27 January 2026
Product regulation and compliance update series
January 2026Draft resolution of the Council of Ministers on the adoption of the Regulatory programme for 2026-2028
On 13 January 2026, a draft resolution of the Council of Ministers on the adoption of the Regulatory programme for 2026-2028 was published in the list of legislative and programme work of the Council of Ministers.
Context
The document aims to reduce administrative burdens, improve the functioning of the law, and ensure greater transparency of the legislative process. It takes into account the results of a review of existing legislation and aligns with the OECD's recommendations on regulatory policy.
Key principles
The Regulatory programme includes measures in two main areas:
- reducing administrative burdens, including further deregulation measures, promoting the principle of balancing administrative obligations, counteracting implementation that increases regulatory burdens (so-called "gold-plating"), and reducing burdens by applying the "digital by default" principle.
- an evaluation system, which is aimed, among other things, at improving the review of the functioning of normative acts, assessing the impact of EU projects, and developing so-called "regulatory sandboxes".
An important part of the Regulatory programme is also the digitisation of the regulatory process and public services. The implementation of new tools is planned, such as:
- a virtual AI assistant in the mObywatel application,
- the Electronic Register of Non-standard Transport Notifications,
- the Energy Efficiency Platform.
The Regulatory programme also provides for the development of ICT systems to monitor legislation and the functioning of the law, particularly in the area of economic lawmaking.
Next steps
The planned date for the adoption of the draft by the Council of Ministers is the first quarter of 2026.
Bill amending the Act on the Handling of Complaints by Financial Market Entities, on the Financial Ombudsman, and on the Financial Education Fund, and certain other acts
On 13 January 2026, a bill amending the Act on the Handling of Complaints by Financial Market Entities, on the Financial Ombudsman, and on the Financial Education Fund and certain other acts was published in the list of legislative and programme work of the Council of Ministers.
Context
The proposed amendments aim to adapt the regulations to the dynamically changing financial market and strengthen the protection of customers using financial services. The proposed solutions are intended to ensure a higher standard of consumer protection and to improve the performance of the Ombudsman's tasks.
Key principles
- broadening the scope of customers and financial market entities - the bill provides for the inclusion of a broader category of customers and entities providing financial services in the Act, which is intended to increase the level of protection for recipients of financial services;
- enabling the Financial Ombudsman to publish announcements, warnings and other information in the public media free of charge - this solution is intended to inform customers more quickly and effectively about the risks associated with the functioning of the financial market;
- changes in out-of-court proceedings in disputes between customers and financial market entities -the bill provides for a modification of the procedures conducted by the Financial Ombudsman, which is intended to increase the effectiveness and accessibility of out-of-court dispute resolution.
Next steps
According to the legislative work schedule, the bill is expected to be adopted by the Council of Ministers in the second quarter of 2026.
New EU rules on chemical safety assessments entered into force on 1 January 2026
On 1 January 2026, legislation establishing a new, harmonised system for chemical safety assessments in the European Union, known as the 'one substance, one assessment' (OSOA) package, entered into force.
Context
The new OSOA package implements the objectives of the Chemicals Strategy for Sustainability, which is part of the European Green Deal. This change introduces a more consistent system for assessing substances and enables a faster regulatory response when new risks are identified.
Key principles
- facilitating the reuse of chemical data and harmonising risk assessments through a new EU-wide chemical data platform, which is expected to become operational within the next three years;
- increasing the consistency and transparency of risk assessments by assigning scientific tasks to agencies with the relevant expertise and tools;
- introducing a system for monitoring and forecasting chemical risks, based on data analysis, indicators and early warning tools, to enable earlier detection of problems and faster regulatory action;
- making data available to a wide range of users, including public authorities, businesses and citizens, to support better decision-making and increase transparency.
The new system is intended to lead to a situation where each substance is assessed once, and the result of the assessment is then used throughout the European legal system.
