Handling Customer Complaints in Poland: A Practical System for Growing Businesses

Handling Customer Complaints in Poland: A Practical System for Growing Businesses

How many complaints did your business handle last month under a clear procedure—and how many depended on an employee improvising a solution?

If you do not know, your complaints process may no longer be keeping pace with your sales. The costs rarely appear in one report: staff time, delayed decisions, inconsistent answers, disputes, and customers who do not return.

The estimated operating cost of one return in Polish e-commerce is PLN 42.96. At 276 returns a month, that is nearly PLN 12,000 a month, before managers’ time, escalations, disputes, and lost customers. A structured complaints system can reduce costs by approximately 30% and handling times by approximately 40%.

This article explains the Polish rules your team needs to distinguish and sets out a practical way to build a process that works across online stores, marketplaces, and direct business sales.

Start by Classifying the Complaint Correctly

In Poland, a complaint about goods may involve different legal routes. Your team should identify the customer, the transaction date, and the basis of the complaint before choosing a response.

Misclassification affects the remedies you offer, the deadlines you track, and the terms you can rely on.

What Changed for Consumer Sales in 2023

The Act of November 4, 2022 (Journal of Laws of 2022, item 2337), which implemented the EU Sale of Goods Directive 2019/771, has applied since January 1, 2023. Many businesses still have forms or terms that do not reflect the change.

The rules your team needs to apply

1. Non-conformity replaced the former consumer-sales defect framework. The Civil Code provisions on rękojmia no longer govern B2C sales under the new regime. Articles 43a–43g of the Consumer Rights Act address non-conformity of goods with the contract. This covers more than a defective product: installation, instructions, stated characteristics, and durability may also matter.

2. The presumption now runs for two years. Previously, the presumption that a lack of conformity existed at delivery applied for six months. It now applies for two years, with the burden of proof on the seller.

3. The response deadline is 14 calendar days. The source’s stated change is from a previous 30-day period to 14 calendar days from receipt of the complaint. Missing the deadline results in the complaint being deemed accepted by operation of law.

4. Consumer remedies follow a sequence. The consumer first seeks repair or replacement. A price reduction or withdrawal from the contract becomes available if, for example, the seller refuses, fails to act within a reasonable time, or the non-conformity continues despite attempts to remedy it. Where the non-conformity is material, the consumer may seek a price reduction or withdraw immediately.

5. Goods with digital elements require updates. The seller must provide updates, including security updates, for at least two years after delivery. Failure to provide them may amount to non-conformity.

6. The consumer bears no complaint-related costs. Transport, labor, and materials fall to the seller, as do removal and reinstallation.

Check the purchase date

According to the transitional distinction in the approved source, goods purchased before January 1, 2023 remain subject to the former Civil Code rękojmia rules, while goods purchased from January 1, 2023 fall under the new consumer non-conformity regime. A team handling complaints from both periods must be able to select the right route.

Review your online-store terms and complaints policy. If they still describe consumer claims as rękojmia claims, state a 30-day response period, or omit the sequence of remedies, they may contain unfair terms and create a risk of action by UOKiK, Poland’s consumer protection and competition authority.

The Operating Cost of an Unstructured Process

A return is not necessarily a legal complaint, but returns show how quickly repeated handling costs can accumulate. The industry estimate used here is PLN 42.96 per return, covering customer service, transport in both directions, receipt, storage, and preparation for resale. At 276 returns each month, that approaches PLN 142,000 a year. Return rates in fashion and footwear reach 30–40%.

The source also reports that 70% of Polish online shoppers used the option to return goods in the preceding year and 46% did so more than once. It states that one in two Poles files a complaint an average of five times a year, most commonly concerning electronics (43%) and clothing or footwear (approximately 40%).

The larger cost is often dispersed across the business:

For a business with revenue of PLN 10–100 million, the source estimates that a disorganized process can produce hidden annual losses of hundreds of thousands of zlotys. It states that an integrated system can reduce costs by approximately 30%, shorten handling times by approximately 40%, and increase net promoter score (NPS) by 25 points.

The 14-Day Deadline Needs an Owner and an Alert

Article 7a of the Consumer Rights Act gives a seller 14 calendar days to respond to a consumer complaint. The approved source describes a missed deadline as causing the complaint to be deemed accepted by operation of law. It also identifies decisions that bear on how that consequence is treated:

• Supreme Court resolution III CZP 113/17, June 13, 2018: missing the 14-day deadline creates at least a rebuttable presumption that the complaint was accepted. The business then bears the burden of showing that the complaint was unfounded.
• Supreme Court judgment IV CSK 75/12: confirmed the concept of deemed acceptance where there is no timely response.
• Regional Court in Łódź judgment III Ca 2311/19: treated the failure to respond on time as a declaration of intent by the business that interrupts the limitation period for the consumer’s claim under Article 123 §1 point 2 of the Civil Code.
• District Court judgment I C 619/19: stated that, where inspection is required, the 14-day period starts when the goods are delivered to the seller, rather than when the complaint is first reported.

