GPSR Rules for Online Shops

You run an online shop and want an organised overview: which GPSR rules apply to online shops, what must you do and in what order? This article collects the obligations of an online seller under Regulation (EU) 2023/988 and the Polish act of 7 November 2025. It starts with the question of what role you play in the supply chain, because that determines the scope of your obligations, and ends with a checklist. Platform-specific tips are in a separate article: GPSR for Your Own Shop: WooCommerce, Shopify.

Key points at a glance

• Products offered online are deemed made available on the EU market if the offer is directed at consumers in the Union (Art. 4). The Regulation sets no turnover threshold and no exemption for small shops (Art. 2).
• The scope of obligations depends on your role: manufacturer (Art. 9), importer (Art. 11) or distributor (Art. 12). Selling under your own brand makes you the manufacturer (Art. 13(1)).
• Every offer must contain, clearly and visibly, the manufacturer's details, the responsible person's details (where the manufacturer is outside the EU), product identification, and warnings and safety information (Art. 19).
• In Poland, warnings and safety information are given in Polish (Art. 4 of the act), and missing Art. 19 information carries a fine of up to PLN 500,000 (Art. 76 of the act).

What role does your shop play

Situation	Role under GPSR	Basis
You sell a product under your own name or trademark (incl. private label)	Manufacturer	Art. 3(8), 13(1)
You bring in a product from a third country and place it on the EU market yourself	Importer	Art. 3(10)
You buy from an importer, wholesaler or EU manufacturer and resell unchanged	Distributor	Art. 3(11)
You make a substantial modification to a product	Manufacturer for the modified part or the whole product	Art. 13(2), (3)

One company can play different roles for different products. See also Importer as manufacturer under GPSR.

Obligations by role

Role	Main obligations
Manufacturer	Safe design; internal risk analysis and technical documentation kept 10 years; type or batch number; manufacturer's details on the product; instructions and safety information in the required language; complaint channels and register; measures for a dangerous product (Art. 9)
Importer	Before placing on the market checks conformity and that the manufacturer met Art. 9(2), (5), (6); shows its own details on the product; ensures Polish instructions; keeps a copy of technical documentation for 10 years; checks consumer communication channels (Art. 11)
Distributor	Before making available, verifies that the manufacturer and importer met the requirements on type or batch number, details and instructions; does not make available a product that appears non-compliant; informs the manufacturer or importer about a dangerous product (Art. 12)
Every economic operator	Internal product safety processes (Art. 14); cooperation with authorities and information on request, including on the supply chain (Art. 15); information in distance-selling offers (Art. 19)

What the shop offer must contain (Art. 19)

Where an economic operator makes products available online, the offer must contain, clearly and visibly, at least: the manufacturer's name (or registered trade name or trademark) and postal and electronic address; if the manufacturer is not established in the EU, the name and postal and electronic address of the responsible person; information identifying the product, including its image, type and other identifiers; and any warnings or safety information that must be on the product, packaging or accompanying document, in a language consumers can easily understand (in Poland, Polish).

Responsible person in the EU (Art. 16)

A product may not be placed on the market unless an entity established in the EU is responsible for the tasks in Art. 4(3) of Regulation (EU) 2019/1020 (Art. 16(1)). Under Art. 4(2) of that Regulation this is a manufacturer established in the EU, the importer (where the manufacturer is outside the EU), an authorised representative with a written mandate or - where none of them is established in the EU - a fulfilment service provider established in the EU.

How an online shop is controlled in Poland

Product controls are carried out by provincial inspectors of the Trade Inspection and the supervisory authority is the President of UOKiK (Art. 6 of the act). Controls of products offered at a distance can be remote, including an anonymous test purchase, and the inspector may require the product to be supplied free of charge for testing (Arts. 30-36). Fines have upper limits from PLN 40,000 to PLN 1,000,000, including up to PLN 500,000 for failing to meet Art. 19 (Art. 76); see GPSR penalties.

Checklist for an online shop

1. Establish your role for each product group: manufacturer, importer or distributor.
2. Establish who the responsible person is and collect their details.
3. Obtain technical documentation with a risk analysis from the manufacturer or supplier, or prepare it if you are the manufacturer (Art. 9(2)).
4. Check that the product has a type, batch or serial number and manufacturer details (Art. 9(5), (6)).
5. If you are the importer, add your own details to the product, packaging or document (Art. 11(3)).
6. Prepare warnings and instructions in Polish (Art. 9(7), 11(4)).
7. Put the Art. 19 information in every offer, clearly and visibly.
8. Provide a channel for consumers to report complaints and safety problems (Art. 9(11), 11(9)).
9. Keep a register of complaints and corrective measures (Art. 9(12), 11(10)).
10. Keep documentation for 10 years and be able to name suppliers and recipients on an authority's request (Art. 11(6), 15(3)-(5)).

Frequently asked questions

Does a small online shop have to apply GPSR?

Yes. The Regulation has no turnover threshold or small-shop exemption. What matters is that you offer consumer products to consumers in the EU (Arts. 2 and 4).

I am a distributor - what must I do?

Before making a product available, verify that the manufacturer and importer met Art. 9(5), (6), (7) and Art. 11(3), (4). If you have reason to believe the product is non-compliant, do not make it available until it is (Art. 12(1), (3)). You must still include the Art. 19 information in the offer.

Is it enough to put the data in the terms or the footer?

No. Article 19 requires the product offer to contain the listed information clearly and visibly. Data in the terms or footer does not replace information in the offer itself.

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Legal status as of: 28 October 2026
Legal basis: Regulation (EU) 2023/988 (Arts. 2, 3(8), (10), (11), 4, 9, 11-16, 19; as amended by Regulation (EU) 2024/2748, which only adds emergency procedures); Regulation (EU) 2019/1020 (Art. 4(2), (3)); Polish act of 7 November 2025 on supervision of general product safety (Dz.U. 2025 item 1826; Arts. 4, 6, 30-36, 76). We did not check consumer law, data protection or category-specific rules. This text is not legal advice.
Last review: 28 October 2026