Which rules apply to an importer of goods from China?
An importer is an EU business that first places goods from outside the EU on the EU market. Five sets of rules apply in 2026: PPWR (packaging), BDO (Polish products and packaging register), GPSR (product safety), CE marking and CBAM (carbon emissions). Selling under your own brand makes you the manufacturer.
That definition of importer is in Article 3(10) of the GPSR. The own-brand rule is in Article 3(8) GPSR, Article 21 PPWR and Article R6 of Decision 768/2008/EC.
| Rule | What it covers | Applies from | Main duty of the importer |
|---|---|---|---|
| PPWR, Regulation (EU) 2025/40 | packaging, incl. packaged goods | 12 August 2026 | importer details on packaging, copy of declaration of conformity |
| BDO, Polish Waste Act (ustawa o odpadach) | placing packaged products on the market | before the activity starts | registration, BDO number on documents, report by 15 March |
| GPSR, Regulation (EU) 2023/988 | consumer products | 13 December 2024 | EU responsible person, details on product and listings |
| CE, EU harmonisation legislation | e.g. electrical equipment | depends on the act | checking declaration of conformity and CE marking |
| CBAM, Regulation (EU) 2023/956 | steel, aluminium, cement, fertilisers and more | 1 January 2026 | authorised CBAM declarant status above 50 tonnes a year |
Importing from China and PPWR: what changed on 12 August 2026?
Since 12 August 2026, PPWR, the Regulation (EU) 2025/40 on packaging and packaging waste, has applied. An importer may only place packaging on the market that meets its requirements. It must put its own details on the packaging, check the manufacturer's documentation and keep a copy of the EU declaration of conformity.
The importer's PPWR obligations are in Article 18 of Regulation 2025/40, and the date of application in Article 71. The importer:
- checks that the manufacturer carried out the conformity assessment and drew up the technical documentation (para. 2);
- puts its name or registered trademark, postal address and, where available, electronic contact on the packaging (para. 3);
- keeps a copy of the EU declaration of conformity for 5 years for single-use packaging and 10 years for reusable packaging (para. 7);
- hands documents to an authority within 10 days of a request (para. 8).
The harmonised label on the packaging's material composition becomes mandatory on 12 August 2028 at the earliest (Article 12(1)). An online platform must collect the registration number of a producer selling to consumers before allowing its listings (Article 45(4)).
BDO when importing from China: who must register?
Every business placing packaged products on the Polish market must be entered in BDO. BDO (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami) is the Polish products, packaging and waste database. Importing such products for business counts as placing them on the market, so importers must register before the activity starts.
The duty to register comes from Article 50(1)(6)(f) and (2) of the Polish Waste Act (ustawa o odpadach). Import as placing on the market is defined in Article 8(24) of the Packaging Act (ustawa o gospodarce opakowaniami i odpadami opakowaniowymi). Registration brings four obligations:
- you put your BDO number on documents linked to that activity, such as invoices and receipts (Art. 63 of the Waste Act, bdo.mos.gov.pl);
- you pay a registration fee and an annual fee: PLN 200 for a micro-enterprise, PLN 800 for other businesses (bdo.mos.gov.pl);
- you file an annual report with the voivodeship marshal (marszałek województwa) by 15 March for the previous year (Art. 76(1) of the Waste Act);
- you ensure recycling of packaging waste yourself or through a packaging recovery organisation (organizacja odzysku opakowań), and pay a product fee (opłata produktowa) if targets are missed (Arts 17 and 34 of the Packaging Act).
Operating without registration carries a penalty of PLN 1,000 to PLN 1,000,000 (Art. 194(3) of the Waste Act, BDO registration rules). Distributing products from an unregistered business is prohibited (Art. 41 of the Packaging Act). Since September 2026, BDO has also registered authorised representatives of foreign producers under Article 45(3) PPWR (BDO notice).
GPSR: who is the responsible person for a product from China?