Next steps
The package consists of three legal acts:
- Regulation (EU) 2025/2455 of the European Parliament and of the Council of 26 November 2025 establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook framework for chemicals;
- Regulation (EU) 2025/2457 of the European Parliament and of the Council of 26 November 2025 amending Regulations (EC) No 178/2002, (EC) No 401/2009, (EU) 2017/745 and (EU) 2019/1021 as regards the reattribution of scientific and technical tasks and improving cooperation among Union agencies in the area of chemicals;
- Directive (EU) 2025/2456 of the European Parliament and of the Council of 26 November 2025 amending Directive 2011/65/EU as regards the reattribution of scientific and technical tasks to the European Chemicals Agency.
Work on the full implementation of the data platform and monitoring tools will continue in the coming years.
New system for supervising general product safety
On 3 January 2026, the Act on the Supervision of General Product Safety of 7 November 2025 came into force, replacing the Act on General Product Safety of 2003.
Context
The new regulation introduces into the Polish legal system the enforcement mechanism for Regulation (EU) 2023/988 (the GPSR) and establishes a strengthened framework for the supervision of consumer product safety. The Polish Act on the Supervision of General Product Safety serves an executive function: it defines the competence of authorities, the rules governing inspections, the course of administrative proceedings, and the catalogue of administrative sanctions.
Key principles
- strengthening the role of the President of the Office of Competition and Consumer Protection (UOKiK) as the central coordinator of the system, the national Safety Gate contact point, and the authority responsible for conducting proceedings concerning general product safety, including those involving online platform providers;
- extending the powers of the Trade Inspection Authority, including the introduction of remote inspections, mystery shopping, the ability to request technical documentation, and access to the embedded software of a product;
- increasing administrative sanctions, including penalties of up to PLN1 million for placing on the market a product that does not comply with the general safety requirement;
- expanding the scope of responsible entities -responsibility applies not only to manufacturers and importers, but also to providers of online platforms and information society services.
Next steps
The new Act introduces detailed intertemporal provisions:
- products placed on the market before 13 December 2024 may continue to be made available, provided they comply with the requirements of the previous Act on General Product Safety;
- previous legislation applies to proceedings and inspections initiated prior to the entry into force of the new Act on the Supervision of General Product Safety.
E-commerce: results of EU product compliance checks - conclusions from Priority Control Area (PCA) 2025
On 7 January 2026, the results of an inspection carried out by customs authorities were published on the European Commission's website. The inspection was carried out between April and June 2025 as part of the EU's coordinated PCA (Priority Control Area) inspection operation, aimed at assessing the compliance of products imported into the EU through e-commerce.
Context
The initiative involved 27 customs administrations and 108 market supervision authorities, which carried out increased inspection activities on products coming directly to consumers from third countries. The aim of the operation was to increase the safety of products available on the EU market and to reduce the inflow of products that do not meet EU requirements.
The PCA inspections focused on toys and small electronic products, i.e. goods most frequently ordered online and at the same time carrying the highest risk of non-compliance. Member State authorities focused their activities on the four largest sales platforms, which account for over 90% of low-value shipments imported from outside the EU.
Inspection results
- with EU law, in particular with regard to labelling, warnings, technical documentation and instructions for safe use;
- in 84% of cases, the products tested in laboratories were found to be unsafe, with risks such as choking, electric shock, the presence of dangerous chemicals and suffocation identified;
- many products did not contain the required elements that EU businesses must provide in order to place a product on the market, which means that consumers buying goods from outside the EU receive products with a significantly
- the rapid growth in the number of e-commerce shipments is outpacing the pace of effective control mechanisms, indicating a need to further strengthen the import supervision system.
Next steps
The PCA operation provided EU Member States and EU institutions with data confirming the need to intensify cross-border controls and to strengthen cooperation between customs authorities and market supervision institutions. The planned actions include:
- further increasing the inspection capacities of customs authorities;
- developing joint analytical tools and databases on dangerous products;
- intensifying cooperation with e-commerce platforms;
- implementing more advanced methods for selecting consignments for inspection.
The European Commission announced that the PCA results will be used in the continued legislative and operational work concerning product safety in e-commerce.
