The dynamic development of the computer games market has led to a significant change in the monetization models used by game producers and publishers. The traditional sales model, based on a one-time purchase of a product by the consumer, has been largely replaced by solutions based on long-term user engagement and generating revenue through micropayments (microtransactions). Mechanisms known as loot boxes, consisting in the paid purchase of virtual packages with random content.

Although initially perceived as a means of enhancing gameplay, this mechanism is currently the subject of intense legal, economic, and social debate. It is increasingly being pointed out that the design of loot boxes utilizes psychological mechanisms similar to those that have been present in traditional gambling games for many years. The random nature of the reward, the uncertainty of the outcome, the “near miss” effect, the limited availability of certain items, and the use of dynamic animations intended to enhance the user’s emotional engagement all contribute to the blurring of the line between entertainment and gambling mechanisms.

Additional controversy stems from the fact that the vast majority of modern games using loot boxes are also aimed at minors. Unlike traditional gambling games, participation in these mechanisms does not require a specific age or meeting specific formal requirements. In practice, this means that random monetization mechanisms are also used by children and adolescents, who, due to their stage of psychological development, are particularly susceptible to the influence of behavioral design techniques and so-called dark patterns).

In recent years, the issue of loot boxes has ceased to be analyzed solely through the prism of gambling law. Regulations concerning consumer protection, digital services, and child safety in the online environment are gaining increasing importance. Discussions at the European Union level indicate that the future legal framework may be based not only on classic definitions of games of chance but also on instruments to combat manipulative practices and ensure a high level of protection for consumers using digital services.

At the national level, the problem remains equally relevant. Polish lawmakers have not yet decided to introduce a separate definition of loot boxes into the Gambling Act of 19 November 2009. This does not mean, however, that these mechanisms remain entirely outside the scope of existing regulations. In practice, administrative bodies assess each specific business model on a case-by-case basis, analyzing whether its design meets the statutory definition of gambling. At the same time, the development of the secondary market for trading in virtual items, particularly so-called skin gambling , is creating new interpretative challenges that the legislature did not anticipate when enacting the current regulations.

The changes introduced by the PEGI rating system in 2026 provided an additional impetus for reassessing the current regulations. The revised rules for classifying games with paid random mechanisms confirm the growing awareness of the risks associated with the use of loot boxes, especially for underage users. Although the PEGI rating is not a source of generally applicable law, its practical importance for the European market remains significant and may influence both the distribution of games and the future direction of legislative changes.

The purpose of this article is to analyze the current legal status of loot boxes under Polish and European Union law, taking into account recent regulatory changes, the practices of administrative bodies, and the experiences of selected European countries. Particular attention will be paid to whether the current regulations effectively protect consumers from mechanisms based on randomness and whether the current regulatory model meets the challenges of the modern digital economy.

The essence of loot boxes and their functioning models

The concept of a lootbox has not yet been defined in either Polish or European Union law. However, in the literature and by public institutions, it is generally accepted that a lootbox is a mechanism whereby the user obtains, for a fee or free of charge, a virtual package containing items whose contents remain unknown until opened. A characteristic element of this solution is randomness – the user has no influence on the item they receive, and the probability of obtaining individual rewards is determined by the game developer or platform operator.

At the definitional level, however, it should be emphasized that the term “lootbox” encompasses a wide variety of business models, the legal assessment of which cannot be uniform. Public debate often equates all mechanisms based on randomness with gambling, while from a legal perspective, individual solutions differ in both their economic structure and the degree of risk to the consumer. It is precisely this diversity that means that assessing the compliance of lootboxes with applicable regulations requires an analysis of the specific operational model, not just the presence of a random element.

The most classic model occurs in games where lootbox content is limited solely to cosmetic items, such as skins , animations, character outfits, or visual effects. These items do not affect gameplay or increase the player’s chances of success. They are intended solely for aesthetic purposes, allowing the user to personalize the appearance of their character or equipment. Such solutions were long considered relatively safe from a consumer protection perspective, but the development of secondary markets for trading virtual items has significantly changed their economic significance.

A good example is the Counter-Strike series, where weapon skins initially served only a visual purpose. Over time, however, a robust secondary market developed around these items, allowing them to be sold for real money. Consequently, the value of some virtual items began to reach several thousand, or even several dozen thousand, and in exceptional cases, several hundred thousand euros. In practice, this means that a randomly acquired item can have a tangible financial value, even though the game developer itself does not officially allow for its sale. The existence of an external market is one of the main arguments raised in the discussion on the classification of such mechanisms as potentially akin to gambling.

Loot boxes used in sports games, such as EA SPORTS FC Ultimate Team, are of a different nature. In this model, users purchase virtual packs containing player cards, coaches, or other team items. Unlike skins in games like Counter-Strike, acquired items directly impact gameplay. Acquiring rare players can increase a team’s competitiveness and improve player performance. Although the developer publishes information regarding the probability of receiving rewards in a given category, the user still doesn’t know the contents of a specific pack at the time of purchase, and the decision to purchase is based on a random mechanism.

Yet another model is found in so-called gacha games, extremely popular, especially in Asian markets and in the mobile gaming segment. This mechanism is based on randomization of characters, equipment, or other items necessary for further progression in the game. A characteristic feature of gacha systems is their close connection to long-term user monetization. Players are encouraged to repeatedly make micropayments to obtain exceptionally rare characters or items, the probability of obtaining which can be extremely low. The literature indicates that these solutions most fully utilize the mechanisms of behavioral economics and the psychology of addiction.

However, the most controversial are third-party platforms that enable the trading of virtual items and participation in games of chance that use items from video games as a form of currency. These services operate independently of game developers, leveraging the existing market for skins or other digital goods to organize mechanisms reminiscent of classic casino games. Users deposit funds or use their virtual items to participate in lotteries, roulette, duels, or other games based on chance. Unlike traditional loot boxes offered by game producers, the participant’s goal is not only to obtain a specific item but often to achieve a tangible economic benefit resulting from the possibility of reselling it.

From a legal perspective, the differences between the presented models are crucial. Not every mechanism employing an element of randomness automatically leads to its classification as gambling. Factors that should be assessed include, first and foremost, the potential for financial gain, the existence of a secondary market, the method of financing participation, the possibility of withdrawing funds, and the actual impact of randomness on achieving a specific outcome. In practice, this means a case-by-case analysis of the specific business model, rather than adopting a uniform classification for all types of loot boxes .

This approach is also reflected in the practice of many European countries. Both administrative bodies and courts are increasingly moving away from abstract assessments of the lootbox mechanism itself, focusing instead on analyzing their actual operation and impact on consumer interests. Consequently, the current legal debate no longer revolves around the question of whether lootboxes as a category should be considered gambling, but rather which monetization models justify their inclusion in a specific regulatory regime.

Loot boxes and the definition of gambling in Polish law

Assessing the compliance of lootbox mechanisms with Polish law requires, above all, an analysis of the provisions of the Gambling Act of 19 November 2009. Although the legislature has not yet decided to introduce a separate definition of lootboxes, this does not mean that these mechanisms remain outside the scope of applicable regulations. On the contrary, in practice, their legal classification depends on whether the specific operating model meets the criteria for one of the games specified in the Act.

The basic premise of the Gambling Act is to subject activities in which the outcome depends on chance to a specific regime, and the participant gains the opportunity to obtain a specific financial or material benefit. The Act does not use the term “lootbox” because it was enacted at a time when modern computer game monetization models were practically nonexistent. This necessitates a functional interpretation, taking into account the economic nature of the mechanism in question, not just its name or the technical solutions adopted by the game developer.

A key element of most loot boxes is undoubtedly randomness. The user making the purchase neither knows the contents of the package nor has the ability to influence the outcome of the drawing. However, the mere presence of a random element is not sufficient to classify a given mechanism as gambling. In practice, the nature of the prize received by the participant and the ability to assign it a real economic value are equally important.

This is where a fundamental difference between classic loot boxes offered by game developers and the mechanisms used by third-party platforms for trading virtual items becomes apparent. If the item obtained through a draw has a purely aesthetic function and cannot be legally exchanged for cash or used outside of the game environment, the arguments for classifying such a mechanism as gambling are significantly weaker. The situation is different when the item is de facto a property that can be freely traded on the secondary market, yielding a real financial benefit.

In practice, the greatest controversy surrounds so-called skin gambling. In this model, users use items obtained in-game as a means of participating in subsequent games of chance organized by third parties. Skins, which were originally purely cosmetic, are beginning to function as a kind of digital currency with measurable economic value. This mechanism leads to a situation in which participants risk losing items of real-world value in exchange for the opportunity to win an even more valuable reward. This structure bears a much greater resemblance to classic gambling games than the traditional micropayment systems used by game developers.

At the same time, caution should be exercised before drawing too far-reaching conclusions. The mere existence of a secondary market does not automatically mean that every loot box should be classified as gambling. From a legal perspective, a case-by-case analysis of the entire business model is necessary, including, among other things, the method of acquiring virtual items, the possibility of their resale, the role of the game producer, the scope of control over the trade in digital assets, and the actual economic significance of the rewards. Consequently, two mechanisms utilizing an identical element of randomness may be subject to entirely different legal assessments.

This position is also reflected in the practice of Polish administrative bodies. To date, there has been no established practice of automatically classifying all loot boxes as gambling. Authorities focus instead on analyzing specific business models and assessing whether they meet the requirements of applicable regulations. This approach reflects the nature of the Gambling Act, which uses functional definitions, leaving authorities considerable scope for assessing individual factual circumstances.

In this context, the practice of entering certain online platforms into the Register of Domains Used to Offer Gambling Games in Contravention of the Act has become particularly significant. However, such an entry does not mean that all platforms utilizing the element of randomness conduct illegal activities. Each decision is preceded by an assessment of the specific operational model of the given service. Consequently, it cannot be assumed that the lootbox mechanism itself has been deemed illegal in Poland. It is not the abstract technical structure that is being assessed, but rather its practical application.

Under current law, it seems more appropriate to ask not whether loot boxes per se constitute gambling, but which of their numerous operating models demonstrate characteristics that justify the application of the provisions of the Gambling Act. This approach avoids oversimplification and better reflects the reality of the digital market, where solutions with widely varying levels of risk to consumers coexist.

At the same time, it should be noted that even if a given mechanism does not meet the criteria for gambling within the meaning of the Act, this does not mean there is a lack of legal oversight. Modern regulations increasingly refer to consumer protection instruments, counteracting manipulative practices, and ensuring the safety of children using digital services. Therefore, analysis of loot boxes cannot be limited solely to gambling law. Regulations regarding consumer protection, digital services, and designing interfaces in accordance with fair trading principles are gaining increasing importance, and in many cases, they may prove to be a more effective tool for protecting users than traditional gambling law instruments.

Loot boxes as a challenge to consumer protection law and the regulation of digital services

Although the debate surrounding loot boxes has for many years focused primarily on gambling law, a shift in regulatory direction is now becoming increasingly apparent, both at the national and European Union levels. Contemporary challenges related to random mechanisms in computer games concern not only the classification of specific models as gambling, but also the compliance of the practices employed with the principles of consumer protection, the protection of minors, and the fair design of digital services.

This change is primarily due to the development of the digital economy. The mechanisms used by game producers are increasingly based not on traditional product sales, but on long-term user engagement and gradual increase in spending through appropriately designed psychological solutions. This phenomenon is referred to in the literature as behavioral monetization, or monetization that leverages knowledge from cognitive psychology and behavioral economics. The goal of such mechanisms is not simply to facilitate a purchase, but to create an environment that encourages users to make subsequent purchasing decisions impulsively or emotionally.

Of particular importance in this regard are so-called dark patterns, referred to in Polish literature as manipulative or deceptive design patterns. These design solutions exploit the workings of human perception and decision-making processes to induce behaviors that are beneficial to the entrepreneur, but not necessarily aligned with the consumer’s true interests. In the case of loot boxes, these can take a variety of forms – from counters counting down the time until the end of a promotion, through messages about the limited availability of specific rewards, to elaborate animations that enhance the emotional experience of opening the packages.

These mechanisms are not coincidental. Psychological research indicates that a reward system based on a variable ratio reinforcement schedule is one of the most effective ways to maintain long-term user engagement. This same mechanism has been used for many years in classic gambling games, where the unpredictability of rewards maintains a high level of motivation for subsequent attempts. In the case of loot boxes, this mechanism is transferred to the computer gaming environment and combined with an attractive audiovisual setting and the ability to immediately make another purchase.

From the perspective of consumer protection law, a crucial question is whether the use of such solutions could lead to a violation of traders’ obligations arising from provisions on fair market practices. It should be noted that contemporary EU regulations increasingly place greater emphasis not only on the content of information provided to consumers, but also on the design of digital interfaces. Therefore, the subject of assessment is increasingly not the product or service itself, but rather the architecture of the purchasing process and the impact of the interface on the user’s freedom of decision-making.

Underage users are particularly important here. Both the European Commission and the European Parliament have repeatedly stated that children using digital services require a higher level of protection than the average consumer. This stems from their limited ability to assess economic risk and their greater susceptibility to persuasive techniques used by businesses. In practice, this means that solutions acceptable to adult users may be deemed disproportionate or unfair if they are primarily targeted at children and adolescents.

The importance of this issue has increased following the entry into force of Regulation (EU) 2022/2065 on the Digital Single Market (Digital Services Act – DSA). Although this act does not explicitly regulate lootbox mechanisms, it establishes a number of obligations regarding the design of digital services and the protection of users from practices that may negatively impact their decision-making autonomy. In particular, the DSA emphasizes the need to ensure a high level of protection for minors and limit the use of solutions that exploit the vulnerabilities of specific user groups. This trend indicates that future assessments of the legality of lootboxes will increasingly be conducted not only through the lens of gambling law but also taking into account consumer protection standards applicable in the digital environment.

In parallel, the European Commission is working on a legislative package known as Digital Fairness, which aims to adapt EU consumer protection regulations to the realities of the digital economy. Issues under review include manipulative design patterns, interface design that exploits user vulnerability, and mechanisms that exert excessive psychological pressure during purchasing decisions. Although the legislative work has not yet been completed, the direction of the proposed changes clearly indicates that future regulations may also cover monetization mechanisms used in video games.

The European Parliament also highlighted the need to enhance the protection of minors in its resolution of 26 November 2025 on the protection of children online. The document indicated that mechanisms such as loot boxes, in-game currencies, and other systems based on chance should be subject to special scrutiny from the perspective of protecting children from addictive and manipulative digital practices. While the resolution is non-binding, it provides an important political signal indicating the direction of future legislative action at the European Union level.

A separate but crucial element of the modern user protection system is the PEGI age rating. Starting in 2026, this system will adopt a more stringent approach to games featuring paid random mechanisms, recognizing them as solutions requiring a higher age rating. While the PEGI rating is not a source of law and does not in itself determine the legality of specific monetization models, it reflects a growing consensus on the need to provide greater protection for minors from mechanisms that utilize randomness and behavioral design techniques.

