Short answer
Importing supplements from the UK or the US into Poland requires an EU-based food business operator acting as importer, customs clearance, a formula that meets EU rules on ingredients, novel food and doses, a Polish label with only EU-authorised claims, and a GIS notification before first sale. Since Brexit, the UK is a third country, so the same core steps apply to both.
Importing supplements from the UK or the US into Poland: what changes
Since Brexit, the United Kingdom is a third country for the EU. For supplement brands, that puts British products in broadly the same position as American ones: they are imported into the EU, not moved within a single market. Great Britain kept much of the EU food law it had at the time of leaving, so UK products often start closer to EU compliance than US ones. But the rules on each side can drift apart over time, and "it was compliant in the UK" is no longer a guarantee for the EU.
For both origins, entering Poland means working through four questions:
- Who imports the product and takes legal responsibility for it in the EU.
- How the goods clear customs and any official checks at import.
- Whether the formula is EU compliant - ingredients, forms, doses and claims.
- How the product is labelled and notified in Poland.
You need an EU-based operator and importer
A UK or US company cannot simply ship supplements to Polish customers and be the responsible party. Someone established in the EU must act as the importer and food business operator. That entity's name and address go on the label, it files the GIS notification, and it deals with the sanitary inspection if questions arise.
In general terms, the options are:
- Your own EU entity, for example a Polish company, which imports and sells.
- A distributor or importer who buys the product from you and places it on the market.
- A partner operator who imports on your behalf while you keep ownership of the brand and the customer relationship.
Each option shifts cost, control and liability differently. The choice depends on your volumes, tax position and long-term plans, and should be confirmed with a food law firm and customs and tax advisers.
Customs and border formalities
Goods arriving from the UK or the US must be cleared through EU customs. The importer typically needs an EORI number, correct tariff classification of the products, and documentation that supports origin and value. Import duties depend on the classification and origin, and import VAT is due as well. Food products from third countries may also be subject to official sanitary checks at import.
Practical points we see most often:
- Get the classification right early. Supplements can fall under different tariff headings depending on their composition and form, which affects duty.
- Check origin rules for UK goods. The trade agreement between the EU and the UK can reduce duties, but only for goods that meet its rules of origin. Products made in the UK from non-UK ingredients do not qualify automatically.
- Use an experienced customs agent. Delays at the border cost more than the agent's fee, especially for products with a short shelf life.
- Plan where the Polish label goes on. Either the pack arrives with a complete Polish label, or it is relabelled in the EU before it is placed on the market.
EU formulation rules vs the US and UK
The biggest difference for US brands is the regulatory philosophy. Under the US Dietary Supplement Health and Education Act (DSHEA), dietary supplements generally do not need pre-market approval, and structure/function claims can be made with a disclaimer. The EU works the other way round: permitted vitamin and mineral forms are listed, claims must be authorised, and new ingredients need authorisation.
| Topic | US (DSHEA) | UK (Great Britain) | EU and Poland |
|---|---|---|---|
| Framework | Dietary supplements regulated as food, generally no pre-market approval | Retained rules based on the EU framework, may diverge over time | Directive 2002/46/EC plus national rules; Polish Act of 25 August 2006 on food and nutrition safety |
| Vitamin and mineral forms | Broad range of forms in use | Permitted lists similar to the EU at the time of Brexit | Only forms listed in the EU framework may be used |
| Maximum doses | Generally no statutory maximums | Largely guidance based | Not fully harmonised; national practice applies in Poland |
| Claims | Structure/function claims with FDA disclaimer | GB register of authorised claims | Only claims authorised under Regulation (EC) 1924/2006, in permitted wording |
| New ingredients | New dietary ingredient notifications in some cases | GB novel food authorisation | Novel food authorisation under Regulation (EU) 2015/2283 |
| Before first sale | No general pre-market notification | No UK-wide notification | GIS notification before first placing on the Polish market |
This table is a simplification for orientation. Treat each row as a question to check for your specific product, not a final answer.
Novel food and ingredient status
Novel food is the most common hard stop for US products. Under Regulation (EU) 2015/2283, a food or ingredient that was not consumed to a significant degree in the EU before 15 May 1997 needs authorisation before it can be sold. Many ingredients that are ordinary in US supplements - some botanical extracts, specialised compounds and newer branded ingredients - may fall into this category.
How we check ingredient status:
- List every ingredient and its exact form, including extraction method and plant part for botanicals.
- Check the Union list of authorised novel foods and the conditions of use attached to each authorisation.
- Check the EU Novel Food Catalogue for the status of ingredients not on the list, keeping in mind that it is guidance, not law.
- Review national positions in Poland for botanicals and substances where practice differs between member states.
- Confirm with a food law firm wherever the status is unclear. A wrong guess here can mean a product withdrawal.
Cannabidiol (CBD) products are the best known example: in the EU they are treated as requiring novel food authorisation, which is why many US CBD supplements cannot be sold here as they are.
Typical reformulation issues
In our experience, UK and US products run into the same handful of problems. Most can be fixed without losing what makes the product good.
| Issue | Why it happens | Typical fix |
|---|---|---|
| Doses above Polish practice | US products often use high doses, and maximums in Poland are set nationally | Reduce the dose per daily portion or change the recommended portion |
| Non-permitted mineral or vitamin forms | Some forms common in the US are not on the EU list | Switch to a permitted form with a similar profile |
| Unauthorised ingredients | Novel food status or national restrictions | Remove, replace or wait for authorisation |
| Claims not in the EU register | Structure/function claims do not transfer | Rewrite marketing around authorised health claims, dosed to meet their conditions |
| Label units and reference values | US labels use a different panel and daily values | Declare amounts per daily portion with % NRV for vitamins and minerals |
| Additives and colours | Permitted additives and their conditions differ | Check each additive against EU rules and replace where needed |
Polish label, notification and launch
Once the formula is compliant, the remaining steps are well defined. The label must be in Polish and meet Regulation (EU) 1169/2011 and the specific rules for food supplements, including the three mandatory warnings, amounts per recommended daily portion and the EU operator's details. If your packs arrive with an English-only label, relabelling at an authorised facility in Poland is usually the practical route.
- Finalise the Polish label and have it reviewed against our label checklist and by a law firm.
- File the GIS notification before the first product is placed on the market, with the label draft attached.
- Ship to an EU warehouse registered with the sanitary inspection, and relabel if needed.
- Open one sales channel and build reviews before scaling.
If you are a UK or US brand weighing Poland, our market entry report starts with exactly this gap analysis between your current product and what the EU requires.