January reports from the Trade Inspection Authority
Below we present information on the Trade Inspection Authority (IH) reports published last month on the website of the Office of Competition and Consumer Protection (UOKiK).
Solid fuel boilers
The UOKiK website published the results of an IH inspection of solid fuel boilers with a capacity of up to 500 kW. The inspection was carried out from June to October 2025 by provincial IH inspectorates in Bydgoszcz, Kielce, Warsaw and Poznan. Ten models of boilers available in retail and wholesale trade were inspected, including nine manufactured in Poland and one imported from Turkey.
Results of the inspection:
- two of the ten models were found to have irregularities in the form of an incorrectly drawn up declaration of conformity, which means that there is no confirmation that the product meets the eco-design requirements;
- all 10 models were subjected to laboratory tests, which found no non-compliance - the seasonal energy efficiency and levels of dust, carbon monoxide and nitrogen oxide emissions were confirmed to be in line with the manufacturers' declarations.
As a result, the Trade Inspection imposed an obligation on the enterprises in question to take corrective measures in relation to two models. The corrective measures have already been completed for one model.
Recreational services
The UOKiK website published the results of an IH inspection concerning the safety of recreational services provided by businesses operating, among other things, playrooms, rope parks, climbing walls and trampoline parks. The inspection was carried out in 2025 by provincial IH inspectorates throughout Poland. A total of 263 businesses were inspected, including facilities located in shopping centres.
Results of the inspection:
Irregularities were found in 106 of the 263 businesses (40.3%), of which 60 establishments (22.8%) posed a threat to user safety, including:
- unprotected sharp edges, sockets, cables and protruding structural elements;
- loose elements (springs, straps, slats) that could lead to entanglement or injury;
- mechanical damage (foam loss, fabric tears, broken covers);
- lack of fall cushioning zones and slippery or unstable platforms;
- and in numerous cases, damage to technical components, improper fastenings and wear and tear of the structure resulting from intensive use or weather conditions were found.
Consequences of the inspection:
- 24 administrative decisions were issued, imposing penalties totalling PLN35,300 concerning the displaying of prices;
- nine post-inspection statements and seven organisational requests were issued;
- four penalty notices (totalling PLN600) were issued for errors in CEIDG/KRS data and four warnings were issued;
- the businesses found to have committed irregularities were obliged to remedy them.
The inspection found that:
- three out of thirty models had formal irregularities, including incorrectly drawn up declarations of conformity (one smartwatch and one headphone model) and a lack of CE marking (in two headphone models);
- two headphones models did not have product identification information, which makes it difficult for consumers to pursue claims and for inspection authorities to identify the product;
- laboratory tests found that four models of headphones exceeded the permissible lead content (above 1500 mg/kg, where the norm is 1000 mg/kg), which constitutes a serious violation of the regulations on the restriction of hazardous substances.
As a result of the inspection, IH will submit four requests to the President of UOKiK to initiate administrative proceedings, and the products in question will be withdrawn from sale. In one case where formal non-compliance was found, the manufacturer has taken corrective action.
Exercise benches
The UOKiK website published the results of an IH inspection concerning the labelling and safety of exercise benches. The inspection was carried out from July to September 2025 by provincial IH inspectorates in Biairystok, Gdansk, Kielce, Opole, Rzeszow and Szczecin. Nine models of exercise benches available in retail and wholesale outlets were inspected.
The inspection found that:
- there were irregularities in labelling, including missing or incomplete manufacturer's details, incomplete instructions for use and maintenance, missing or incorrect warnings, and instructions available only in a foreign language;
- five out of nine models had structural defects, including loss of bench stability during exercise, unstable barbell supports resulting from defective holder construction, and the presence of areas posing a risk of hand entrapment;
As a result of the inspection:
- in the case of five products with structural defects, IH submitted requests to the President of UOKiK to initiate administrative proceedings;
- in the case of four products questioned solely on the basis of their labelling, they were allowed to undergo corrective measures under the supervision of IH.