GPSR, the Regulation (EU) 2023/988 on general product safety, has applied to consumer products since 13 December 2024. A product may only be placed on the market if an economic operator established in the EU is responsible for it. For goods from China, that is usually the importer or the manufacturer's authorised representative.
The requirement is set by Article 16 GPSR. Article 4(2) of Regulation (EU) 2019/1020 lists who can take the role: an EU manufacturer, the importer, an authorised representative or a fulfilment service provider. An authorised representative needs a written mandate from the manufacturer.
Under Article 11 GPSR, the importer has four tasks:
- it puts its name or trademark, postal and electronic address on the product or, if that is impossible, on the packaging or an accompanying document (para. 3);
- it adds instructions and safety information in a language consumers can easily understand (para. 4);
- it keeps a copy of the technical documentation for 10 years (para. 6);
- it reports a dangerous product to the authorities through the Safety Business Gateway, the EU notification portal (para. 8).
An online listing must show the manufacturer, the responsible person for non-EU manufacturers, product identification with a picture, and warnings (Article 19 GPSR).
CE declaration of conformity on import: who signs it?
The manufacturer draws up and signs the EU declaration of conformity, and the manufacturer or its authorised representative affixes the CE marking. The importer does not issue a declaration on behalf of a Chinese factory. It checks that the conformity assessment was done and that the product carries the CE marking and documents, then keeps a copy.
The CE marking shows that the manufacturer takes responsibility for the product's conformity with EU requirements. It goes only on products for which a specific EU act provides for it (Article 30 of Regulation 765/2008). The manufacturer's and importer's duties are in Articles R2 and R4 of Decision 768/2008/EC.
The importer puts its name and address on the product and keeps a copy of the declaration for the period set for that product. For low-voltage electrical equipment that is 10 years (Article 8(8) of Directive 2014/35/EU). If you sell a product under your own brand, you are the manufacturer, and you sign the declaration.
CBAM: who does the 50-tonne threshold cover?
CBAM (the Carbon Border Adjustment Mechanism) covers imports of steel, aluminium, cement, fertilisers and a few other goods. An importer is exempt if the combined net mass of such goods does not exceed 50 tonnes in a calendar year. Before crossing the threshold, it needs the status of authorised CBAM declarant.
The threshold was introduced by Regulation (EU) 2025/2083, amending Regulation (EU) 2023/956 (Article 2a, Annex VII). All CN codes in the year count together, and you declare the exemption in the customs declaration. Once you pass 50 tonnes, the obligations cover all imports of that year (Article 2a(2)).
The threshold does not apply to hydrogen or electricity (Article 2a(4)). The first CBAM declaration, for 2026, is due by 30 September 2027, and sales of CBAM certificates start on 1 February 2027.
Annex I also lists finished articles, such as steel screws and nuts (CN 7318), other articles of steel (7326) and articles of aluminium (7616). Furniture in Chapter 94, such as coffee tables, is not on the list.
What do Allegro and Amazon require from sellers of goods from China?
Allegro listings must show the manufacturer's details, the responsible person where the manufacturer is outside the EU, and safety information. You can add your BDO number to your account, but according to Allegro a missing number does not block sales today. By law, the same GPSR details must appear on every platform, Amazon included.
Allegro explains its GPSR requirements in its help centre. Its article on extended producer responsibility states that the Polish EPR number is the BDO number. The number is mandatory by law, but Allegro has no duty to check it.
Selling to Germany is different: without a LUCID register number, buyers in Germany cannot place an order. Allegro says it will check EPR numbers once EU countries adapt their registers to PPWR. On Amazon the same rules apply: Article 19 GPSR and Article 45(4) PPWR.
What do we check before shipment?
Before the goods leave China, we check which of these rules apply to your product: CN code and CBAM, CE, GPSR labelling and packaging. The MEYİS group's own customs team, not an outside broker, clears the goods in Poland: tariff classification, declaration, duty and import VAT.
How clearance itself works is described on customs clearance in Poland. If you are still looking for a manufacturer, start with our sourcing agent in China page. Under DDP from China, the quote settles who acts as importer.
Legal position checked: September 2026.