Buying From a Polish Wholesaler: What About GPSR

"I buy from a Polish wholesaler with a VAT invoice, so GPSR isn't my problem" - one of the most common beliefs among Allegro sellers. It sounds logical: if the goods are already in Poland, someone before you must have placed them on the market legally. That's partly true - buying from a Polish wholesaler, you're usually not the importer and don't create documentation from scratch. But Regulation (EU) 2023/988 (GPSR), applicable since 13 December 2024, puts obligations on every link in the chain, including the distributor - and the distributor is you. This article shows what to check before buying from a wholesaler, what to enter in your listing, and when the wholesaler's problem becomes yours. If you're unsure of your role in the chain, start with Manufacturer, Importer, Distributor: Your GPSR Role.

Buying from a wholesaler = you are a distributor

If the goods were placed on the EU market by someone else (an EU manufacturer or an importer) and you only resell them, you are a distributor. It's the lightest GPSR role, but not a role without duties. A distributor:

• acts with due care: doesn't sell a product they know, or should know, is non-compliant,
• checks before selling that the product carries the required markings: manufacturer details, responsible person details (for non-EU products), a batch or model identifier, Polish warnings and instructions,
• ensures traceability: can show who they bought from and who they sold to,
• cooperates with surveillance authorities and reports dangerous products,
• in online sales, provides the required product data in the listing.

A wholesaler's invoice is not a certificate of compliance

The most common mental shortcut: treating a VAT invoice from a Polish company as proof of GPSR compliance. An invoice only confirms a transaction. Polish wholesalers - especially those selling Asian goods from wholesale markets - regularly carry products with no manufacturer details, no responsible person and no Polish warnings. If you list such a product on Allegro, it's your listing that gets hidden and you who receives the authority's summons, because you are the one making the product available to consumers.

GPSR requires a distributor, before making a product available on the market, to verify that the manufacturer and, where applicable, the importer have met their labelling and information obligations. A distributor who knows or should know of non-compliance must not make the product available.

What to check before buying: a 10-minute audit

Before ordering a carton of goods, ask the wholesaler for photos of the product and packaging, or ideally a sample unit. Check:

What you check	What should be there	Red flag
Manufacturer details	Name, postal address and electronic contact on the product or packaging	No details at all, or only a Chinese factory name with no address
EU responsible person	An entity with an EU address (for goods from outside the Union)	Clearly Asian goods with no EU entity anywhere
Product identifier	Model, batch or serial number	An anonymous product with no marking
Language	Warnings and instructions in Polish	English or Chinese only
CE marking (where applicable)	CE mark on electronics and toys plus a declaration of conformity available from the supplier	The wholesaler "has no access" to the declaration
Documents on request	The wholesaler can identify the importer and pass on documents or a contact	"Everyone sells this" instead of an answer

If the product falls under CE-marked legislation, also read GPSR vs CE Marking: Differences and What You Need.

When the wholesaler's problem becomes yours

• You sell a product with visible gaps - if there are no manufacturer details on the packaging, "I didn't know" won't work. The gaps were visible and you should have spotted them.
• You sell under your own brand - your logo, your packaging? Under GPSR you become the manufacturer with all its duties. The mechanism is described in Importer as Manufacturer: When GPSR Duties Transfer.
• The wholesaler disappears - when an authority asks about a product and your supplier no longer exists, the full burden of explanation falls on you. That's why you collect documents at purchase, not at inspection.

What to enter in your Allegro listing

As a distributor you must also complete the GPSR listing fields: manufacturer details, responsible person details (for non-EU goods), warnings and safety information. Where do you get them? From the product packaging and from the wholesaler. If the wholesaler can't provide them, go back to the table above - that's a red flag. The field-by-field how-to is in GPSR on Allegro: How to Add the Required Data.

Document your purchases: your shield in an inspection

The minimum set worth archiving with every wholesale delivery:

• the invoice with the wholesaler's name, address and date,
• photos of the product and packaging with visible markings,
• correspondence where you ask about the importer, responsible person and documents,
• any declarations, reports or statements received,
• a link between the delivery and specific listings and sales periods.

This set shows the authority you acted with due care - a distributor's key line of defence.

Frequently asked questions

I only buy from Polish wholesalers. Does GPSR apply to me at all?

Yes, in the distributor role. You don't create technical documentation from scratch, but you must check product labelling, provide the required data in your listing, ensure traceability and cooperate with authorities.

Do I need the technical documentation for a wholesaler's product?

You don't create it - that's the manufacturer's or importer's duty. But you must know who they are and be able to point the authority to them. In practice, get at least the importer's details and basic documents from the wholesaler.

The wholesaler says "everything is compliant". Is that enough?

A verbal assurance is not enough. Ask for the manufacturer's and responsible person's details, labelling photos and documents. If the wholesaler refuses, you sell at your own risk - and visible labelling gaps implicate you too.

What if I repackage wholesale goods and add my logo?

Selling under your own brand changes your role: from distributor you become the manufacturer within the meaning of GPSR. Then technical documentation, risk assessment and labelling are your obligations.