The above circumstances lead to the conclusion that the future of loot box regulation will likely be shaped primarily by regulations concerning consumer protection and digital services, rather than solely by traditional gambling law instruments. While the Gambling Act focuses on the qualification of specific business models, contemporary EU regulations increasingly assess the design of digital services and their impact on the autonomy of user decisions. Consequently, assessing the legality of loot boxes in the future will require comprehensive consideration of both gambling law and regulations concerning consumer protection, digital services, and children’s rights.

Approach of selected European countries to regulating loot boxes – a comparative analysis

The lack of a uniform definition of loot boxes in European Union law has led individual member states to develop different models for regulating this phenomenon. These differences concern not only the legal classification of random-based mechanisms but, above all, the assessment of the risks loot boxes pose to consumers, especially minors. As a result, the European Union currently boasts both countries adopting a very restrictive approach and jurisdictions that prefer to analyze individual business models rather than create separate statutory regulations.

Belgium has taken the most stringent stance for many years. The Belgian Gaming Commission has determined that certain lootbox mechanisms meet the criteria for gambling if the participant pays a fee, the outcome depends on chance, and the reward represents a specific economic value. Consequently, some game producers have decided to remove paid lootboxes from the Belgian market or significantly limit their functionality. This solution was primarily preventative in nature and aimed at limiting children and adolescents’ exposure to mechanisms that utilize randomness as a monetization tool .

The Dutch experience was different. For many years, the Dutch supervisory authority took a similar stance to the Belgian one, deeming certain lootbox models to be in violation of gambling regulations. The dispute concerned one of the most popular monetization models used by Electronic Arts became the subject of years of administrative and court proceedings. However, the final rulings demonstrated that the classification of loot boxes cannot be based solely on the presence of an element of randomness, but requires consideration of the overall economic structure of the game, the method of trading virtual goods, and the actual potential for financial gain for the user. The Dutch experience thus highlighted the difficulties associated with applying traditional definitions of gambling law to new business models operating in the digital economy.

At the opposite extreme is the approach adopted in Poland. To date, Polish lawmakers have not decided to create separate regulations regarding loot boxes or introduce a statutory definition. This means that the assessment of individual models is based on applicable gambling regulations and an analysis of the specific factual circumstances. This approach provides administrative bodies with significant interpretative flexibility, but also limits predictability for businesses operating in the digital market.

The practice of Polish authorities indicates that a functional assessment of the specific business model is crucial. In the case of platforms enabling the use of virtual items as a means of participating in games of chance, authorities may apply the instruments provided for in the Gambling Act, including entry into the Register of Domains Used to Offer Gambling Games Contrary to the Act. However, this does not automatically mean that all loot boxes used in computer games are illegal. The Polish model is therefore based on an analysis of the economic impact of a given solution, not on an abstract assessment of the randomness mechanism itself.

An analysis of the solutions adopted in individual countries leads to the conclusion that what is becoming increasingly important is not simply classifying loot boxes as gambling, but rather protecting consumers from the psychological mechanisms that lead to excessive spending or compulsive behavior. Therefore, many countries are beginning to perceive the loot box problem as an issue that goes beyond traditional gambling law and requires the use of instruments appropriate to consumer law and digital market regulation.

This approach also aligns with actions undertaken at the European Union level. The European Commission and the European Parliament increasingly point out that the fragmentation of national regulatory models can lead to uneven levels of user protection in the digital single market. The global nature of game producers’ operations means that businesses operate simultaneously in multiple markets, adapting their business models to the most stringent requirements in force in individual countries. In practice, this means that future legal solutions will likely aim for greater harmonization of consumer protection standards at the EU level.

However, this doesn’t mean a complete ban on loot boxes is necessary. A much more likely approach would be to introduce requirements regarding the transparency of random mechanisms, the publication of actual reward probabilities, more effective age verification of users, and restrictions on the use of solutions that exploit the vulnerability of children and adolescents to persuasive techniques. Such a regulatory model would preserve the possibility of using micropayments as a legal method of financing computer games while simultaneously strengthening consumer protection.

From the perspective of Polish law, the experiences of other European countries have significant interpretative significance. They demonstrate that mechanisms operating at the intersection of gambling and digital services cannot be assessed solely through the lens of classic legal constructs developed for traditional casinos or lotteries. The development of the digital economy requires a more comprehensive approach, taking into account both the economic significance of virtual goods and the impact of interface design on consumer decisions. Consequently, the future model for regulating loot boxes will likely be based on a combination of instruments from gambling law, consumer protection law, and regulations governing digital services, rather than the exclusive application of one of these legal regimes.

Conclusions de lege lata and postulates de lege ferenda

The analysis leads to the conclusion that current Polish law does not allow for a uniform legal classification of all lootbox mechanisms. Despite the growing number of voices calling for the recognition of lootboxes as a form of gambling, the current legal status does not provide a basis for automatically subjecting this entire product category to the provisions of the Gambling Act of 19 November 2009. Each assessment requires consideration of the actual operation of the specific business model, the nature of the prize, the potential for further turnover, and the economic impact of user participation in the random mechanism.

This doesn’t mean, however, that the current regulations remain entirely insufficient. With respect to some models operating on the market – particularly platforms that use virtual items as a means of participating in games of chance or enabling their exchange for cash – current regulations may be applicable. The practice of administrative bodies to date demonstrates that the Gambling Act remains an instrument that helps counteract the riskiest forms of activity, especially when virtual goods begin to function as an equivalent of money or property.

At the same time, it’s important to note that the vast majority of modern loot boxes don’t pose a classic gambling law problem. Their primary purpose isn’t to organize games of chance in the traditional sense, but to create a monetization model that leverages psychological mechanisms that increase user propensity to make subsequent purchases. For this reason, the current regulatory debate is increasingly shifting from gambling law toward consumer protection law and the regulation of digital services.

It seems that this is precisely the direction that Polish lawmakers should also adopt. Attempting to classify all loot boxes as gambling would oversimplify the extremely diverse digital market. A much more rational solution seems to be creating separate regulatory obligations for mechanisms that utilize randomness, without the need for automatic application of the entire gambling law regime.

First and foremost, it seems reasonable to introduce full transparency into random mechanisms. Before making a purchase, users should be able to familiarize themselves with the actual probability of winning individual prizes, how the randomization algorithm works, and whether this probability remains constant for all participants. Such solutions already exist in some computer games, but currently they are primarily driven by voluntary decisions by businesses or requirements in specific foreign markets.

The second direction of change should be to strengthen the protection of underage users. In light of current psychological knowledge and the positions of EU institutions, there is little doubt that children are particularly susceptible to the influence of mechanisms based on a variable reward system. Therefore, it seems reasonable to consider limiting the ability of people under a certain age to purchase paid loot boxes or introducing mandatory parental control mechanisms to effectively manage minors’ expenses.

Regardless of the above, legislators should consider introducing more detailed regulations regarding third-party platforms enabling the trading of virtual items. It is this market segment that currently raises the greatest concerns from the perspective of consumer protection and compliance with the Gambling Act. In particular, situations in which items obtained in-game become a means of participation in subsequent games of chance or can be directly converted into cash require analysis. In such cases, the line between a digital service and gambling activity becomes significantly blurred, justifying the application of more restrictive oversight measures.

Obligations regarding marketing activities should also be a crucial element of future regulations. In practice, loot boxes are primarily promoted through influencers and online creators, whose audiences often include minors. While advertising collaborations in and of themselves cannot be deemed unacceptable, situations in which marketing messages exclusively emphasize the possibility of winning exceptionally valuable prizes, disregarding the actual probability of winning them, or employing techniques that could create unreasonable expectations among recipients regarding potential benefits, require special consideration. In this regard, both consumer protection regulations and regulations regarding the integrity of advertising messages may apply.

The issues presented demonstrate that the issue of loot boxes is not limited to gambling law. In fact, it exemplifies a much broader phenomenon involving the use of advanced digital design techniques to influence users’ economic decisions. Technological advancements increasingly render traditional private and public law frameworks inadequate for assessing new business models based on user behavior analysis and interface design that maximizes consumer engagement and spending.

Consequently, the future of loot box regulation will likely depend less on further expansion of the definition of gambling than on the development of European consumer protection standards in the digital environment. Regulations on the transparency of digital services, countering manipulative design patterns, and ensuring a high level of protection for children using the internet are becoming increasingly important . These instruments may become the primary tool for mitigating the risks associated with loot box operations in the coming years.

It should therefore be assumed that effective regulation of this phenomenon requires a multifaceted approach, combining instruments of gambling law, consumer protection law, and digital market regulation. Only such a comprehensive solution will achieve the right balance between the freedom of game producers to conduct business and the need to ensure a high level of protection for users, particularly children and adolescents, who remain most vulnerable to the negative effects of random-based mechanisms.

Artykuł Lootboxes in Computer Games – Between Gambling Law and Consumer Protection. Regulatory Analysis Against the Background of Polish and European Union Law. pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

You see a video, a product catches your eye, and an “add to cart” button is already blinking in the corner of the screen. A few seconds later the order is placed, paid for, and on its way — all without leaving the app. That’s how TikTok Shop works: a closed-loop model in which the path from watching a piece of content to completing a purchase has been cut to the bare minimum. That very immediacy is its greatest strength and, at the same time, the source of its most serious concerns.

A platform that in 2017 drew around 72 million monthly users now attracts more than 1.5 billion — and between 11 and 15 million in Poland alone. TikTok has stopped being merely a place for entertainment and has turned into a powerful advertising and sales engine, combining influencer marketing, algorithmic personalization, and the emotional purchasing impulse. For businesses, it is a new and remarkably effective retail space. For consumers, it is an environment in which it grows ever harder to tell an authentic recommendation from an ad, or a fleeting enthusiasm from a considered decision.

That is precisely why TikTok Shop has landed at the center of lawmakers’ attention. While its model is not unlawful, the platform’s operation intersects with an entire web of regulation: from consumer law and the ban on “dark patterns,” through the EU’s DSA and DMA, data protection and safeguards for minors, all the way to advertising, media, and electronic communications law. This article shows where the convenience of one-tap shopping ends and the protection of the buyer’s free will begins.

What makes the TikTok Shop platform innovative?

Today, an effective marketing strategy is becoming an increasingly important priority for sellers. In Poland, monopolies in sales are relatively rare. Many competing companies operate in most industries. When purchasing products, consumers must choose from hundreds, or even thousands, of options offered by different brands. The scale of this phenomenon is evidenced by the fact that in the fourth quarter of 2025, over 2.9 million active businesses operated in Poland alone, the largest group of which were those associated with the retail sector. Meanwhile, buyers generally do not want to spend much time thoroughly analyzing goods available on the market. They are often guided by the opinions of other users, brand recognition, or media coverage. Therefore, in an information society based on the dynamic development of social media, tailoring advertising to current consumer needs and behaviors becomes crucial for running a business. Authentic and credible recommendations from trusted creators are becoming more important, and for many buyers, they are more persuasive than formulaic television commercials.

Considering the above arguments, many companies are making changes to their advertising strategies, for example, opting for influencer marketing. Online creators typically publish aesthetically and thematically consistent content that captures the interest of users with similar preferences and tastes. A business partnering with an influencer who shares similar values gains the opportunity to reach a large group of potential consumers, made up of the influencer’s followers. TikTok has become the dominant platform enabling the implementation of the marketing model described above. In 2017, the application had approximately 72 million monthly active users, and according to data from 2026, this number has increased to approximately 1.54 billion. In Europe alone, TikTok has already reached over 200 million users, and in Poland, the number ranged from 11 to 15 million. The average time spent on the platform is 70 minutes per day, which translates to approximately 35 hours per month. These statistics also indicate the continued growth of TikTok’s popularity, confirming the future of using social media for advertising and promotional purposes.

The development of influencer marketing significantly changed existing marketing practices, and its increasing prevalence led to the transformation of the TikTok app from a social media platform into an advertising system. The effective and profitable collaboration between media and advertising prompted the platform to take the next step in its development, combining these two sectors. Users were offered the opportunity to completely simplify the purchasing process. Previously, consumers only saw product advertisements, which attracted their attention and prompted them to search for sales offers. However, this pattern left them time to consider whether a purchase was truly necessary or necessary. It was also likely that, despite their interest in the product, they would eventually forget about the advertised product, and therefore their desire to purchase it.

The solution to the marketing strategy described above turned out to be a new feature presented by TikTok: TikTok Shop. The innovative nature of this tool is based on a closed-loop model, meaning the purchasing process takes place within a single app. Users first encounter content promoting a specific item. They then have the option to immediately purchase it by adding the advertised item to their shopping cart in the bottom corner of the app. TikTok acts as an intermediary for payment, shipping, and the entire order process. In this way, the app has evolved not only into a profitable advertising system but also an online store, becoming a marketplace platform that mediates payment, logistics, and order fulfillment.

The origins of TikTok Shop

Initially, the online shopping phenomenon developed through e-commerce. Its popularity contributed to the diversification of online sales into several business models: B2C, B2B, and C2C. The former involves a relationship between a business and an individual customer (examples include online stores such as Zalando, Zara, and IKEA). B2B refers to transactions between businesses, while C2C refers to sales between individuals, such as on platforms like Vinted, OLX, and Allegro.

These e-commerce models typically control the sales process independently. Their profits largely come from consumers who shop by searching for specific products they need. Entrepreneurs compete with each other through marketing activities aimed at convincing consumers of the quality of their products and building brand recognition.

In the next stage, the development of social media, and consequently influencer marketing, contributed to the emergence of a completely new type of buyer, one driven by impulse. Online creators present a specific lifestyle on their profiles in a significantly idealized form, which attracts the attention of their followers and becomes a role model. The desire to emulate the creator they follow can manifest itself both in their behavior and in the possessions they possess. The influencer thus becomes a person who inspires and encourages the purchase of a given product. Even if, from a rational perspective, the buyer doesn’t need the product, they often decide to purchase it under the influence of influencer marketing.

Additionally, a new branch of e-commerce has emerged, known as discovery commerce . This model relies on the discovery and purchase of new items while actively browsing social media. Highly advanced algorithms select content for users that aligns with their tastes or interests, in order to evoke certain emotions that then transform into a strong purchasing impulse. Social media platforms, recognizing this profitable sector, have contributed to the development of social commerce, including TikTok Shop. This solution capitalizes on users’ fleeting enthusiasm and allows them to complete their order without leaving the app. The entire process, from advertising content to payment and shipping, is handled by TikTok, which can limit the time available for rational purchase consideration.

What exactly does the purchasing process look like on TikTok Shop?

TikTok Shop is not a separate app, but a new feature added to the TikTok platform. There’s no need to create a new account or install a new app. This solution provides access to a wide group of potential consumers, as every existing TikTok user over the age of 18 can familiarize themselves with the new feature. This solution gives businesses multiple ways to reach consumers. The platform offers a separate tab, “Shop,” where users can search for specific products using filters and categories, or browse recommended items based on their activity on the platform.