Do not leave deadline calculation to memory or assume that acknowledging receipt is the substantive response. Even a complaint your team considers clearly unfounded can become costly to contest after a missed deadline.

At minimum, configure an alert three days before the applicable deadline and give someone authority to escalate an unresolved case. If inspection or a technical opinion is needed, make the timing and responsibility visible in the case record.

UOKiK Risk Extends Beyond the Complaints Form

In 2024, UOKiK issued more than 750 decisions and imposed penalties totaling more than PLN 937 million, according to the figures in the source. Almost PLN 263 million related to infringements of collective consumer interests and unfair terms. The source also reports 41 proceedings initiated, 70 decisions issued, and more than 14,500 inspections by the Trade Inspection Authority.

The cited matters illustrate different risks; they should not all be read as decisions about the same type of complaint clause.

Terms and practices to check include:

1. Excluding or limiting seller liability for defects, delays, or damage in transit.
2. Allowing unilateral changes to terms without a valid reason.
3. Altering statutory deadlines or imposing extra formalities, such as requiring a damage report completed with a courier.
4. Referring customers to a third party without explaining the seller’s own responsibility.
5. Failing to make clear who the seller is on a marketplace.
6. Using dark patterns—interface designs that make submitting a complaint difficult. The source states that UOKiK examined 642 websites and found at least one dark pattern on more than 75% of them.
7. Requiring a receipt as the only proof of purchase. UOKiK indicates that a bank statement, card-payment confirmation, or order-confirmation email may also serve as proof.

A penalty for infringing collective consumer interests can reach 10% of the previous year’s turnover. The source also identifies a potential penalty of up to PLN 2 million for management personnel.

Marketplace Sales: Separate the Seller’s Duty From the Platform’s

A sale through Allegro, Amazon, or another marketplace involves at least two relationships:

1. The sales contract is between the customer and the seller. That seller is responsible for non-conformity of the goods, even though the transaction took place on a platform.
2. The electronic-services contract is between the customer and the platform. The platform is responsible for its own intermediary services.

If the platform is itself identified as the seller—for example, “sold by Amazon” or “sold by Allegro”—the goods complaint is addressed to the platform in that seller capacity.

The Digital Services Act (DSA), applicable since February 17, 2024, adds marketplace-platform obligations identified in the source: trader traceability and seller verification, informing consumers about purchases of illegal products, restrictions on dark patterns, and an easily accessible, free, timely internal complaint-handling system supervised by qualified staff under Article 20 DSA.

The Omnibus Directive requires clear information about whether a marketplace seller is a business or a private individual. That status affects the scope of consumer protection, including withdrawal rights and claims based on non-conformity of goods with the contract.

If your business is the marketplace seller, the platform’s procedures do not replace your own process for complaints about the goods. Your staff still need to identify and answer those claims under the applicable Polish rules.

Build the Process in Seven Steps

The sequence below starts with immediate controls and moves toward documentation, ownership, and training.

1. Audit What Actually Happens

Map how a complaint travels through every channel you use: your online store, direct B2B sales, marketplaces, and distributors. Compare practice with your written terms and internal instructions.

Check whether:

• Staff can identify the customer category and applicable legal regime at intake.
• The complaints policy reflects the post-January 1, 2023 rules.
• B2C forms incorrectly refer to rękojmia.
• Your ticketing system tracks the 14-day response deadline.
• Each stage has a named person or department responsible for it.

2. Separate Consumer and B2B Routes

The distinction belongs in forms, workflows, response templates, and training—not only in a legal memo.

Build a separate intake check for an entrepreneur with consumer rights. A customer’s business status alone should not end the classification exercise.

3. Update the Documents Staff Use

Review:

• Website terms and the complaints policy for the consumer non-conformity regime.
• The commercial guarantee policy, keeping it distinct from statutory complaints.
• Separate B2C and B2B complaint forms.
• At least 8–10 response scenarios, including acceptance, refusal, repair or replacement, price reduction, and referral to a guarantor, with B2C and B2B versions where needed.
• General Terms of Sale (GTS) for B2B customers, especially rękojmia and guarantee provisions.

A voluntary guarantee must not become the team’s default answer to a claim the customer has made against the seller under the non-conformity rules.

