Importing Food Supplements from the UK to Poland 2026

Food supplement or medicinal product – the distinction that determines everything

Before any discussion of duties, VAT and border controls, one fundamental question must be answered: is the product a food supplement or a medicinal product? This categorisation determines the entire market entry pathway – different regulatory bodies, different registration obligations, different HS codes and different VAT rates.

Under Polish law, a food supplement is a foodstuff intended to supplement a normal diet (Act of 25 August 2006 on food and nutrition safety). The product must not treat or prevent disease or claim pharmacological action. Oversight lies with the Chief Sanitary Inspectorate (GIS), and the importer's only obligation is to submit a notification of first placement on the market – not registration.

Conversely, a medicinal product (even an OTC – over-the-counter product available without prescription) must hold a marketing authorisation issued by the President of URPL (the Office for Registration of Medicinal Products) or by the EMA. Placing a medicinal product on the Polish market without authorisation is a criminal offence carrying fines and criminal liability.

The practical consequence: if the label of a British product carries phrases such as "relieves pain", "helps with cold symptoms" or "clinically proven to treat" – it is most likely a medicinal product, not a supplement, and requires the URPL registration pathway rather than the GIS notification pathway.

Polish regulations: mandatory GIS notification

Under Article 29 of the Food and Nutrition Safety Act, any business operator placing a food supplement on the Polish market for the first time must notify the Chief Sanitary Inspector. The notification is filed electronically via the GIS e-Notification system (accessible through the PUE portal).

Contents of the GIS notification

• Product name and name of the business operator introducing it (importer/distributor);
• Qualitative and quantitative composition – all active ingredients, vitamins, minerals and excipients;
• Pharmaceutical form (capsules, tablets, syrup, powder);
• Label (packaging) template compliant with Polish food labelling requirements;
• Recommended daily serving and warnings;
• Country of origin, manufacturer, country of dispatch.

What happens after the notification is filed

Filing the notification is not an "authorisation". GIS merely maintains a register and may open an inquiry if it has doubts about the product's safety, composition, labelling or classification (e.g. where in GIS's view the product is actually a drug). Such a procedure may last from several weeks to several months and during that time placing the product on the market is formally permitted, though the importer bears the risk of a negative decision.

In practice, for a UK importer this means that sales may commence on the day the notification is filed – there is no need to wait for acceptance. However, the importer must document compositional compliance with the declaration and be prepared for an inspection by the District Sanitary Inspector (PPIS).

UK FSA vs EFSA – two different ingredient lists after Brexit

Before Brexit, supplements legally placed on the market in the UK could automatically be sold in Poland – the UK was part of the single market and the Food Standards Agency (FSA) applied the same ingredient lists as the EU's European Food Safety Authority (EFSA). Since 1 January 2021, this has changed.

The UK now runs its own Novel Food authorisation procedures, its own lists of permitted vitamins and minerals (FSA Assimilated Regulation (EU) 2015/2283) and its own maximum levels. EFSA, meanwhile, updates the EU lists (Regulation (EU) 2015/2283 on novel foods, Regulation 1925/2006 on food fortification).

The practical consequence: a product legally sold in the UK may be illegal in Poland if it contains an ingredient that the UK authorised as a Novel Food but the EU has not yet approved. Classic examples: CBD hemp extracts, certain medicinal mushrooms, edible insects, enzymatically modified hyaluronic acid.

How to check whether an ingredient is a Novel Food in the EU

• The EU Novel Food Catalogue maintained by the European Commission – a free database;
• The Union authorisation list – Annex to Regulation (EU) 2017/2470;
• EFSA opinions – if an ingredient has a positive EFSA opinion it is likely authorised.

If an ingredient is a Novel Food without EU authorisation, the importer must either change the formulation, apply for authorisation (a lengthy and costly procedure, minimum 18 months), or withdraw from the EU market.

HS classification – 2106.90 or 3004

The correct HS (Harmonized System) code is critical not only for the duty rate but also for the VAT rate and potential border controls. Food supplements are most commonly classified under two headings:

Warning: an incorrect classification (e.g. assigning to 2106 a product that carries pharmacological claims and should be in 3004) may result in a tax authority audit, additional VAT assessment, a customs penalty and a block from URPL. At first import it is always worth obtaining a classification consultation from a customs broker.

0% duty under the TCA – but only with preferential origin

The Trade and Cooperation Agreement (TCA) UK–EU of 2020 provides for zero customs duty on goods of UK or EU origin. For supplements in heading 2106 this eliminates the 9–12.8% MFN duty – provided the rules of origin are met.