Products offered by sellers using the TikTok Shop service can also be viewed on the “For You Page” tab. This is the subpage most frequently visited by users. This option is especially useful when a company decides to use influencer marketing. A creator posts a video promoting a selected product, and buyers are immediately presented with a purchase button at the bottom of the page. Consumers can also directly access the profiles of brands and creators to find the products they offer or promote.

The latest feature, TikTok Live, is gaining popularity. Before the live stream begins, the seller or influencer adds products available in the TikTok Shop. During the live stream, the host can showcase products, communicate with users, and answer their questions via chat. This can increase the credibility of the product and the seller, as well as encourage consumers to make a purchase, which they can do without interrupting the stream.

The very process of posting ads on TikTok Shop helps build consumer trust. Becoming a seller requires thorough verification, which the TikTok platform conducts to protect users from unreliable and fictitious businesses.

The first step to becoming a seller is to log in to your TikTok Seller Center account using your email address, phone number, or existing TikTok account. You’ll also need to fill out an application form with information that proves your seller credentials, such as your company name, address, and contact information.

After successful verification, the seller completes their store profile, adding a description, name, logo, seller details, addresses, customer service information, and tax information. It’s also necessary to configure payment and delivery methods, including the shipping address, available delivery methods, order processing time, and return policy. Connecting the store dashboard to a regular TikTok account is also crucial. This allows for tagging offered products in live videos, etc. The seller then has the option to publish their product, including the title, description, price, available models, and inventory. The platform also allows businesses to add listings by importing a product catalog from another sales platform.

After a consumer makes a purchase, the seller receives a sale notification in the TikTok Seller Center. The seller is then responsible for packaging and shipping the item to the user, which can be done manually or using external order processing systems.

Distance selling and consumer rights

The TikTok Shop platform offers the option of concluding a sale via a distance contract. This does not require the parties to be physically present at the same time, but rather requires at least one means of distance communication (Act of 30 May 2014 on consumer rights, Article 2). Therefore, when making a purchase through the TikTok Shop, consumer rights are governed by national and European Union law.

In Poland, the primary legal act regulating these activities is the Act of May 30, 2014, on Consumer Rights. Article 12 requires businesses to clearly inform consumers in distance contracts, including the method and deadline for contract execution, the total price including taxes, the right to withdraw from the contract, the complaint procedure, and the seller’s identifying information. The TikTok Shop platform is therefore obligated to provide the required information to the user before finalizing the order via the app. An important regulation is also included in Article 17 of the aforementioned Act and concerns the requirement to design the interface in a way that confirms the consumer’s awareness of the obligation to pay. In the case of platforms that allow order completion via a “button,” it must be clearly marked, e.g., “I buy with an obligation to pay” or “I buy and pay.” Otherwise, the contract is not concluded. The requirements described above are referred to as ” button ” solution ” and are intended to protect consumers from accidentally concluding paid contracts. Alternative obligations also arise from the Directive of the European Parliament and of the Council of 25 October 2011 on consumer rights.

The Consumer Rights Act also implements the EU Commodity Directive (2019/771), introducing uniform standards for the conformity of goods with the contract. A trader is liable for any lack of conformity of goods with the contract upon delivery and for two years from the date the discrepancy is discovered. The Act also governs basic consumer claims in the event of non-conformity, including repair or replacement of the goods, and if this is not possible, a price reduction or withdrawal from the contract.

Given that the sales strategy on the TikTok Shop platform relies on recommendation algorithms and influencer marketing, the Omnibus Directive (EU) 2019/2161 of November 27, 2019, plays a significant role in consumer empowerment. Its regulations introduce the obligation to provide information about the lowest price, disclose whether reviews were published by verified consumers, and indicate whether the seller is a business or an individual. The Omnibus Directive therefore increases consumer awareness and allows consumers to make more rational and manipulation-free purchasing decisions.

Digital Services Act Regulation

Due to their global nature, online platforms reach hundreds of millions of users. Content published through them can reach a very wide audience, thus influencing social, political, and economic relations. Massive social networking sites, therefore, go beyond simply providing entertainment or communication services and digital space, and are beginning to shape the reality around us.

The strong influence of individual platforms on current international relations has initiated more stringent oversight, including through the provisions of Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on the single market for digital services and amending Directive 2000/31/EC (Digital Services Act – DSA). Based on this regulation, TikTok was recognized by the European Commission as a Very Large Online Platform (VLOP). This status is granted to portals with monthly active users exceeding 10% of the EU population. TikTok exceeded the threshold and was classified as a VLOP in 2023.

Platforms deemed globally influential are not solely responsible for removing illegal content. They are also required to counteract the negative consequences that may arise from their operation. Among the most important responsibilities of very large online platforms (VLOPs) is the identification and assessment of systemic risks and the potential implementation of proportionate mitigation measures. Impacts on fundamental rights, democratic processes, the protection of minors, public safety, and the dissemination of illegal content are particularly scrutinized. Once a specific risk is identified, measures are planned to counteract its escalation, such as modifying the user interface or changing certain advertising practices. In emergency situations, the European Commission has the authority to require VLOP providers to assess the platform’s impact on the development of the crisis, implement specific mitigation measures, and submit periodic reports on the effectiveness of these actions. Very large online platforms are also required to undergo an annual independent audit of compliance with the Digital Services Act (DSA) and regularly publish comprehensive reports on their activities. The aim of this action is to ensure transparency of the platform’s operation towards users and supervisory authorities.

The DSA also regulates advertising by introducing the requirement to maintain a public ad repository. This repository should include, among other things, the ad’s content, advertiser, funding entity, broadcast time, and the number of recipients. This solution is intended to ensure transparency in advertising messages and enable social and scientific analysis of platforms’ promotional activities. Restrictions have also been imposed on recommendation systems. This means that VLOPs are required to provide users with at least one way to display content that is not based on profiling, meaning it does not use user activity history or data. To monitor platforms’ compliance with the EU regulation, it is also possible to impose a requirement to share data on, for example, the performance of recommendation algorithms with the European Commission, national digital service coordinators, or verified researchers.

TikTok, however, is not subject only to the obligations of very large online platforms. It is subject to all regulations provided for in the Digital Services Act. According to Article 26, each advertisement must be clearly identified as promotional material and indicate the advertiser, the funding entity, and the mechanism by which it was tailored to the user. This restriction is particularly useful for the TikTok Shop platform, where sponsored content is commonly created in the manner of regular content published by creators. Limiting the phenomenon of so-called hidden advertising through the provisions described above aims to increase user awareness.

One of the DSA’s key goals is also the protection of minors. When designing their services, platforms are required to consider a high level of protection for minors and their privacy. It is prohibited to display advertisements based on the profiling of minors when the platform has knowledge of the user’s minor status. The goal is to limit the use of children’s data for marketing purposes and reduce the risk of addictive use of the app.

The European Commission has also become concerned about potential negative consumer behavior resulting from the increasing transformation of large social media platforms into e-commerce portals. Complex profiling algorithms, influencer marketing, and instant purchases can encourage users to make impulsive decisions or even become dependent on purchasing processes. Articles 25 and 27 of the Consumer Protection Act (DSA) mitigate this risk. Designing web interfaces that manipulate or complicate consumer decision-making – so-called dark patterns – is prohibited. Examples of unacceptable solutions include hiding options that are less favorable to the business, making it difficult to unsubscribe from services, or designing buttons that encourage a specific choice. Users should also be fully aware of how the recommendation system works; therefore, platforms are required to clearly present its main parameters and the possibility of changing the content suggestion method.

Tamper protection and dark patterns

A key premise of the TikTok Shop platform is the immediacy of purchases. While this solution is very beneficial for businesses and, typically, consumers, it can lead to abuse. Sales without leaving the app, a simplified order completion process, and algorithmic personalization of recommended products seem to provide greater convenience when shopping online. However, some activities can be classified as ” dark patterns”, manipulations used to mislead users and influence their decisions. Because the practices described above can lead to impulsive behavior and distort consumer will, they may be treated as unfair market practices and subject to criminal penalties.

The Act of 23 August 2007 on Counteracting Unfair Market Practices defines an unfair market practice as a sale that is contrary to good practice and significantly distorts or may distort the market behavior of the average consumer before, during or after the conclusion of a product agreement , in particular a misleading market practice and an aggressive market practice (Act of 23 August 2007 on Counteracting Unfair Market Practices, Article 4). The main grounds for considering a market practice misleading include the dissemination of false information or truthful information in a potentially misleading manner. Such misleading information typically concerns the existence of a product, its type or availability, price, the method of price calculation, or the existence of a special price advantage.

To encourage immediate purchases, sellers pressure buyers with messages suggesting limited availability or a limited-time promotion for a specific product. Examples of such messages include phrases like “100 people are viewing the product,” “offer ends in 2 hours,” or “only 4 items left.” This practice is not illegal and is one of the most common marketing mechanisms. Problems arise when the website or portal is programmed to continually extend promotions, the offer doesn’t actually expire after the specified date, or the counter restarts upon page refresh.

Misleading practices, such as suggesting the limited nature of a permanently available offer, and aggressive practices, such as exerting time pressure, may result in legal consequences. In addition to the aforementioned Act of 23 August 2007 on Combating Unfair Commercial Practices, this issue is also regulated by Directive 2005/29/EC concerning unfair business-to-consumer commercial practices in the internal market. This directive distinguishes between misleading commercial practices and aggressive commercial practices. Together, they constitute unfair commercial practices, which include, in particular, actions that are contrary to the requirements of professional diligence and that significantly distort or are likely to significantly distort the economic behavior of the average consumer who reaches or is targeted by the practice, or the average member of a group of consumers if the commercial practice is targeted at a specific group of consumers (Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market and amending Council Directive 84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament and of the Council and Regulation (EC) No 2006/2004 of the European Parliament and of the Council (“Unfair Commercial Practices Directive”), Chapter 2, Article 5, paragraph 2).

Directive (EU) 2019/2161 of the European Parliament and of the Council of 27 November 2019 (Omnibus Directive) is also intended to combat various manifestations of the “dark patterns” phenomenon. It requires sellers to disclose the lowest price for a product within the last 30 days. This is intended to prevent the practice of artificially inflating prices and then announcing sales. The practice of fake reviews has also been curbed by introducing an obligation to disclose whether and how reviews posted on sales websites are verified. The Omnibus Directive also introduced the requirement to indicate on marketplace platforms whether the seller is a private individual or a professional entrepreneur, so that consumers are aware of who they are buying from.

The European Union has also introduced restrictions related to the design of digital services, contained in Regulation 2022/2065 on the Digital Single Market (DSA). As a result, online platform providers cannot design, organize, or operate their online interfaces in a way that misleads, manipulates, or otherwise interferes with or limits the ability of service users to make free and informed decisions. The regulation therefore directly addresses the fight against “dark patterns,” i.e., website design practices that deliberately use deceptive techniques, such as pre-selected consents or difficult unsubscribes.

The President of the Office of Competition and Consumer Protection (UOKiK) has broad authority to protect consumers from the unfair commercial practices mentioned above. Under the Act of 16 February 2007 on Competition and Consumer Protection, one of his powers is to protect the collective interests of consumers, including through provisions counteracting unfair market practices. If necessary, the UOKiK President may initiate proceedings against a business, ordering it to cease the unfair practice, or requiring the seller to remedy the effects of the violation. Should a business fail to comply with the guidelines, he may impose a fine of up to 10% of the business’s turnover in the previous year.

The number of legal acts, including EU documents, regulating unfair commercial practices reflects the considerable interest in this issue among both legislators and consumer protection authorities. TikTok Shop, as a social commerce model, is not illegal. It utilizes mechanisms combining influencer marketing, personalization, and emotional impact on the recipient, but the design of the user interface is crucial for this platform. The popularity of mass sales portals has contributed to the increasing use of “dark patterns” by businesses over the past few years. For this reason, the European Union and the Office of Competition and Consumer Protection (UOKiK) are increasingly rigorously monitoring sales tactics and issuing new legal acts to protect consumers and their free will when making purchases.

Influencer Marketing and Advertising Law

The effectiveness of influencer marketing stems from combining advertising with the ability to make an immediate purchase. Affiliate links, product tags, or direct purchase buttons, such as those on the TikTok Shop platform, are displayed beneath posts, videos, or other promotional materials. This purchasing model has proven effective by significantly simplifying the ordering process, thus reducing the time consumers spend considering the rationale behind the transaction.

The popularity of the marketing strategy described above stems from its perception by users, who perceive it as authentic and credible. Influencers present promoted products in a natural way, integrating them into their daily routine. However, if the material does not solely reflect the creator’s personal opinion but is created after receiving a benefit in return, it is considered commercial communication. This means it is subject to legal regulations on advertising and consumer protection. In Poland, influencers should clearly label advertising content in accordance with the Recommendations of the President of the Office of Competition and Consumer Protection. These regulations are intended to prevent misleading users.

Only content regarding a product that the influencer purchased independently and for which they did not receive remuneration or other benefits can be marked as a private opinion. Such material contains genuine feelings and opinions and therefore does not constitute advertising under the law and is not subject to advertising law. This is the most credible and reliable form of review for potential consumers, as it was created by a person not under any obligation to the manufacturer.

A manufacturer may enter into an agreement with an influencer to promote a product in exchange for a free product, financial benefit, or other form of remuneration. This creates legally regulated advertising. It may take the form of a post, report, or live broadcast in which the creator demonstrates how they use the product and its positive properties. Due to the natural presentation of the product as an everyday element, the recipient may have difficulty distinguishing a genuine recommendation from commercial content. The Act of August 23, 2007, on Counteracting Unfair Market Practices, classifies the act of concealing a promotional message as a misleading omission. Failure to clearly indicate the commercial nature of the material may hinder consumers’ proper assessment of the message and directly influence their purchasing decisions.

Another common advertising strategy is to feature a product integrated into published content without directly promoting it, for example, by placing it in the background of the material. This phenomenon is called product placement. Activities covered by advertising and consumer protection law also include, among others, affiliate and partner links, ambassador programs, and partner competitions. In Poland, these practices must contain clear, understandable to the average recipient, and visible advertising labels from the very beginning, such as “advertisement,” “paid collaboration,” or “sponsored content.” The Office of Competition and Consumer Protection (UOKiK) also recommends the use of two-level labeling, meaning that, in addition to the information contained in the content, the platform’s functionality must also be used to announce the paid collaboration. Detailed guidelines can be found in the Recommendations of the President of the UOKiK regarding the labeling of advertising content by influencers. Material is considered advertising content not only when the influencer receives monetary compensation in exchange for its creation. The same obligation applies when promoting your own business, receiving a free product or service, or obtaining a sales commission via an affiliate link or discount code (Recommendations of the President of the Office of Competition and Consumer Protection regarding the marking of advertising content by influencers).