4. Give the Team a One-Page Decision Matrix

The matrix should answer six questions:

1. Who is the customer? Consumer, business, or entrepreneur with consumer rights?
2. Where was the sale made? Online store, marketplace, direct B2B channel, or distributor?
3. What is complained about? The product, transport, installation, or instructions?
4. Who decides? Customer service, quality, logistics, or legal?
5. When is the response due? The consumer deadline or the applicable B2B contractual deadline?
6. Which outcomes are available? Repair, replacement, price reduction, refusal, or an appropriate referral?

An approach familiar from IT service-level agreements can help: categorize cases and specify who responds and who resolves them. Acknowledgment time—confirming that a complaint has arrived—is not the same as decision time. Document both without confusing an internal service target with the legal response deadline.

5. Monitor Every Deadline

Configure your CRM or ticketing system to provide:

1. Automatic acknowledgment showing the receipt date and case number.
2. An alert on day 11 after receipt of a B2C complaint—three days before the stated deadline.
3. Escalation to a manager on day 13 if the case remains undecided.
4. A weekly report of open complaints and their status.

Make the case owner responsible for checking whether the facts of a particular complaint affect the deadline, including the inspection issue described in the cited District Court judgment.

6. Define Responsibility Across the Supply Chain

Where carriers, distributors, installers, or service subcontractors are involved, customers should not have to navigate your internal allocation of responsibility. The source’s position is that the seller answers to the consumer, including where transport or installation was performed by another party.

Internally, establish:

• A clear division of work between customer service, logistics, sales, and service teams.
• Recourse clauses in partner contracts so you can seek to recover complaint costs caused by a partner.
• A named case owner at each stage.

A staged escalation route can keep routine disputes at the operational level, move harder ones to management, and involve legal counsel after the internal route has been used. Clear ownership also reduces the number of cases that reach senior management unnecessarily.

7. Train With Cases, Not Just Legal Definitions

Use short workshops built around situations employees will face:

• A customer reports faulty installation: who owns the response, what should the customer be told, and who investigates?
• An employee says, “The commercial guarantee does not cover this,” although the customer is asserting non-conformity against the seller. How should the response change?
• A B2B customer complains: which contract terms apply, and on what basis could the claim be refused?
• Day 14 is approaching and the team is waiting for a technical opinion: who must act, and what response can be sent on time?

How We Can Help

Complaints handling sits where Polish consumer law, contracts, and daily sales operations meet. We help e-commerce businesses, manufacturers, and distributors connect their written rules to the way their teams actually work.

Our work can include a consistency audit of documents and practice; updated terms, forms, response templates, and B2B GTS; a decision matrix and escalation route; deadline controls; review of recourse provisions with carriers, distributors, and installers; and scenario-based team training.

A workable process is more than a compliant document. It gives staff a basis for decisions, gives customers a consistent answer, and shows management where risks and costs arise.

Put the System in Place Before Growth Exposes the Gaps

A process that worked informally at a smaller scale can begin to produce missed deadlines, inconsistent answers, avoidable escalations, and UOKiK risk as volumes rise. The practical starting point is to audit the current route, update the documents, assign decisions and deadlines, and train the people using them.

If you are unsure whether your Polish complaints process still fits your sales model, contact us. We can help identify the gaps and prioritize what to change first.

Frequently Asked Questions

We have a complaints policy on our website. Is that enough?
Not necessarily. Check whether it reflects the rules applying from January 1, 2023, uses the correct consumer-sales terminology and deadline, and matches your current channels and actual staff practice. Outdated or unfair terms can create UOKiK risk.

What if we do not respond to a consumer complaint within 14 days?
Under the rule described in the source, the complaint is deemed accepted by operation of law. Supreme Court resolution III CZP 113/17 describes at least a rebuttable presumption of acceptance, shifting the burden of showing that the claim was unfounded to the business. The source also cites Regional Court in Łódź judgment III Ca 2311/19 on interruption of the limitation period. Contesting the result can take time and money.

Can we apply one complaints policy to consumers and business customers?
They require distinct legal routes. The Consumer Rights Act non-conformity regime governs the consumer route described here; Civil Code rękojmia governs the B2B route and can be limited or excluded by contract. Also check whether an individual business customer qualifies as an entrepreneur with consumer rights.

Who handles a complaint about goods purchased through a marketplace?
The seller of the goods handles a non-conformity claim. The platform handles its own intermediary-service responsibilities. If the platform itself is identified as the seller, the goods complaint is directed to it.

What if the complaint concerns transport or installation by a subcontractor?
The source’s position is that the seller remains responsible to the consumer. Assign one team to manage the customer’s case, investigate internally, and review partner contracts for a route to recover costs caused by the carrier or installer.

Can we limit or exclude rękojmia for B2B customers?
Yes, the source states that Civil Code rękojmia may be contractually limited or excluded in B2B dealings. Put the provision in the contract or effectively incorporated GTS accepted by the other party; a reference on a website alone may not be enough.