Conditions for zero duty

• Preferential origin – the goods must "originate" in the UK within the meaning of the TCA origin protocol. If a supplement was manufactured in the UK from Chinese raw materials and does not meet the "substantial transformation" rule, it does not benefit from preferences.
• Statement on Origin – must appear on the invoice or in a separate document. Standard wording: "The exporter of the products covered by this document declares that, except where otherwise clearly indicated, these products are of United Kingdom preferential origin." Above a certain value (£6,000 for UK) the exporter must be registered in the REX (Registered Exporter) system.
• Direct transport – goods must be transported directly from the UK to the EU (transit through a third country is permissible only under the non-manipulation conditions).

Without a statement of origin the customs broker will file the declaration at the MFN rate – and a retrospective refund can then be claimed within 3 years, subject to supplementing the documentation. In practice: always request a Statement on Origin from the UK seller before shipment.

VAT at 8% or 23% – why it matters enormously

Food supplements in Poland are subject to a VAT rate of 8% under Annex 3 to the VAT Act (the category covering food products for special nutritional purposes and food supplements). For a typical UK importer this means a significant cost advantage compared to goods taxed at the standard 23% rate.

When the VAT rate is 23%

• when the product does not qualify as a food supplement under the food safety legislation – e.g. a cosmetic with "nutritional" claims, or a borderline product requiring classification as a cosmetic or medical device;
• when the product is classified under a heading outside HS 2106 (e.g. 1702 – functional sugar preparations);
• when the product contains alcohol above 1.2% or other ingredients that exclude it from the annex;
• when the tax authority classifies the product as a drug rather than a supplement (then 8% VAT applies under the "medicinal products authorised in Poland" category).

Example: a 15-percentage-point difference on a value of £10,000

An importer brings in a batch of multivitamins from the UK with a customs value of £10,000 (approx. PLN 50,000):

• VAT at 8%: PLN 4,000
• VAT at 23%: PLN 11,500
• Cash difference at clearance: PLN 7,500

As a result, applying the wrong VAT rate across several containers per year can significantly impact cash flow. Import VAT can of course be reclaimed, but it must be paid first – Procedure 42 allows this to be avoided when the goods are moving on to another EU member state. See our import clearance service with Procedure 42.

Border and sanitary controls – SPS, PPIS and customs authorities

Food supplements imported into the EU are subject to several parallel control regimes:

Standard customs control

The customs office in the destination country (Poland) verifies that the customs declaration matches the commercial documents – invoice, packing list, T1 document (if transit), Statement on Origin, certificates. Where there are doubts it may carry out a physical examination and take samples.

SPS border control (Sanitary and Phytosanitary)

Since 2024 the UK has formally applied a full SPS regime for goods entering from the EU, and symmetrically the EU requires sanitary controls for certain food categories from the UK. For pure supplement forms (vitamins, minerals, plant extracts not based on animal-derived products) a veterinary certificate or Border Inspection Post (BCP) clearance is generally not required. Note: products containing collagen, chondroitin, fish oils, gelatine – these may require a sanitary certificate and entry via a Border Control Post.

Post-market sanitary inspection

After customs clearance and entry into the warehouse, the District Sanitary Inspector may inspect at any time – checking that the label matches the GIS notification, taking samples for laboratory testing, and checking storage conditions. A negative inspection = withdrawal from sale + an administrative fine.

Polish-language label – information requirements

Even a product legally placed on the market in the UK must carry a label in Poland that complies with Regulation (EU) 1169/2011 on food information to consumers and the Polish Food and Nutrition Safety Act. Minimum requirements:

• name of the foodstuff in Polish + the designation "food supplement";
• list of ingredients in descending order of weight;
• net quantity;
• storage conditions;
• details of the party responsible for information on the label (Polish importer/distributor);
• best-before date or use-by date;
• recommended daily serving;
• warnings: "Do not exceed the recommended daily dose", "Food supplements should not be used as a substitute for a varied diet", "The product should be stored out of reach of young children";
• nutritional value of the active ingredients (RDI – Reference Daily Intake).

The label may be added (re-labelling) at the Polish warehouse – it does not need to be printed in the UK. Many importers use overlabelling: the original English label + a Polish adhesive label. This is acceptable provided the Polish label covers all required information and cannot be easily removed.

What does it all cost – price ranges 2026

The total cost of a single import operation comprises several items. The figures below are typical market ranges – the actual quote depends on value, number of tariff lines, the need for re-packing and inspections.

Price disclaimer: The ranges above are indicative and reflect market rates as of April 2026. The actual quote depends on the shipment characteristics, number of tariff lines, border controls, exchange rates and individual broker policies. Contact us for a personalised quote.

Case study: first shipment of multivitamins from a UK manufacturer

A Polish supplement distributor found a premium multivitamin producer for athletes in Manchester. Trial batch: 2,400 packs at £8 each, total value £19,200. The British manufacturer held REX status and issued a Statement on Origin (UK preferential origin). The product contained only vitamins, minerals and plant extracts from the standard EFSA list – no Novel Food ingredients.