In the event of non-compliance with the Recommendations of the President of the Office of Competition and Consumer Protection regarding the labeling of advertising content by influencers, pursuant to the Act of 16 February 2007 on Competition and Consumer Protection, the Office of Competition and Consumer Protection (UOKiK) conducts proceedings against entrepreneurs using practices that violate the collective interests of consumers. Actions may be taken against advertisers, influencers, and marketing agencies. Therefore, responsibility for incorrect labeling of advertising content rests not only with the creator publishing the material but also with all entities participating in organizing the promotional campaign. One of the sanctions that the President of the UOKiK has the right to impose is a financial penalty. Incorrectly labeled promotional material can also be considered surreptitious advertising. Due to the dynamic development of influencer marketing, the proper creation of marketing content is currently widely subject to UOKiK scrutiny. Therefore, it is worth clearly and understandably labeling sponsored publications, among other things, to avoid significant financial penalties.

Personal data protection

TikTok Shop, as a hybrid social network and e-commerce platform, processes a significant amount of data related to both user activity and purchasing processes. The app’s operation is based on audience profiling and matching the most relevant content. Therefore, the platform’s operations are subject to the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

In addition to user data such as name, surname, contact details, shipping addresses, and payment information, media platforms also collect information that allows for behavioral analysis. Time spent browsing specific products, interactions with ads, and the history of items added to carts or wish lists allow the TikTok Shop platform to create a personalized recommendation system based on past activity. This phenomenon creates so-called behavioral advertising, a marketing strategy based on user profiling using advanced algorithms to predict future purchasing decisions. The concept of profiling refers to the automated processing of personal data, particularly for the purpose of predicting a user’s economic situation, personal preferences, interests, health, and location.

According to the GDPR, profiling is permissible, but it also comes with a number of obligations. Platforms are obligated to transparently inform users about, among other things, the purposes of profiling, the legal basis for data processing, the consequences of the actions taken, and their rights, including the right to object to profiling. Data of minors is particularly protected. Due to the growing popularity of the TikTok app among young users, it was necessary to subject it to special regulations in this regard. In the area of information society services, the processing of data of children over 16 years of age is lawful. An exception is made for situations in which a person with parental authority or guardianship provides prior consent. However, EU member states may introduce a lower age limit in their laws, but it must be at least 13 years old, as is the case in Poland, for example. To ensure that platforms enforce their obligations related to the protection of minors, they should use appropriate age verification mechanisms. In practice, however, this solution requires further improvement due to the common practice of users providing false data during registration.

The President of the Office of Competition and Consumer Protection (UOKiK) plays a crucial role in protecting users, especially the collective interests of consumers. He is authorized to take action against entrepreneurs who engage in unfair market practices, design manipulative interfaces, and so on. Personal data protection, however, falls primarily within the remit of the Office for Personal Data Protection (UODO), which oversees compliance with the GDPR and the secure processing of information by companies and institutions. Due to its global influence, TikTok has attracted increasing attention from EU authorities in recent years and is becoming the subject of more frequent inspections. Due to the platform’s European headquarters being located in Ireland, the relevant supervisory authority is the Irish Data Protection Commission (DPC). For example, in 2025, this institution imposed a fine of €530 million on ByteDance, the app’s owner. The fine was imposed on the transfer of user data from the European Economic Area to China in violation of the GDPR and the failure to demonstrate data protection at the level guaranteed in the EU.

The GDPR is supplemented by Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications), which regulates, in addition to the processing of personal data, the confidentiality of electronic communications, also known as ePrivacy. Due to the scope of its regulations, the provisions of this directive have particular relevance to the TikTok Shop application. The platform uses numerous tracking technologies, such as cookies and mobile device advertising identifiers, to monitor user activity. Information may be stored on a user’s device or accessed only after obtaining prior consent. Exceptions are made only for technologies strictly necessary to provide the service requested by the user, such as remembering a shopping cart. An additional ePrivacy regulation was also envisaged, the purpose of which was to replace the current directive and harmonize the personal data protection rules applicable in all EU Member States. The changes were to include, among other things, simplifying the rules regarding cookies. However, the project encountered legislative difficulties and was not adopted by decision of the European Commission.

Abuse of Market Power and the Digital Markets Plan

The dynamic expansion of the largest digital platforms’ influence has led to the need to adapt competition law to the new situation, particularly in the digital market. To this end, the European Union adopted Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828 (Digital Markets Act – DMA). The Act introduces the concept of a gatekeeper. This term refers to an entrepreneur with an influential position in the internal market, through which business users reach end users. A gatekeeper provides a core platform service and maintains an established market position.

The dominant position of a gatekeeper is also associated with a number of obligations. Among other things, the practice of self-preferencing, which involves favoring one’s own products or services over the offers of other businesses using the platform, is prohibited. In the case of TikTok Shop, this could involve using recommendation algorithms to increase the visibility of products promoted by individual sellers, without applying objective and fair advertising criteria. This type of favoritism and limiting the reach of individual entities could lead to a distortion of fair competition between businesses using TikTok Shop for sales purposes.

By decision of the European Commission, BytaDance Ltd. was granted gatekeeper status solely for the operation of the TikTok application as a social media platform. The DMA regulations governing the gatekeeper position do not apply directly to TikTok Shop, but they may impact the rules for recommending products and using entrepreneurs’ data.

Media law and audiovisual regulations

Audiovisual materials are the primary tool for promoting and selling products on the TikTok Shop marketplace. Therefore, the app’s operations are also subject to scrutiny for compliance with media law and regulations governing audiovisual media services. The dominant role in this regard is played by Directive 2010/13/U of the European Parliament and of the Council of 10 March 2010 on the coordination of certain provisions laid down by law, regulation, or administrative action in Member States concerning the provision of audiovisual media services (Audiovisual Media Services Directive – AVMSD) and the Broadcasting Act of 29 December 1992, which implements it into Polish law. As a result of the amendment to the Act of 11 August 2021, the regulations have been extended to video-sharing platforms, including the TikTok app.

Video-sharing platforms are primarily obligated to implement appropriate measures to protect minors from harmful content that could negatively impact their moral, mental, or physical development. These provisions have been implemented into Polish law through Article 47e of the Broadcasting Act, which mandates, among other things, the marking of potentially inappropriate content with special graphics for young viewers. These regulations are particularly important for the TikTok Shop platform due to the constantly growing number of underage users. Posting content that spreads hatred and discrimination is also prohibited.

TikTok Shop, a hybrid social media platform and e-commerce platform, is often used to publish so-called audiovisual commercial communications—images used to directly or indirectly promote goods, services, or individuals (Directive 2010/13/U of the European Parliament and of the Council of 10 March 2010 on the coordination of certain provisions laid down by law, regulation or administrative action in Member States concerning the provision of audiovisual media services, Article 1). Article 9 of the AVMSD requires member states to ensure that such communications are easily recognizable, thus prohibiting hidden audiovisual commercial communications. The use of subliminal techniques or the inclusion of discriminatory content would also be illegal. The National Broadcasting Council (KRRiT) is responsible for ensuring compliance with audiovisual law. Its remit includes, among other things, overseeing the activities of video-sharing platform providers.

The sales method used by TikTok Shop may seem analogous to teleshopping, offerings directly to consumers to deliver goods or services in exchange for payment. This modern form of interactive audiovisual commerce (live shopping) bears numerous similarities to traditional teleshopping. The mechanisms of both aforementioned sales methods involve presenting the product, its specific features, available options, and generally encouraging the recipient to purchase. However, teleshopping is targeted at a general, anonymous audience who may only be interested in the recommended product. Meanwhile, TikTok Shop relies on advanced algorithms that target promotional content to users who, based on their previous activity, have shown interest in similar content.

Platform liability under e-commerce regulations

The original act regulating the legal liability of online platforms in the European Union was Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market (Directive on electronic commerce). Its foundation was the so-called safe harbor principle, i.e., the principle of limited liability of online intermediaries. According to this principle, hosting service providers and online platforms were not liable for content or goods published by users, provided they had no actual knowledge of the illegal nature of the content or goods or services or, upon obtaining such knowledge, promptly removed any infringements. Furthermore, the directive did not impose a general obligation on platforms to monitor content published by users.

However, the ongoing development of digital platforms has made it necessary to amend the current liability model. Regulation (EU) 2022/2065 – Digital Services Act (DSA) – came into effect on February 17, 2024. This regulation does not eliminate the principle of limited liability but significantly expands monitoring obligations, especially for very large online platforms (VLOPs). One of the key obligations introduced under the new regulations is the Know Your Business Customer (KYBC) principle. This regulation aims to increase the safety of consumers shopping online by limiting sales conducted by dishonest or anonymous traders. Before enabling sales through its platform, an online platform must collect and verify basic data identifying the seller. The required information includes, among others, the trader’s name, registered office address, contact details, registration number in the relevant register of traders, and the trader’s payment account details. In the event of refusal to provide the specified data or providing it falsely, the platform should prevent the trader from conducting sales until the situation is resolved.

A problematic issue related to the TikTok Shop app is defining the platform’s responsibility for transactions conducted by sellers using it. Although TikTok Shop formally acts as an online intermediary, it can be argued that its operating mechanism goes beyond passive hosting. A recommendation system using algorithms, promoting offers, and providing marketing and analytical tools to sellers are the mechanisms TikTok Shop uses to shape consumer behavior and purchasing decisions. The platform’s influence on the visibility of offers and the order fulfillment process may support assigning it broader responsibilities in overseeing the online sales process.

Regulations on electronic communications, including the European Electronic Communications Code and the Polish Electronic Communications Law

The TikTok Shop platform does not constitute an electronic communications service under European Union law, but its operations provide for various forms of electronic communication. TikTok Shop’s use of push notifications, in-app messages, and marketing communications requires the platform to comply with regulations governing electronic marketing and the protection of user privacy in electronic communications. The primary legal acts regulating these aspects are Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code (EECC) and the Act of 12 July 2024 – Electronic Communications Law.

The primary function of TikTok Shop is to enable entities to sell goods through the social media platform. Article 2 of the European Electronic Communications Code defines an electronic communications service as the transmission of signal transmissions or the provision of interpersonal communications services. The mere ability to exchange messages between users or with sellers does not automatically qualify the TikTok Shop platform as a provider of electronic communications services, as this is not its core competency and does not constitute its core business. However, because electronic communications are primarily used for marketing purposes, it is obligated to comply with regulations governing direct marketing and the protection of user privacy.

Push notifications, messages sent directly to users’ mobile devices, are an increasingly popular marketing solution. TikTok Shop uses them to provide information about order status, discounts, time-limited campaigns, or the launch of live shopping. Transactional notifications regarding order fulfillment, shipping, or payment status are typically part of the contract and do not require marketing consent. However, notifications encouraging potential consumers to make a purchase are classified as direct marketing and, in accordance with electronic communications law, require prior user consent.

The practice of using automated calling systems and electronic means of communication for advertising purposes without the user’s prior consent is also prohibited. Users should be clearly informed about the purpose of receiving marketing communications, the data controller, and the possibility of withdrawing consent, which should not result in any negative consequences. With respect to the TikTok Shop platform, the above position means that it is unlawful to send promotional content to users solely based on the fact that they have an account on the app.

TikTok Shop is the clearest example of how thin the line between entertainment, advertising, and commerce has become – a one-tap purchase woven into a stream of content is now as effortless as liking a video. Yet that convenience comes at a price: the closed-loop model and algorithmic personalization shrink the time left for rational reflection, while responsibility for protecting the consumer shifts increasingly away from the buyer and onto the platform and the legislator. EU and national regulations – from consumer law, through the DSA and DMA, data protection and safeguards for minors, all the way to media and electronic communications law – form a web meant to counterbalance the platform’s power and restore the buyer’s awareness of their own choices. TikTok Shop thus remains a dual phenomenon: on one hand a groundbreaking innovation in digital commerce, on the other a test of whether the law can keep pace with a technology that sells faster than we can think.

Artykuł A Store in Your Pocket, the Law in the Background: TikTok Shop Under the Regulators’ Lens pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

We are pleased to share that Kiełtyka Gładkowski KG Legal has published an expert contribution in Infor, one of Poland’s leading legal and financial publications, devoted to one of the most intriguing regulatory phenomena of the digital economy: loot boxes in video games.

“Loot boxes in video games: between gambling law and consumer protection – a regulatory analysis under Polish and European Union law”

The article goes far beyond the classic “are loot boxes gambling?” debate. By analysing the actual monetisation models used in modern games — particularly microtransactions involving paid acquisition of virtual packages with randomised content — we examine how these mechanisms interact with:

• Polish gambling law and the statutory definition of a game of chance,
• EU consumer protection rules,
• digital services regulation,
• taxation and compliance considerations,
• and emerging concerns related to behavioural design and dark patterns.

One of the key conclusions is that the regulatory importance of loot boxes stems not only from their possible resemblance to gambling mechanisms, but also from the fact that such systems are frequently used by inexperienced consumers, including minors, who may be especially susceptible to manipulative design techniques aimed at increasing engagement and spending.

This is precisely the type of cross-sector regulatory issue in which our team has extensive experience — combining expertise in technology law, highly regulated industries, digital services, compliance, consumer protection and EU regulatory frameworks. We are proud that this experience is reflected in publications appearing in professional journals such as Infor.

Read the article here: Infor – Loot boxes in video games: between gambling law and consumer protection

Artykuł Kiełtyka Gładkowski KG Legal has published an expert contribution in Infor, devoted to loot boxes in video games pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

Analysis of key changes for business managers

We have analyzed the proposed changes to criminal procedure, which introduce a new structure for conducting proceedings, moving away from the current, restrictive model. The foundation of the amendment is the liberalization of regulations and the strengthening of procedural guarantees for suspects, which is a direct response to the need to implement EU directives and restore the adversarial standard.

Compared to the current state of affairs, the draft law shifts away from the inquisitorial model and instead provides real legal protection for economic participants. These changes are crucial for individuals serving on corporate boards, effectively increasing their legal security in the area of risks inherent in running a business.

Recent years in Polish criminal procedure have been characterized by the primacy of procedural efficiency over individual rights, leading to a systematic tightening of discipline. This has manifested itself, among other things, in the facilitation of the use of preventive measures and the admission of evidence obtained illegally. Project 1600 makes a systemic shift towards strengthening citizen guarantees, restoring the principle of full equality of the parties and fair litigation. For the business sector, this means a real opportunity to actively shape their defenses at the pre-trial stage, instead of adopting a solely reactive approach.

A key element of this reform is to address years of neglect related to the implementation of the so-called EU defense directives (Directive 2013/48/EU of the European Parliament and of the Council of 22 October 2013 on the right of access to a lawyer in criminal proceedings and in European arrest warrant proceedings, and on the right to have a third party informed upon deprivation of liberty and to communicate with third persons and with consular authorities while deprived of liberty (OJ L 294, 2013, p. 1)). The existing regulations failed to meet European standards, which became the basis for the European Commission to initiate proceedings for Poland’s violation of its treaty obligations. The most important change in this regard is Article 245 § 1 of the Code of Criminal Procedure, which requires that a detained person be immediately allowed to contact a defense attorney and have a direct conversation. As the bill’s justification indicates, detention is a criminal act aimed at prosecuting, and therefore a lawyer or legal advisor providing assistance at this stage has full defense status. Furthermore, the introduction of mandatory on-call duty for lawyers and legal advisors, as defined in Article 245 § 2 of the Code of Criminal Procedure, guarantees effective legal assistance from the very first minute of the proceedings.

