufacturer isn't enough — you must provide a Polish version.
Is it enough to list warnings in the listing description, without a leaflet in the parcel?
No. Information in the online listing satisfies part of the duty (before purchase), but the product must be physically supplied with safety instructions and warnings. The consumer must have access to them after opening the parcel too, without going back to Allegro.
Who drafts the warnings if the Chinese manufacturer didn't supply any?
You, as the importer placing the product on the EU market. You take on the manufacturer's duties, which includes drafting warnings and instructions based on a risk assessment. You can use ready-made templates matched to the product category.
Do warnings apply to simple products too, like clothing?
Yes, to the extent there's a risk. Clothing may need warnings about composition or washing instructions, and children's clothing — for example about drawstrings and small parts. GPSR covers all consumer products, and the scope of warnings follows from the risk assessment of that category.