Operational pathway:

1. Week 1: HS classification as 2106.90.92 (vitamin-based supplement), confirmation that the composition complies with Annex to Regulation 1925/2006 (permitted vitamins and minerals);
2. Week 1: preparation of the Polish label – translation, nutritional values, mandatory warnings;
3. Week 2: GIS e-Notification filed – status "registered";
4. Week 3: goods leave Manchester. UK export clearance £80, ENS £20. T1 transit to Poland – from £200 to £500 + guarantee from £225;
5. Week 3: import clearance in Poznań – £200 (approx.), duty 0% (TCA), VAT 8% on customs value + transport costs (base ~PLN 78,000, VAT ~PLN 6,240 – reclaimable via JPK);
6. Week 4: re-labelling at the Poznań warehouse, release for B2C and B2B sale.

Total customs and sanitary handling cost: in the range of PLN 4,000 to PLN 5,500 (excl. VAT). If you need transit, see our article on T1 Transit UK.

Most common mistakes by supplement importers

• No GIS notification – selling before notification = breach of the Food Safety Act, risk of an administrative penalty;
• Classification as HS 2106 instead of 3004 for products carrying therapeutic claims on the label – risk of URPL proceedings;
• Skipping the Novel Food check – CBD, mushroom extracts, insects and some peptides require EU authorisation;
• No Statement on Origin from the UK exporter – loss of 9–12.8% tariff preference;
• Applying 23% VAT "to be safe" instead of 8% – unnecessary cash flow burden;
• Polish label provided as a PDF overlay only – no physical re-labelling before placing on the market.

FAQ – frequently asked questions about importing supplements from the UK to Poland

Does every supplement from the UK need to be notified to GIS?

Yes, if this is the first placement of that specific product on the Polish market by that operator. The notification is filed via the GIS e-Notification system. If the same product is already registered with GIS by another importer, the new operator must still file their own notification – unless acting as a distributor of a product already placed on the market by the registering importer.

How long does GIS registration take?

The online notification takes a few minutes – you receive confirmation of the notification number immediately. Sales may commence on the day the notification is filed. If GIS decides to open an inquiry (which it may at its discretion) it can take from several weeks to several months, but it does not block market entry – only a negative final decision would do so.

What is the VAT rate on supplements from the UK?

For food supplements within the meaning of the food safety legislation, classified under HS 2106 and listed in Annex 3 to the VAT Act, the rate is 8%. Borderline products (drug/supplement/cosmetic), incorrectly classified items, or products containing exclusion ingredients (e.g. alcohol above 1.2%) may be taxed at 23%.

Can UK multivitamins be legally sold in Poland?

In principle yes, provided the composition falls within EU permitted vitamin and mineral lists (Regulation 1925/2006) and contains no Novel Food ingredients not authorised in the EU. UK FSA authorisation alone is not sufficient – the EU now maintains separate lists. Always check every ingredient in the EU Novel Food Catalogue.

What about duty on supplements from the UK?

Thanks to the TCA UK-EU trade agreement, duty is 0% – provided the goods have UK preferential origin and the exporter has provided a Statement on Origin (declaration of origin on the invoice). Without the statement, the MFN rate applies (9–12.8% for heading 2106), which can be reclaimed retrospectively within 3 years.

Can CBD supplements from the UK be imported?

This is a particularly sensitive category. CBD extracts are classified as Novel Food in the EU and require authorisation. EFSA is reviewing dozens of applications, but until authorisation is granted, placing CBD as a food supplement on the market in the EU is formally illegal. The UK took a different approach and the FSA accepts CBD under certain conditions. Importing CBD from the UK to Poland as a food supplement = high risk of seizure by customs and GIS. Consult a lawyer before making a decision.

Can a private individual order supplements from the UK for personal use?

B2C online purchases from the UK to Poland are subject to the same rules as commercial imports, but for small parcels (value up to €150) no customs duty is charged (above that threshold the MFN rate applies, as a private individual cannot obtain a Statement on Origin). VAT is always charged. Novel Food and other restrictions apply equally. In practice, supplement parcels are rarely inspected, but the risk exists.

What the current official guidance means in practice

Regulations on food supplement imports, GIS requirements, Novel Food lists and VAT rates may change. The European Commission updates the Novel Food Catalogue and permitted ingredient lists every few months, and GIS may revise the e-Notification procedure. Always verify current guidance before starting an import operation. The information in this article reflects the legal position as of April 2026.

Official sources

• GIS – Chief Sanitary Inspectorate — e-Notification, 2026
• European Commission: Novel Food Catalogue — 2026
• UK FSA: Regulated products – food and feed — 2026
• Polish Ministry of Finance: customs tariff, VAT rates — 2026
• Trade and Cooperation Agreement UK–EU (TCA) — EUR-Lex, 2021