This solution is important for management bodies, as the isolation of an organization’s leader creates the risk of paralyzing the entity’s decision-making. The guarantee of immediate legal assistance enables the implementation of crisis management procedures and significantly reduces the risk of submitting flawed procedural declarations with a high degree of economic complexity.

Project 1600 introduces systemic mechanisms to limit the arbitrariness of imposing preventive measures in isolation. A significant change is the increase in the threshold for a severe sentence from 8 to 10 years (Article 258 § 2 of the Code of Criminal Procedure) and the requirement to demonstrate a real risk of perversion in each case. This eliminates the automatic nature of detention in commercial cases, obliging the court to assess whether the severity of the impending sanction actually poses a threat to the course of proceedings in the specific factual circumstances.

The new wording of Article 248 §§ 2 and 3 of the Code of Criminal Procedure serves to discipline law enforcement agencies. It introduces an absolute obligation to release a detainee if, within twenty-four hours (reduced from the current forty-eight) of being brought to the attention of the court, they are not served with a detention order and justification. The legislature establishes an absolute prohibition on re-arrest based on the same facts and evidence. This solution curbs the practice of circumventing procedural deadlines by repeatedly detaining an individual under the same circumstances. For governing bodies, this regulation guarantees the stability of their procedural status and protects personal freedom through repeated isolation.

The reform is complemented by the expansion of evidence disclosure. The amendment to Article 156 § 5a of the Code of Criminal Procedure removes the previous restriction on the exclusion of witness statements from accessible files. The current wording requires the authority to immediately provide the suspect and defense attorney with evidence attached to the arrest request. Restoring full equality of arms allows the defense to substantively refute the prosecution’s entire case, rather than select fragments. For management, implementing these rigors provides fundamental protection against the use of isolation as a pressure tool, directly protecting the reputation and operational stability of the company.

The planned amendment introduces a fundamental change to the Polish criminal process, restoring the primacy of procedural fairness to establishing the material truth at all costs. A key element of the reform is the definitive rejection of the admissibility of so-called “fruits of the poisonous tree,” which directly implements the fair trial standard. Under the current legal framework, shaped by the controversial wording of Article 168a of the Code of Criminal Procedure, evidence cannot be deemed inadmissible solely on the basis that it was obtained in violation of procedural rules or through a prohibited act. Therefore, previous case law permitted the procedural validation of evidence from unlawful sources, provided it was not obtained as a result of the most serious crimes (such as murder or deprivation of liberty). The amendment replaces this model with an absolute prohibition on using materials obtained as a result of a prohibited act. This excludes the possibility of subsequently deeming evidence obtained in violation of the law admissible and prevents law enforcement agencies from remedying procedural deficiencies by invoking an overriding public interest.

In the area of operational control, the reform introduces adequacy rules, which significantly modifies the current procedure for handling incidental evidence. The previous regime of Article 168b of the Code of Criminal Procedure allowed for almost unlimited use of wiretapping materials in cases involving any crime, even if they did not fall within the list of acts justifying the use of operational control. This led to a phenomenon referred to in the doctrine as fishing expeditions, where surveillance ordered in high-stakes cases became a gateway to seeking marginal violations, such as fiscal violations, which would not, in themselves, legitimize such a profound interference with civil liberties. The amendment thus compels the prosecutor to exercise a higher level of investigative diligence, shifting the defense’s focus from substantive analysis of evidence to reviewing the legality of its acquisition.

For the business sector, the implementation of these solutions brings enormous guarantee benefits, primarily in the form of protecting the integrity of business communications and eliminating uncertainty as to the procedural status of managers.

The analysis is based on the standards developed by the European Court of Human Rights in the context of Article 6 of the ECHR, as well as the constitutional principle of proportionality and the right to privacy. The new wording reflects the desire to civilize criminal procedure, where the reliability of state authorities becomes paramount over the ad hoc effectiveness of the public prosecutor, which is the foundation of economic security in a state governed by the rule of law.

The overall proposed changes to criminal procedure should be viewed as a significant strengthening of the legal position of entrepreneurs and management. The shift from an inquisitorial model to a fully adversarial and transparent judicial process significantly minimizes the risk of procedural abuses, which could previously be used as a tool for extraneous pressure in commercial disputes. The reinstatement of strict evidentiary prohibitions and the shortening of procedural deadlines for deprivation of liberty compel law enforcement agencies to adhere to a higher standard of diligence, which directly translates into the operational stability of businesses. Under the new legal framework, the most crucial element of a defense strategy is not only the substantive refutation of allegations but, above all, rigorous oversight of the legality of the state’s operational actions.

Sources:

Directive 2010/64/EU of the European Parliament and of the Council of 20 October 2010 on the right to interpretation and translation in criminal proceedings (OJ L 280, 26.10.2010, p. 1);

Directive 2012/13/EU of the European Parliament and of the Council of 22 May 2012 on the right to information in criminal proceedings (OJ L 142, 1.6.2012, p. 1);

Directive 2014/41/EU of the European Parliament and of the Council of 3 April 2014 regarding the European Investigation Order in criminal matters (OJ EU L 130, 1.5.2014, p. 1, OJ EU L 201, 30.7.2019, p. 47, OJ EU L 39, 21.02.2022, p. 1 and OJ EU L 2023/2843, 27.12.2023);

Directive (EU) 2016/343 of the European Parliament and of the Council of 9 March 2016 on the strengthening of certain aspects of the presumption of innocence and of the right to be present at the trial in criminal proceedings (OJ L 65, 11.03.2016, p. 1);

Artykuł Criminal Procedure Reform (Project 1600) – Polish Standards of Protection in Commercial Matters pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

Jan K., a literature enthusiast with an extraordinary fondness for Polish children’s poetry, finally managed to find a very rare book after a long search – an edition of Julian Tuwim’s “Locomotive,” which he purchased without hesitation from a used bookstore in Maryland, USA, via the online platform AbeBooks. The ease and simplicity of the solution – clicking the “BUY NOW” button, which would soon bring his dream book to him – combined with the bargain price for such a sought-after rarity in the reading community, filled Jan K. with optimism. From that moment on, he simply waited for the Polish Post to knock on his door and deliver him the publication he considered the opportunity of a lifetime. Perhaps it would have been, had Jan K. considered the key issues surrounding importing goods from the USA and the associated costs.

In analyzing the above case, it is crucial to focus on the fundamental concepts related to consumer rights and obligations, which have legal implications – and which can be reduced to the following questions: who does Jan K. become and what does he do in this regard? Given the dynamic growth of global e-commerce between the European Union and the United States, current regulations impose on consumers the role of participants in trade in goods. Under the Union Customs Code, and as confirmed by the case law of the Court of Justice of the European Union (CJEU), goods mean any product that has a measurable monetary value and, as such, may constitute the subject of a commercial transaction. Therefore, every shipment of goods is subject to customs supervision upon crossing the EU border (Article 134, point 1 of Regulation 952/2013 establishing the Union Customs Code), which also includes customs control (Article 5, point 3 thereof), which refers to specific verification activities performed by customs and tax authorities, such as a search of the goods. This procedure may also involve the risk of a customs debt (Article 5, point 18, ibid.), which would impose on the debtor (Article 5, point 19, ibid.) the obligation to pay the applicable shipping charges. Furthermore, raising the issue of a customs representative – in the form of direct or indirect representation (Article 18, point 1, ibid.), Poczta Polska could potentially become this representative.

Returning to Jan K.’s case, since the book meets the definition of a commodity, the consumer effectively becomes an importer of non-EU goods. The American sales platform was therefore merely a tool enabling the transaction and payment, acting solely as an intermediary between the seller and the buyer. Therefore, the consumer bears all legal responsibility for the authenticity of the documents submitted to Poczta Polska for clearance. Returning to reality, Jan K. should pay attention to important legal aspects when purchasing a unique reading item. It’s worth starting by separating the price of the goods from the shipping costs.

Higher mathematics – calculating customs value

If additional fees related to importing goods from the US to Poland are not included in the price, you should calculate how much you will actually pay for shipping, as the final customs value is made up of several additional fees. Shipping to the EU must first be added to the product price. Customs duty, which varies depending on the product type, is added to this amount (this information is available, for example, in the Polish ISZTAR tariff system or the European TARIC). This amount becomes our VAT base, and the tax is calculated from it. Estimating the total cost of goods, including import, significantly helps in making rational consumer decisions and can save our wallets, sometimes unprepared for additional financial burdens.Play

When tariffs work and when they don’t

Is Jan K. rightly happy about his bargain, or will he first have to contend with the customs system? Until now, a fairly favorable rule existed, according to which shipments up to €150 worth were completely duty-free. However, July 1, 2026, introduces a revolution in this area – the duty exemption is replaced by a flat-rate duty mechanism of €3 for each item, representing a group of goods of the same type, and therefore classified under the same CN code. Although from a customs perspective, the seller would be the customs debtor, the Ministry of Finance emphasizes that how this cost is calculated depends on the business policy of the given platform. Many American platforms add the flat-rate duty to the final price in the basket or in the shipping costs. Additional fees may also be related to the seller’s shipping terms – the seller may declare that they will cover import duties (DDP), or the buyer may be responsible for this, and may be charged a surcharge (DAP). Failure to establish clear shipping terms often results in the buyer being required to pay, a fact that only becomes apparent upon delivery. For this reason, Jan K. should verify the terms he agrees to and what additional costs are included in the price.

The IOSS and OSS procedures may provide some stability in terms of fees. IOSS, which applies to purchases of physical goods, including those from the US, is aimed at non-EU entities that conduct distance selling of imported goods (SOTI) and have established an intermediary that is an active VAT payer in Poland. Currently, this system is used by the vast majority of large platforms in the US, such as Amazon, eBay, Etsy, and Shopify, although additional verification is always helpful. EU and non-EU OSS, on the other hand, are primarily useful for digital services (e-books, games), telecommunications and broadcasting services (internet-based television signal delivery), and other intangible services (e.g., educational services). However, a key aspect of the IOSS system, which we will discuss in more detail in the context of purchases on US platforms, is the value threshold – if the actual value of a physical book is within €150, the platform will collect Polish VAT directly during the payment transaction. However, if this value were higher than EUR 150, IOSS cannot be used and the parcel is subject to the standard customs procedure requiring declaration on the SAD H1 document in the AIS-IMPORT system (i.e. use of the VAT E-Commerce system).

Where is the Polish Post Office in all this?

Article 19 of the Customs Law is a treasure trove of knowledge on the proper conduct of customs procedures – it regulates, among other things, the procedure for presenting goods and filing customs declarations in postal traffic handled by a designated operator. This is where Poczta Polska SA comes in, fulfilling this role, thus acting as a link between the e-consumer and the foreign operator. As mentioned earlier, anyone can appoint a customs representative, acting directly or indirectly. However, in the case of shipments imported from countries such as the USA, there is a certain institutional facility known as tacit (implicit) customs representation.

This mechanism works simply: if the actual value does not exceed €150, the designated operator, i.e., Poczta Polska, will be authorized by law to file a customs declaration on behalf of and for the benefit of the recipient (unless the consumer objects to the notification of arrival). What does this mean in practice? The platform simply adds Polish VAT at the time of purchase. If it uses the IOSS system, the customs declaration in the e-commerce system is submitted using the simplified H7 customs declaration, and the consumer receives the parcel from the Poczta Polska postman at no additional charge upon delivery. If the platform is not equipped with IOSS, VAT must be calculated and collected upon the goods’ arrival in the EU, which means the consumer pays VAT under the general rules upon delivery.

What if the shipment value exceeds €150? The problem of verifying whether the platform uses IOSS resolves itself somewhat. In this case, the platform loses its customs supplier status and assumes only accounting obligations, and therefore, customs and tax duties are settled within the scope of full customs declarations in the national AIS-IMPORT system in the importing country. Poczta Polska does not have an implied power of attorney in this case – the recipient receives a notification and must submit the required documents within 14 days, grant Poczta Polska a customs power of attorney, or otherwise perform customs clearance on their own.

Cooperation with Poczta Polska – proper documents for conscientious service

Courier companies are becoming increasingly popular, ensuring efficient delivery and clear communication. However, when importing goods from a non-EU country, additional fees may be charged. Poczta Polska often proves to be a more cost-effective alternative, but it requires a complete set of documents. This list includes: confirmation of the type and value of the goods; proof of payment: shipping costs, insurance, and any discount information; recipient details and additional documents such as certificates and permits (in transactions between private parties, a “declaration regarding the goods contained in the shipment” in the case of gifts). Importantly, the better the description of the parcel, the less chance of additional complications, such as the need to clarify the contents, prepare corrections, or delays.

Polish Post’s negative dictionary

Since we’ve touched on customs situations that can prove particularly problematic, we should mention Poczta Polska’s blacklist of goods – or rather, its negative vocabulary. This list lists goods for which Poczta Polska does not perform customs clearance under the VAT E-commerce package; customs clearance is handled independently. These primarily include: goods shipped as commercial samples, medicines and medical devices (high risk of shipment detention), food (possible additional inspections), plant and animal products (often subject to separate sanitary regulations), weapons, collectibles and counterfeits (intellectual property rights), electronics with batteries (frequent transport requirements), alcohol and tobacco products (tax regime and quantity restrictions). These goods therefore require special care and adherence to formal requirements, not to mention the need for full customs clearance using the SAD H1 import document.

Other (this time favorable) exceptions

Goods that deviate from the rule regarding proper customs clearance can also have a positive impact on the consumer. These special situations include, among other things, customs duty exemption. Under Article 203(3) of Implementing Regulation 2015/2447, non-Union goods that originally had EU status are exempt from import duties as a result of being exported from outside the EU and then re-imported within three years and released for free circulation. Another example, although going beyond sales on foreign sales platforms, are gifts with an actual value of up to €45 – they are completely exempt from customs duty if they are a private-to-private, occasional, free-of-charge, and appropriately marked package (excise goods do not apply here).

How will all this work in practice? The case of Jan K.

To this end, let’s consider two scenarios: in the first, Jan K. managed to snag his dream book for only €50, as it didn’t stand out from the catalog of books available at the second-hand bookstore. In the second, Jan K. paid €300 for “Lokomotywa” (The Locomotive), as it was a collector’s edition, practically unavailable in the current reading market. The AbeBooks platform, like most major American platforms, uses the IOSS system. What path will a consumer of the American sales platform have to take to enjoy their desired book?

Scenario 1: Locomotive below €150

The customs value is immediately apparent – Polish VAT was added to the price of the goods, and payment was made via the AbeBooks platform, while imports at the border are VAT-exempt. Although the flat-rate customs duty of €3 per item should have been paid through the platform, Jan K. should be aware that this amount could have been included in the price of the book itself or in the shipping costs. The parcel was shipped from the USA, and the seller marked it with the platform’s IOSS identification number. Jan K. did not object, so Poczta Polska became the tacit customs representative and processed the clearance automatically, using a simplified H7 customs declaration in the e-commerce system. The parcel was not classified as a collector’s item, which was due to the seller’s precise and detailed descriptions. A Poczta Polska postman delivered the parcel to Jan K., and from that moment on, he was able to immerse himself in Tuwim’s poetry.

