Guide chapters
Product card: information without which an offer cannot be published
The product card is not solely marketing material. It is the place for fulfilling pre-contractual obligations, GPSR, DSA, and industry-specific regulations. The absence of a mandatory element must result in blocking publication, not a yellow warning that the seller can ignore.
Common minimum - this is not an 'Amazon' form#
For GPSR, a common form can be brief. A business entity's offer should include:
- a photo and the name/type of product and an identifier allowing to determine which product the offer concerns;
- the manufacturer's name and its postal and electronic address;
- if the manufacturer is outside the EU - the name and postal and electronic address of the responsible person in the EU;
- warnings and safety information in Polish only if the product requires them;
- the seller, the full price, delivery, and other consumer information relevant to this offer.
There is no general obligation to enter the weight, all dimensions, composition, capacity, serial number, and dozens of parameters for every product. Such fields are activated only for categories where such information is legally required or necessary for safe use and a fair description.
Is a photo of the label sufficient?#
The law requires information to be clearly and visibly available in the offer; it does not mandate a specific database structure. A legible photo of the label can provide some information and is good evidence, but it should not be the sole mechanism for key data.
Minimum variant for the platform:
- the seller adds a clear photo of the entire label/packaging, with the possibility of zooming;
- in short fields or an automatically extracted summary, the platform displays the manufacturer, the responsible person in the EU, the product identifier, and the most important warnings;
- the remaining composition, instructions, and markings can remain on a legible photo or in an attached document, if category regulations do not require a better presentation method;
- a human or automated check rejects blurry, cropped photos, photos in a foreign language without Polish information, or photos depicting a different version of the product.
The photo alone is insufficient if the text is illegible on a phone, the manufacturer remains unsearchable, warnings are not accessible to a screen reader user, or the label does not contain all required information.
Handicrafts and unique items#
A craftsperson is a manufacturer but does not have to invent a model and series that do not actually exist. For a unique painting, mug, or piece of jewelry, the identifier can be the title/name, author's designation, year or date of creation, and a unique item number or another element assigned to the item. The identifier should be on the product, packaging, or a tag attached to the product, and in the offer – not exclusively in the marketplace's internal number.
Instructions and warnings are not mandatory 'for the sake of it'. If a product can be safely used as intended without instructions and warnings, GPSR does not require the creation of fictitious text. A safety analysis appropriate to the product remains required.
Used, vintage, antique, and 'for repair' products#
| Offer type | GPSR rule | Minimum platform decision |
|---|---|---|
| Regular used product sold by a business | GPSR covers used, repaired, and refurbished products | Require photos of the actual condition, product identification, seller, and safety information available for the specific item. |
| Product placed on the EU market before December 13, 2024 | Can be resold if it met previous requirements; no need to add new GPSR markings on the product itself | Seller declares approximate period/origin and shows existing markings; the platform does not enforce a non-existent 'GPSR responsible person' for an old item. |
| Occasional consumer-to-consumer sale | A private consumer generally does not have GPSR business obligations | Lighter form: actual photos, condition, brand/origin if known; still block withdrawn, dangerous, or prohibited products. |
| Antique, work of art, or collectible historical item | Antiques are excluded from GPSR; the mere marketing term 'vintage' does not create an exclusion | Separate category declaration and description of features justifying antique/artwork/collectible status; a regular used item does not go through this path. |
| Product explicitly sold for repair or refurbishment before use | Excluded from GPSR only if this purpose is clearly indicated | Mandatory marking 'do not use before repair/refurbishment', description of defects, and no presentation as a functional product. |
What the buyer must see, and what can remain as evidence#
| Visible before purchase | Stored as evidence, not necessarily public |
|---|---|
| seller and their status; manufacturer; responsible person in the EU; product identification; price; delivery; warnings; category information | declarations of conformity; test reports; origin invoices; power of attorney of the responsible person; risk analysis; certificates; verification correspondence; history of changes and decisions |
| sales/platform terms and conditions; right of withdrawal; complaint procedure; ranking/advertisement; review policy | accepted document versions; offer and checkout snapshot; inspection result; notifications and corrective actions |
Principle of variants and shared offers#
If multiple sellers use a single shared product card, each of them must still be correctly assigned to their offer. A shared description cannot overwrite other variants, manufacturers, importers, or warnings. The platform blocks linking to an existing card when the product code is insufficient to confirm full identity.
I design multi-vendor platforms with onboarding, payments, moderation, and operational workflows.
Explore marketplace development