Scenario 2: “Locomotive” above €150

Now let’s analyze a slightly less favorable option for Jan K.: Here, customs duty and VAT are not included in the book’s price, which initially pleased Jan K. The seller shipped the package, but because it was shipped from the United States, the carrier must submit an Entry Summary Declaration (ENS) and lodge it with the appropriate customs office before the goods arrive. An ENS would not be necessary only if the sale was made from common transit countries that have concluded agreements with the EU on the recognition of security and safety inspections conducted in these exporting countries, namely Norway, Liechtenstein, and Switzerland. When the package reaches Poland, customs and tax systems block its further route, and it is placed under customs supervision. Poczta Polska sent the importer, Jan K., a paper notification (although electronic notification is also possible) about the shipment being held for customs clearance. A terrified Jan K. tried to find out what was happening with his parcel and why it had been detained. He finally discovered that Poczta Polska was not his customs representative. After controlling his emotions, he gathered the necessary documentation, which included proof of purchase, payment confirmation with a breakdown of the price of the goods themselves, shipping fees, and item description, as well as a signed power of attorney, and sent it to Paczka Polska. Poczta Polska, which had become Jan K.’s active representative, processed customs clearance using the AIS-IMPORT system, using full import customs declarations on the SAD H1 document. The customs and tax office then assessed fees: customs duty based on the CN customs classification and VAT based on the tax base, which is the combined price of the goods, transportation fees, and customs duties. This process was successful, the parcel was returned to postal service, and the postman knocked on Jan K.’s door – the importer’s enthusiasm was somewhat lower than in Scenario 1, as he had already incurred customs and VAT costs before beginning the reading.

What if the package arrives damaged?

The complications continue: the package was damaged, and we don’t know who to contact. Since the introduction of the Tax Explanations on July 1, 2021, autonomous tax law creates a legal fiction under which the electronic interface operator is considered a B2C supplier, the platform is therefore obligated to tax and settle the transaction. This solution is primarily beneficial to officials, who find it more convenient to collect VAT from a large platform than from hundreds of smaller sellers. On the other hand, it creates a certain ambiguity – as we established above, the platform is still merely an intermediary under civil law. Why do we see a discrepancy here? Because of the issue of tortious liability.

If the “Locomotive” purchased by Jan K. were lost or destroyed before delivery, from July 2021, the consumer would have to direct warranty or non-performance claims to the Maryland antiquarian bookstore, not the AbeBooks platform (if the damage occurred during transport, i.e., before formal release by customs). It should undergo a qualification process as defective goods, and if approved, the American seller is to make a price adjustment, which will reduce the overall customs value, automatically including the costs of customs duty and VAT. For goods over €150 or of collector’s value, the loss or destruction of a package in the warehouse results in a customs debt, and Poczta Polska becomes the debtor. If damage to goods worth less than €150 occurred during transport by Poczta Polska, after legal qualification and removal of the goods from customs supervision, the postal operator is obligated to pay the VAT, along with default interest.

Despite the many scenarios, one important rule stands out – the platform itself very rarely pays compensation. Based on US court decisions (such as the Bolger vs. Amazon.com, LLC case, in which Angela Bolger suffered serious bodily injury after a laptop battery purchased through Amazon exploded), it can be assumed that the chance of obtaining compensation increases essentially only if the platform controlled the physical delivery process. Or rather, if this can be proven in court. Platform uniqueness, as Janger and Twerski called it in their renowned 2023 analysis, is increasingly being raised as a serious problem for consumer protection and rational risk management. American sales platforms hide behind formal definitions of “sale” and “title,” but in practice, these explanations have little application. This absurdity is particularly evident in models such as FBA (Fulfillment by Amazon), where the platform stores, packages, and ships the goods, and claims the right to substitute without consulting the consumer. The fiction of a “recognized supplier” exists under VAT law, yet remains free from civil liability.

Cost-related catches – what to watch out for so as not to overpay

As the example above shows, the issues of cost and financial responsibility are often ambiguous, so it’s important to understand what additional fees we might be exposed to. Distinguishing the price of the goods from transportation fees, customs duties, and VAT is the first, but not the last, point at which we should consider how much importing goods purchased on an American marketplace will actually cost us. In addition to the components of the customs value, we must also consider other possible fees, such as the cost of insuring the imported goods, loading and handling fees associated with their transport to the national border or a Polish port.

The principle that “determinations of charges for transport costs must be unambiguous, precise, and separate for domestic and international sections” is one of the key aspects of EU customs law. Why is this so important? According to Articles 71 and 72 of the UCC, foreign and domestic sections are treated differently – the customs value of goods increases upon entry into the customs union, whereas within the EU, costs are not included in this value. However, the Act introduces a condition here, specifically a clear separation of goods and transport costs (which is why this had to be clearly stated in Scenario 2 of Jan K. in Jan K.’s documents for Poczta Polska). If only one transport amount appears on the invoice, the customs authority has the right to include 100% of the transport costs in the customs value. This trap, known as the cascading effect, is likely to occur in transactions on online marketplaces, as confirmed by the Supreme Administrative Court’s rulings in this case.

The customs authorities’ reasoning can be traced to the Supreme Administrative Court’s judgment of March 17, 1999 (SA/ Sz 1731/98). In this case, the Spanish wine seller failed to divide costs and sections into foreign and domestic, and the transaction itself resulted in two sets of invoices for different amounts (the second set of invoices had a significantly higher value). The Supreme Administrative Court dismissed the importer’s complaint regarding alleged violations of customs and administrative law by the customs authorities, and in its justification, cited the obligation to determine the amount due in a clear and precise manner, using objective and measurable data. The judgment is a reprimand for the company’s arbitrariness.

Separating costs is also important in so-called simplified procedures. As mentioned earlier, the simplified H7 declaration applies to products whose actual value, i.e., the price of the goods themselves, does not exceed €150. If the seller fails to separate the costs on the invoice, shipping costs will be included in the actual value – if this amount exceeds €150, the seller will have to go through the full customs procedure. Failure to clearly present the cost breakdown could also impact the efficiency of the entire import procedure. Because the simplified H7 declaration is processed automatically by the National Tax Administration, the algorithm may detect irregularities in the declared data, which may result in document revisions or a physical inspection of the package. This, in turn, can generate potential delays and other problems.

There are also minor and often overlooked issues, such as different CN codes for goods in the same package. A separate flat-rate customs duty must be paid for each item from a different line item. Let’s not forget the mundane, yet utterly human, issue: if the item we ordered doesn’t meet our expectations and we want to return it, the customs and VAT costs will not be refunded. With this in mind, it’s important to weigh the pros and cons before making a final decision.

Summary

The purchase of Tuwim’s “Locomotive,” besides its aesthetic appeal, undoubtedly provided Jan K. with insight into the EU customs system for goods imported from outside the European Union, specifically the USA. The most important lessons learned from this lesson include an awareness of the consumer’s role when importing goods from outside the EU and their customs and tax obligations, as well as the operating principles and powers of the Polish Post, along with its requirements for importers. The potential costs incurred by both consumers and sellers in transactions made via the online marketplace were also analyzed. A study of regulations and specific examples demonstrated the importance of a properly conducted procedure for both parties, so as to avoid unnecessary financial burdens on either side.

In the current era of globalization and the development of global export giants, purchasing products and services online is inevitable. American platforms such as Amazon, eBay , Wayfair, Target, and Walmart, having established a stable and strong position in the global market, conduct sales primarily focused on protecting their structures and generating profits. Therefore, as Polish consumers of American products, we should, above all, protect our own interests and financial security, be aware of the dangers and risks associated with ignorance of appropriate customs procedures and our obligations as a party to the transaction. In other words, let’s follow the example of Jan K., who fulfilled his desire for a unique book by studying his consumer rights and responsibilities on the American platform AbeBooks.

Bibliography:

Legal acts:

Act of 11 March 2004 on tax on goods and services (consolidated text: Journal of Laws of 2025, item 775, as amended). https://sip.lex.pl/#/act/17086198/444640770/podatek-od-towarow-i-uslug?keyword=podatek%20od%20towar%C3%B3w%20i%20us%C5%82ug%20&searchPit=2026-07-15

Act of 19 March 2004 – Customs Law (consolidated text: Journal of Laws of 2024, item 1373). https://sip.lex.pl/#/act/17088507/441956979/prawo-celne?keyword=ustawa%20prawo%20celne%20&searchPit=2026-07-15

Council Regulation (EC) No 1186/2009 of 16 November 2009 setting up a Community system of reliefs from customs duty (codified version) (OJ L 324, 2009, p. 23, as amended). https://sip.lex.pl/#/act/67914249/3571055/rozporzadzenie-1186-2009-ustanawiajace-wspolnotowy-system-zwolnien-celnych-wersja-ujednolicona?keyword=Rozporzadzenie%C4%85dzenie%201186%2F2009%20ustanawiaj%C4%85ce%20ws%C3%B3lnotowy%20system%20zwolnie%C5%84%20celnych%20(wersja%20ujednolicona)&searchPit=2026-07-15

Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code (OJ L 269, 2013, p. 1, as amended). https://sip.lex.pl/#/act/68359246/176766672/rozporzadzenie-952-2013-ustanawiajace-unijny-kodeks-celny?keyword=Rozporz%C4%85dzenie%20952%2F2013%20ustanawiaj%C4%85ce%20unijny%20kodeks%20celny%20z%201%20maja%202016%20&searchPit=2026-07-15

Commission Implementing Regulation (EU) 2015/2447 of 24 November 2015 laying down detailed rules for implementing certain provisions of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union Customs Code (OJ L 343, 2015, p. 558, as amended). https://sip.lex.pl/#/act/68591768/181445989/rozporzadzenie-wykonawcze-2015-2447-ustanawiajace-szczegolowe-zasady-wykonania-niektorych…?keyword=Rozporzadzenie%20wykonawcze%202015%2F2447%20z%201%20maja%202016%20&searchPit=2026-07-15

Ministry of Finance. (2021, September 1). Tax clarifications regarding the so-called VAT e-commerce package introduced by the Act of May 20, 2021, amending the Act on Value Added Tax and certain other acts (Journal of Laws, item 1163) . https://www.podatki.gov.pl

Judgment of the Supreme Administrative Court in Szczecin of 17 March 1999, SA/ Sz 1731/98, M.Podat. 2000, no. 5, item 29.

https://sip.lex.pl/#/jurisprudence/520132316/1?directHit=true&directHitQuery=SA%2FSZ%201731%2F98

Artykuł A well-aimed shot at American e-commerce. A practical guide to customs clearance of US shipments through the Polish Post. pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

The holiday season is in full swing, but our litigation team remains fully alert — and fully engaged. The best proof: ongoing preparations for proceedings before the General Court of the European Union in Luxembourg in one of the most complex categories of disputes — EU grant litigation.

What is the dispute about?

We represent a client — a beneficiary of a grant awarded under an EU framework programme — in a dispute with the European Innovation Council and SMEs Executive Agency (EISMEA). At the heart of the dispute lies the allegation of so-called technology abandonment (departure from the technology) — the EU agency’s claim that, in the course of the project, the beneficiary departed from the technology on which the funding decision was based, which, in the Agency’s view, justifies a demand for repayment of the funds.

This is one of the most difficult and most judgment-laden categories of allegations in grant disputes. The line between impermissible “abandonment” of a technology and the natural — indeed expected — evolution of a solution in a research and innovation project is fluid, and where that line is drawn determines the fate of the entire funding. Disputes of this kind require navigating simultaneously the grant agreement regime, European Union law and the technological specifics of the project.

A direct action before the EU General Court

The dispute will be brought before the General Court of the European Union by way of a direct action based on the arbitration clause contained in the grant agreement (Article 272 TFEU). As part of the preparations, our attorneys-at-law have set up individual representative accounts in e-Curia — the mandatory electronic filing system of the EU courts — and stand ready to represent the client at every stage of the proceedings in Luxembourg.

What does this mean for you?

If your company is implementing, or has implemented, an EU-funded project (Horizon 2020, Horizon Europe, EIC Accelerator and others) and you have received a letter from an EU institution questioning the implementation of the project, an audit notification, a debit note or a repayment demand — you are not without recourse. Decisions and demands of EU executive agencies are subject to review, and beneficiaries have real legal remedies at their disposal, including judicial proceedings before the EU General Court.

Our litigation team combines experience in civil and commercial disputes with hands-on knowledge of EU law, the EU grant regime and the procedure before the EU courts.

Feel free to reach out — holiday season included. We are not slowing down.

Artykuł Summer holidays? Not for our litigation team. We are preparing a dispute before the EU General Court pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

1. Reports only via e-Sanepid

Every dietary supplement introduced to the market for the first time must be reported to the Chief Sanitary Inspector (GIS). Until now, various forms were acceptable – paper or electronic, with a handwritten or electronic signature. After the amendment comes into effect, the only acceptable method will be the e-Sanepid platform.

What does this mean in practice?

• It is necessary for each person submitting notifications to have a qualified electronic signature or a trusted profile.
• All communication with sanitary inspection bodies – letters, decisions, and confirmations – will be handled through the platform account. The moment of notification submission will be clearly confirmed with an official receipt, eliminating disputes over the deadline.
• Companies that have previously used paper forms or traditional correspondence must immediately switch to the new channel and ensure appropriate employee training.

The change also concerns the timing of the notification obligation: the previous option to notify the Chief Sanitary Inspectorate (GIS) at the stage of intended product introduction is no longer available. The obligation now arises at the time of actual introduction to the market.

2. Strict deadlines and automatic presumption of irregularities

The amendment introduces a completely new mechanism for conducting investigations. This change has the greatest potential to surprise companies without effective internal compliance procedures.

How does the new mechanism work?

If the Chief Sanitary Inspectorate initiates an investigation and requests the entity to submit a scientific opinion, the company has exactly 14 days to submit an application to an accredited scientific unit – at the same time forwarding a copy of it to the Chief Sanitary Inspectorate.

The mechanism for presuming irregularities is a significant innovation. Previously, a company’s inaction during the proceedings did not automatically result in any legal consequences – the proceedings could drag on for years. Following the amendment, any failure to meet the 14-day deadline will lead to direct negative consequences, regardless of whether the product is safe.

3. Advertising without reporting? A fine of nearly one million zlotys

This change directly impacts brands engaging in active digital marketing. Previously, advertising or presenting a dietary supplement without prior notification to the Chief Sanitary Inspectorate (GIS) was punishable by a fine (a misdemeanor). Following the amendment, this becomes grounds for imposing an administrative fine – with new, significantly higher penalties.

What exactly is prohibited?

The amendment penalizes not only the sale of a supplement without reporting it to the Chief Sanitary Inspectorate (GIS), but also the mere advertising or presentation of it if the notification has not been effectively submitted. In other words:

• Sponsored post on Instagram or Facebook promoting a new supplement before notification = grounds for an administrative penalty.
• Product page in the online store visible to the public before successful reporting to GIS = risk of infringement.
• Promotional materials sent to wholesalers or distributors before GIS is notified = potential infringement.
• Influencer marketing initiated before the date of effective notification = liability on the part of the entity commissioning the campaign.

Prohibition on suggesting medicinal properties – wider scope

The amendment expands liability for violations of advertising requirements from labeling to the entire marketing message. Previously, sanctions primarily covered incorrect packaging labeling. Following the amendment, a company is responsible for every communication channel – online advertising, point-of-sale materials, newsletters, or YouTube videos – if the message suggests that a varied diet does not provide sufficient nutrients, or if a supplement is presented as a medicinal product.

4. Public register – the company’s reputation under public scrutiny

The Chief Sanitary Inspectorate (GIS) has maintained a register of dietary supplements before, but the amendment will significantly expand its scope and availability. The data will be published on the e-Sanepid platform and will include:

• the name of the product and its qualitative composition (without quantitative data – the recipe remains protected),
• product qualification proposed by the entity,
• information about the initiation or ongoing investigation,
• data on the detection of a prohibited ingredient.

5. Fines – increase by over 330%

The maximum administrative fine for violating food safety regulations is increasing from 30 to 100 times the average monthly salary. At the current salary level, this means:

The new penalties are imposed administratively (not as fiscal or misdemeanor offenses), which means faster proceedings and no need to prove intentional guilt. A mere finding of a violation is sufficient. The increased level of sanctions has a real deterrent effect, especially for companies with turnover in the tens of millions of zlotys.

The biggest risks – a practical overview

Artykuł CLIENT ALERT Dietary supplements market in Poland Amendments to food safety regulations | May 2026 pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

Publication date: July 07, 2026

– the first edition of a new nationwide event dedicated to the defence, security and resilience of the state

On June 19-20, 2026, representatives of our law firm will participate in the Warsaw Defense Trade Fair (WTO 2026), which will be held at the EXPO XXI Exhibition Center in Warsaw. This is the first edition of a completely new trade fair and conference event, created in response to the growing importance of the defense sector, national security, and technologies supporting Poland’s institutional, economic, and social resilience. The fair is held under the honorary patronage of the Ministry of Interior and Administration and the Minister of National Defense. The event is informally referred to as a “mini-MSPO in Warsaw” – a capital city-based, intimate alternative to the September International Defense Industry Fair in Kielce, open not only to professionals but also – on the second day – to the general public.

The goal of the Warsaw Defense Fair is to integrate key groups responsible for national security and to create a space for dialogue, collaboration, and exchange of experiences between public administration, the military, uniformed services, the defense industry, the technology sector, the investor community, and military universities. The event combines exhibition, conference, and networking elements , creating a platform for showcasing modern technologies, exchanging expert knowledge, and building business relationships in one of the fastest-growing sectors of the Polish economy.

The trade fair program is divided into two complementary days, representing one of the most distinctive solutions adopted by the organizers. Friday, June 19, 2026, will be an industry day (B2B/B2G), intended exclusively for companies, institutions, and business partners. Industry registration is required. This day will be a platform for meetings and discussions between individuals and entities interested in establishing cooperation in the defense and security sector, including representatives of public administration and local governments, soldiers and uniformed services, representatives of companies in the defense and technology sectors, investors, industry advisors, and representatives of military universities. The program focuses on key challenges facing the defense and national security sectors, including conferences, panel discussions, and business and institutional meetings concerning the development of the Polish defense industry, modernization of the Armed Forces, public procurement in the defense sector, and cross-sectoral cooperation.

Saturday, June 20, 2026, will be an open day (B2B/B2G/B2C), also open to the public interested in security, defense, and shooting. The second day significantly complements the industry portion and expands the event to include the general public, as well as educational and outreach communities. It will feature demonstrations of equipment and technologies in near-operational settings, demonstration zones by exhibitors and manufacturers, presentations of solutions in cybersecurity, drones, communications, and critical infrastructure protection, as well as numerous lectures for enthusiasts. Topics covered include firearms licenses – myths and legal realities, training and shooting sports, hearing and eye protection, safety and ergonomics at the shooting range, and civic preparedness for crisis situations.

Exhibitors and thematic scope

Over 100 exhibitors will be present at the fair, representing a full cross-section of entities active in the Polish defense and security sector. Exhibitors include military units such as the 1st Warsaw Armored Brigade and the 18th Capital Territorial Defense Brigade, international technology companies, including 3M Poland, which presents personal protection solutions for the defense sector, and Artec 3D with 3D scanners used in military applications. The shooting and equipment segment will be strongly represented, with companies such as House of Guns , Hubertus Pro Hunting , Kaliber, 4HUNTING, Kolba, 4SHOOTER, Son of Gun , Jammas , and Wolfer. Group and Works11. The event is also partnered by the Legia Warsaw Central Military Sports Club – Shooting Section.

The exhibition covers cutting-edge weapons, equipment, facilities and technologies used in the defense and security sector: unmanned systems and drones, cybersecurity solutions, tactical communications and communication technologies, critical infrastructure protection, personal protective equipment, 3D scanning and simulation technologies, individual soldier equipment, as well as solutions in the area of civil defense and population protection.

Three conference stages and a substantive agenda

The WTO 2026 program will unfold simultaneously across three conference stages. The industry day will be dedicated to the most important strategic challenges facing the defense sector – the technical modernization of the Polish Armed Forces, the development of the domestic arms industry, cooperation with foreign partners, public procurement in the defense sector, new dual-use technologies , and the role of the private sector in building national resilience. The second day, open to the public, will feature lectures and discussions covering a much broader range of topics – from legal issues concerning access to weapons and individual security, through shooting sports and defense training, to preparing society for crisis situations and disseminating knowledge about modern defense technologies.

The significance of the event from a legal perspective

The establishment of the Warsaw Defense Fair is part of the broader context of the dynamic development of the Polish defense sector, which in recent years has become one of the most important areas of public and private investment, generating significant demand for legal services. From the firm’s perspective, issues related to public procurement in the defense sector, regulations regarding trade in arms and dual-use technologies, export controls, protection of classified information, cybersecurity in the context of the NIS2 directive, intellectual property rights in defense technology projects, and financing of projects from European funds (including the European Defense Fund and ASAP), as well as the development of regulations regarding artificial intelligence in military applications in light of the European AI Act . The participation of representatives of the KG LEGAL KIEŁTYKA GŁADKOWSKI law firm in this event is a natural element of tracking the development of one of the fastest-growing sectors of the Polish economy and building competences in the area of law related to new defense technologies.

The Warsaw Defense Fair 2026 demonstrates that security and defense are no longer the exclusive domain of the military and state administration. They have become an area of broad cross-sectoral cooperation, with technology companies, investors, academia, non-governmental organizations, and informed citizens playing key roles. The development of this sector today requires not only advanced technological competencies but also an appropriate legal, regulatory, and institutional environment.

Link to the event: https://wto26.exposupport.pl/program

#WarsawDefenceExpo #WTO2026 #WarszawskieTargiObronne #DefenceIndustry #DefenseIndustry #DefenceExpo #DefenseExpo #PolishDefenceIndustry #PolishArmedForces #NationalSecurity #StateResilience #CivilDefence #HomelandSecurity #DefenceTechnology #DefenseTech #MilitaryTechnology #MilitaryInnovation #DualUseTechnology #DefenceProcurement #PublicProcurement #ArmsTrade #ExportControl #ClassifiedInformation #CyberSecurity #NIS2 #CriticalInfrastructure #InfrastructureProtection #UnmannedSystems #Drones #UAV #TacticalCommunications #PersonalProtectiveEquipment #3DScanning #AIinDefence #AIAct #ArtificialIntelligence #EuropeanDefenceFund #EDF #ASAP #IntellectualProperty #DefenceIP #TerritorialDefence #WOT #ArmedForces #MilitaryModernization #SportShooting #FirearmsLaw #WeaponsPermits #ShootingSports #RangeSafety #CrisisPreparedness #EmergencyPreparedness #Resilience #B2B #B2G #EXPOXXI #Warsaw #Warszawa #Poland #MONRP #MSWiA #MiniMSPO #DefenceConference #SecurityConference #LegalTech #LawFirm #KGLegal #KieltykaGladkowski

Artykuł Representatives of our law firm KG LEGAL KIEŁTYKA GŁADKOWSKI will take part in the Warsaw Defence Fair 2026 pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

On June 19, 2026, representatives of our law firm will participate in the Data Science Summit AI Edition 2026, which will be held at the Palace of Culture and Science in Warsaw. For many years, the event has been one of the most important technology conferences in Central and Eastern Europe, bringing together specialists responsible for the development and implementation of the most advanced solutions based on artificial intelligence, machine learning, and data analysis. It provides a meeting place for the business, technology, scientific, and administrative communities—a space where implementation practice meets regulatory and strategic reflection.

Link to the event: https://ml.dssconf.pl/#agenda

This year’s edition focuses on the most important directions of development of modern artificial intelligence, including, among others, generative AI ( Generative AI), large language models (LLM), GPT systems, AI agents, Agent-to-Agent (A2A) architectures, Context Model Protocol (MCP), reinforcement learning, computer vision, predictive analytics, MLOps, LLMOps, AI governance and broadly understood data-driven business transformation.

The conference is aimed at data scientists, AI experts, data engineers, IT system architects, programmers, cybersecurity specialists, digital transformation leaders, product development managers, public administration representatives, and executives of enterprises implementing AI-based solutions. Speakers will include representatives of global technology companies, international corporations, financial institutions, telecommunications operators, energy companies, research and development organizations, academia, and technology startups – including AI directors, chief system architects, digital transformation leaders, scientists, AI engineers, MLOps experts, cybersecurity specialists, and managers responsible for implementing technological innovations.

The event is distinguished by its practical nature. The program focuses not only on presenting technological innovations, but primarily on showcasing real-world implementations already in place in businesses, public administration, the financial and energy sectors, e-commerce, telecommunications, healthcare, and industry.

Enterprise AI – From Experiment to Infrastructure

One of the most important themes of the conference is the practical use of artificial intelligence in production environments. It is increasingly clear that AI has ceased to be an experimental technology and has become a component of real-world business infrastructure. In this context, we are analyzing ways to counteract the phenomenon of so-called information bubbles and build more sustainable recommendation systems used by the largest media platforms. Methods are emerging to increase the diversity of presented content, reduce algorithmic bias, and design systems that responsibly influence user behavior.

A key issue is the collaboration between classic machine learning and generative AI. Combining both approaches allows for the development of scalable, cost-effective solutions, ready for use by large organizations. A significant portion of the discussion also focuses on countering financial fraud – methods for detecting fraud and building competitive advantage through structured AI system development processes. Developer experience and modern work environments for AI teams are also gaining importance, including ways to accelerate the creation and maintenance of AI-based applications.

The technological landscape is strongly influenced by the prototyping of AI agents using modern programming environments and platforms supporting the creation of autonomous systems. Simultaneously, there are emerging themes regarding the use of AI in the legal sector – methods for assessing the reasoning ability of language models, methods for tracing legal sources, and techniques for increasing the reliability of AI-generated responses. From a security perspective, mechanisms for securing autonomous systems against attacks, unauthorized access, and attempts to manipulate their behavior are particularly important.

Equally important is the optimization of language models – techniques for quantization, distillation, and model size reduction while maintaining high efficiency. In the financial sector, solutions are emerging that include automated document processing, data extraction, and the development of intelligent analytical platforms. As an illustration of the creative potential of AI, the mechanisms behind music generation by artificial intelligence and the application of deep learning in creative processes are also discussed.

Generative AI – Multimodality, Agents, and Public Administration

Generative AI is one of the fastest-growing areas of contemporary technology. In production practice, it is used to automatically describe works of art, create alternative descriptions that increase the accessibility of digital documents for people with disabilities, and develop strategies for replacing very large and expensive language models with smaller, specialized solutions that can be effectively used in enterprises. The evolution of architectures leads from simple prompts, through RAG mechanisms, to multi-stage pipelines integrating multiple data sources and advanced LLM architectures.

Multimodality plays a significant role – solutions that can simultaneously analyze text, images, sound, and spatial information – opening the door to building more versatile AI systems. In enterprise environments where standard communication protocols aren’t feasible, building agents that exclusively utilize approved APIs, internal tools, and development platforms becomes crucial, while adhering to security and governance principles.

A crucial direction is the use of artificial intelligence in public administration, including the process of transforming an AI project into a product accessible to millions of citizens. Solutions that generate sound, speech, and music using modern diffusion models and transformers are also gaining importance, as are automatic analysis of PDF documents and the extraction of structured data from multi-page administrative materials. Hybrid pipelines combining generative AI, signal processing, and embedded systems for use in resource-constrained devices are also emerging. A separate, increasingly important issue is assessing the quality of RAG chatbots, testing them before deployment, and building reliable conversational systems.

Machine learning in practice – recommendations, energy, finance

Classic machine learning remains relevant – on the contrary, it’s finding applications in major industrial and financial implementations. Modern recommendation systems are emerging, based on data representation vectors and embedding architectures, where balancing recommendation effectiveness with the ability for users to discover new content is paramount. Digital twins are being used to optimize energy assets and manage industrial infrastructure. In the financial sector, teams of collaborative models are emerging to support decision-making processes.

The challenges associated with AI agents operating in social media are increasingly being discussed – issues such as user privacy, data security, and customer interaction design. In the banking sector, there’s a clear trend toward building millions of personalized models operating in parallel, which requires advanced training optimization, system scaling, and efficient processing of massive data sets.

Deployments, MLOps, and Security – The AI Systems Lifecycle

One of the most practical areas of the event is implementing, maintaining, and scaling AI systems in production environments. Simply developing a model is no longer the biggest challenge; ensuring its stable, secure, and effective operation in real-world business environments is crucial.

The security of generative AI is becoming one of the most pressing issues. Practical methods are emerging to protect models from prompts, injection, jailbreaking, and attempts to bypass control mechanisms. Referring to OWASP guidelines and modern solutions enabling the implementation of AI systems in accordance with the security- by-design principle is becoming standard.

From a legal perspective, issues related to designing global data platforms operating simultaneously in multiple jurisdictions are particularly important. These challenges include data sovereignty, local regulations, and the need to reconcile legal requirements across different jurisdictions.

A key theme is the full lifecycle of machine learning models – the processes of building, deploying, monitoring, updating, and retiring AI models, as well as how to manage their performance at scale. System performance optimization plays a significant role – techniques for reducing latency, shortening inference times, and adapting models to various hardware environments. Case studies from the pharmaceutical sector also appear, demonstrating how to manage chatbots’ deviance from their original purpose and how to minimize the risk of generating undesirable responses. Simultaneously, computer model optimization techniques are being developed, allowing to increase their efficiency many times while maintaining high quality of prediction.

Monitoring LLM systems and AI agents before end-user errors occur is becoming particularly important. Systems for model tracking, automated evaluation, anomaly detection, cost management, and continuous response quality improvement are emerging. Solutions are emerging that enable the management of thousands of AI agents and their evaluation at scale. This is complemented by approaches based on GitMLOps, DevSecOps, and modern observability solutions for systems based on large language models.

AI Agents – Autonomous Decision-Making Systems

One of the most important areas of the conference is AI agents. Modern artificial intelligence is increasingly moving beyond the role of a mere tool for human support and instead becoming an autonomous system capable of executing complex business processes. Methods are emerging for assessing the effectiveness of large-scale multi-agent systems – methods for automated testing, reliability testing, tracing error sources, and building systems that guarantee repeatable results. Significant attention is being paid to monitoring agents in real time, identifying errors, measuring response quality, and continuously improving decision-making processes.

Issues related to the security of AI agents are becoming increasingly important, including attack scenarios that confuse autonomous systems and methods for securing them against manipulation. Practical applications of agents utilizing financial, registry, and business data are emerging, supporting analytical, scoring, and decision-making processes. AI agents are also finding applications in telecommunications and in the construction of systems that independently conduct research and analysis.

Agents’ long-term memory plays a significant role – solutions utilizing knowledge graphs and mechanisms that enable agents to independently organize and expand their accumulated knowledge. Real-time voice agents are highly practical – systems capable of conducting telephone conversations with users, analyzing speech, and generating responses that approximate natural communication. Solutions are also emerging that enable automatic detection of problems arising during the operation of production agents and the generation of evaluation processes without human intervention. Applications also include systems supporting energy management, intelligent buildings, and Internet of Things devices. A separate, important area is the evaluation of Text -to-SQL systems, which enable the automatic conversion of natural language into database queries.

Development and tuning of large language models

A significant portion of the conference was devoted to the creation, training, and refinement of large-scale language models. The most common errors made when building AI models are increasingly understood, as is the significant impact that the proper selection of training data has on their quality. Specialized models for the banking sector are being developed, along with methods for adapting them to specific business applications.

A significant area of research is Polish multimodal models capable of simultaneously understanding text and images, including methods for building them with limited data resources. Techniques for simplifying official and administrative language using language models are also emerging, with a particular emphasis on increasing the accessibility of public transportation. Mechanisms for building trust in artificial intelligence by providing users with justifications for generated responses are gaining increasing importance. Embedding models, used to identify duplicate data, ambiguous names, and unstructured addresses, are becoming increasingly important in everyday business practice.

Business Transformation – Strategy, Data, and Organization

From a strategic perspective, artificial intelligence is becoming one of the most important elements in building a competitive advantage for enterprises. Practical experience is emerging with implementing generative AI in international organizations and managing technological transformation processes. Methods for identifying the most promising AI initiatives from among hundreds of potential projects are becoming increasingly important.

Data quality plays a significant role – proper data preparation is now a prerequisite for the effective implementation of artificial intelligence. Critical analysis of technological trends is also emerging, allowing us to separate the true capabilities of AI from marketing hype. The importance of data architecture and IT systems for the success of transformation projects is becoming increasingly clear. The debate on the future of management in the era of agent-based AI and the changes AI will bring to corporate organizational structures is particularly prominent. Examples of building scalable customer service agents operating simultaneously in multiple countries are also emerging, as are the experiences of large organizations implementing AI, developing data products, supporting business expansion, and transforming the banking sector.

AI in Software Development – Regulation, Security, and Intellectual Property

Artificial intelligence is fundamentally changing the way technology teams work. Building local systems to support programming in compliance with European regulations, including the AI Act and NIS2, is becoming increasingly important. Both the potential and limitations of modern programming assistants are emerging, including the reasons for the failure of AI agents working with enterprise data and ways to build more predictable systems.

Cybersecurity, threat modeling, and vulnerability management in AI-based systems are all important topics, as are the practical aspects of building agent platforms capable of operating in production environments. From a legal perspective, issues related to intellectual property protection, commercialization of AI-based solutions, copyright management, and building secure technological product development processes are particularly important.

Computer Vision – intelligent image analysis

Modern image analysis goes far beyond classical object recognition. New approaches are emerging to using visual models in unusual applications, including Visual RAG systems that enable automated processing of data contained in spreadsheets and corporate documents. The technological trade-offs involved in designing high-performance pipelines are increasingly understood. computer vision. Computer vision is also used in climate forecasting and analysis of environmental phenomena, as well as in automatic data extraction from Polish administrative and business documents.

Debates about the future of artificial intelligence

An integral part of the event are expert roundtable discussions. The role of software agents is discussed – whether they will become merely a tool to support specialists or will they take over some of their responsibilities. The use of AI agents as digital equivalents of junior engineers supporting data science teams is also discussed. Experts engage in debates on the labeling of AI-generated content and the transparency of AI systems.

A separate discussion is devoted to Europe’s technological sovereignty and the possibility of building an independent artificial intelligence ecosystem. The discussion concludes with a discussion on the competencies of the future and the skills that will become crucial for organizations to function in an AI-based economy.

The Data Science Summit AI Edition 2026 demonstrates that artificial intelligence is no longer just a technology of the future. It has become one of the most important tools shaping modern businesses, public administration, and the financial, energy, industrial, and technology sectors. The scale and scope of the topics covered confirm that AI development today requires not only advanced technological competencies but also appropriate risk management, security, regulatory compliance, and a responsible approach to implementing new technologies – making law firms’ participation in such events a natural part of tracking the directions in which new technologies law is heading.

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Artykuł Representatives of our law firm KG LEGAL KIEŁTYKA GŁADKOWSKI will take part in the Data Science Summit AI Edition 2026 – one of the largest events dedicated to artificial intelligence in Central and Eastern Europe pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.

The CE marking was introduced as part of the harmonization of product marking processes within the EU. It is intended to replace all existing conformity markings. The marking itself indicates that the product meets the requirements of the applicable regulations. It is affixed to products intended for introduction into the EEA and Turkish markets, regardless of where they were manufactured.

Main regulations

The main acts that regulate the CE marking of products and the conformity testing that must accompany this process are: Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products and repealing Regulation (EEC) No 339/93 (consolidated text: OJ L 218, 2008, p. 30, as amended) as well as Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common framework for the marketing of products, and repealing Council Decision 93/465/EEC (consolidated text: OJ L 218, 2008, p. 82).

CE marking

Although the mark is generally believed to be an abbreviation of the French expression “Conformité Européenne”, no EU legal act provides such an expansion of this abbreviation.

The appearance and method of affixing the CE marking are specified in Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 and Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008, stating that it consists of the initials “CE” presented in the form specified in the regulation. Unless other regulations specify a different height, it shall be at least 5 mm. In all cases, the proportions of the mark must be maintained. It must be affixed so that it is visible, legible, and indelible from the product. The CE marking is followed by the identification number of the notified body, if it was involved in the production control phase. If the CE marking cannot be affixed to the product, it should be affixed to the packaging or accompanying documentation.

Declaration of Conformity

Union harmonisation legislation requires the manufacturer to draw up and sign an EU declaration of conformity before placing the product on the market.

The manufacturer or its authorized representative established within the EU is required to draw up and sign an EU declaration of conformity as part of the conformity assessment procedure provided for in Union harmonisation legislation. The EU declaration of conformity is a document stating that the product complies with all relevant requirements of the applicable legislation.

By drawing up and signing the EU declaration of conformity, the manufacturer takes responsibility for the product’s compliance with the regulations.

The EU declaration of conformity must be continuously updated and kept for ten years from the date the product is placed on the market, unless a different period is specified by law.

According to the model declaration in Decision No 768/2008/EC of 9 July 2008, the declaration should include:

1. unique product identifier,

2. name and address of the manufacturer or authorized representative issuing the declaration,

3. a statement that the declaration is issued under the sole responsibility of the manufacturer,

4. Subject of the declaration (product identifier enabling the reconstruction of its history. Where appropriate, it may include a photo),

5. all relevant provisions of Union harmonisation legislation that the product must comply with, referenced standards or other technical specifications (such as national standards and technical specifications) in a precise, complete and clearly defined manner,

6. Where applicable, name and number of the notified body that issued the certificate,

7. Additional information,

8. Date of issue of the declaration, signature and position or equivalent designation of the authorized person,

Modules

The mark itself is intended to indicate that the product meets the requirements specified in the law. The product is marked with it by the manufacturer, either independently or with the participation of a national authority (conformity assessment body, notified body). For this purpose, the manufacturer assesses conformity using modules (described in the Commission Notice Blue Guide – Implementation of EU product regulations 2022 (i.e. OJ EU C. of 2022 No. 247, p. 1) and Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008). The modules refer to both the design and production phases. Conformity assessments can be performed using one or two modules. Assessment modules can refer to one of the phases (e.g. only to the production phase), or to both. If a module refers to only one phase, the assessment consists of two modules, while if it refers to both phases, the assessment consists of one.

There are eight modules in total, but with the addition of variants, their number increases to 16 (A, A1, A2, B, C, C1, C2, D, D1, E, E1, F, F1, G, H, H1). Each subsequent module contains further requirements, along with increasing risks posed by the product. In the “least demanding” module, A, the manufacturer only prepares technical documentation and takes all necessary measures to ensure the production process ensures compliance of manufactured products with the technical documentation, and then affixes the marking to the product. In the highest module, H1, the manufacturer must have an approved quality assurance system (approved by a notified body) for design, production, and inspection and testing of finished products. It is also subject to supervision by a notified body. The notified body may also pay unannounced visits to the manufacturer, during which it may conduct or commission product tests.

Entities involved in conformity assessment

At the outset, it is worth noting that regardless of whether a notified body is involved in the conformity assessment procedure or not, the conformity assessment is the manufacturer’s responsibility, and the declaration of conformity is made under his sole responsibility.

There are three possibilities for the involvement of other entities in the conformity assessment procedure:

– No involvement of external entities. In such a case (and this usually applies to products that the legislator has deemed not to pose such a risk that the manufacturer cannot be entrusted with the independent conformity assessment), the manufacturer prepares the declaration itself (along with the appropriate tests and technical documentation), and conducts the tests, inspections, and guarantees compliance during production.

– Conformity assessment is carried out using an accredited in-house body, i.e., a part of the manufacturer. However, this body cannot perform any tasks other than conformity assessment. It must be independent of commercial, design, and manufacturing entities and must possess the same level of technical competence and impartiality as external assessment bodies. They may conduct assessments within the scope of modules A1, A2, C1, or C2.

– Conducting the assessment with the involvement of an external entity. If the legislator deems such intervention necessary, an external conformity assessment body will participate in the conformity assessment. This body must be impartial and fully independent of the organization or the product it assesses. It must not engage in any activities that might compromise its independence, and it must not have user or other interests in the product being assessed.

Member States are responsible for designating conformity assessment bodies. They must designate bodies (within their jurisdiction) that have the appropriate competence to assess product conformity.

Even though in-house bodies cannot be notified (i.e. they cannot be external conformity assessment bodies), they must demonstrate at least the same level of technical competence as external bodies through accreditation.

Notified bodies

Conformity assessment bodies (referred to as notified bodies in EU legislation) are entities designated by Member States. Appointed notified bodies must then be notified to the European Commission.

They play roles in the conformity assessment process, responsible for activities such as calibration, testing, certification, and inspection. To qualify as a notified body, a body must be a legal entity established in a Member State, but it may operate or employ personnel outside a Member State or even outside the EU.

The bodies must be accredited, which means that the relevant national accreditation body must confirm that the conformity assessment body meets the requirements set by the harmonised standards and any additional requirements for carrying out specific conformity assessment tasks.

Member States may designate a maximum of one national accreditation body. However, they may choose not to designate such a body and instead have accreditation performed in their territory by an accreditation body from another Member State. In both cases (designation or non-designation), Member States are required to notify the European Commission.

Notified bodies are subject to oversight by national notifying authorities and must keep them informed about their activities (including, for example, availability of resources, performance of conformity assessments, subcontracting of work, and conflicts of interest). They must provide, directly or through another body (e.g., a national accreditation body), all information concerning the proper implementation of the conditions under which they were notified, upon request, both to their notifying authorities and to the Commission.

The notifying authority is responsible for the activities of notified bodies. It must remain capable of ensuring monitoring. If such monitoring is not possible, the notifying authority must withdraw or limit the scope of the notification to the extent necessary.

It’s also worth mentioning that the independence requirement (which also means that notified bodies “are and must remain” third parties independent of their clients) does not mean that only state bodies can become notified bodies. On the contrary, both state and private entities can apply for this status, provided their independence, impartiality, and reliability are guaranteed, and they constitute independent legal entities with appropriate rights and obligations.

Product labeling requirement

The CE marking is not required for every product, only for those for which legislation requires it. Currently, these include toys, electrical products, machinery, personal protective equipment, and cranes. It is prohibited to affix the CE marking to products that are not covered by the CE marking regulations.

Changes in the law

There have been no significant recent changes to the legislation governing the CE marking. However, sector-specific regulations necessarily influence the use of the mark. Such as Regulation (EU) 2024/2847 of the European Parliament and of the Council of 23 October 2024 on horizontal cybersecurity requirements for products with digital elements and amending Regulations (EU) No 168/2013 and (EU) 2019/1020 and Directive (EU) 2020/1828 (Cyber Resilience Act) (OJ EU L 2024, item 2847, as amended) or Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC (OJ EU L 2025, item item 40) and acts requiring CE marking of products such as Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act) Text with EEA relevance (OJ L 1689, 2024).

In its Annex I, Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 lists Union harmonisation legislation.

In summary, the purpose of the CE marking is to signal that a product meets the requirements of the applicable regulations. It is affixed to the product by the manufacturer, either independently or with the involvement of accredited internal bodies or a notified body, following the conformity assessment module(s) appropriate for the level of risk posed by the product, and under their own responsibility.

CE Marking – what really stands behind those two letters?

CE marking is more than just a symbol on a product – it’s a legal declaration that the product complies with all applicable EU requirements and can be placed on the EEA and Turkish markets, regardless of where it was manufactured.

It is the result of a structured conformity assessment process defined in EU harmonisation legislation (including Regulation (EC) No 765/2008 and Decision No 768/2008/EC). Depending on the level of risk, this process may involve the manufacturer alone, internal accredited bodies, or independent notified bodies.

By affixing the CE mark, the manufacturer takes full responsibility for product compliance. In parallel, an EU Declaration of Conformity must be issued, maintained, and kept up to date, confirming that all relevant legal requirements have been met.

The system is built on risk-based modules – from basic self-assessment to highly controlled certification schemes involving external oversight. This ensures proportional control while maintaining product safety and market access across the EU.

In short: CE marking is not a quality label – it is a regulatory passport for products entering the European market.

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Artykuł CE marking pochodzi z serwisu KIELTYKA GLADKOWSKI LEGAL | CROSS BORDER POLISH LAW FIRM RANKED IN THE LEGAL 500 EMEA SINCE 2019.