.png)
Germany is the largest and most profitable food supplement market in Europe, valued at over EUR 3.2 billion annually. For Polish manufacturers, exporting across the western border offers margins 5 to 15 times higher than domestically. However, the German legal system is unforgiving for the unprepared.
Entering this market without proper formal foundations typically ends with goods blocked at the border, fines of up to EUR 50,000, or a permanent ban on the seller's Amazon account.
Below you will find the current as of November 2025, practically tested step-by-step process - exactly the one we use when introducing our clients' products to the German market.
1. The Most Important Question First: Supplement or Already a Medicine?
Before investing in marketing, you must be certain how your product will be classified by German authorities (BfArM and BVL). The boundary is thin and runs differently than in Poland.
A product will be classified as a medicine (Arzneimittel) - entailing costly and time-consuming registration - if:
- Doses are too high: Vitamin or mineral content exceeds the upper safety limits set by BfR.
- Contains Novel Food: The formulation includes substances without EU authorisation or at concentrations higher than permitted.
- Inappropriate communication: The label or advertising suggests a therapeutic effect (key words: "cures", "regenerates inflammation", "prevents disease").
Expert Tip: Before starting any procedures, commission a professional composition and advertising claims analysis (Compliance Check). This will help avoid the costly withdrawal of the product from the market.
2. Step 1 - BVL Notification (Mandatory Gateway)
In Germany, placing a food supplement on the market requires notification. From 2025, this process is fully digital via the BUCH / Lebensmittelwarnung portal. Without notification confirmation, selling is illegal.
What is required for notification:
- Final label in German (compliant with LMIV and NemV).
- Exact quantitative composition including percentage of nutrient reference values (NRV).
- Company data: Polish entity and a German correspondence address (mandatory requirement).
Processing time: 1-3 business days | Official cost: EUR 0
3. Step 2 - German VAT Number (USt-IdNr)
If you plan to sell via Amazon.de, Kaufland.de, or your own shop targeting German consumers, the Polish VAT-OSS number may not suffice.
The application is submitted online at the BZSt website. Processing time: 2-6 weeks.
4. Step 3 - Your Tax Shield: uvZTA
Most supplements qualify for a reduced 7% rate. The solution is a uvZTA - an official confirmation from Zoll (German Customs).
Validity: 3 years | Cost: EUR 0
5. Step 4 - PZN (Pharmazentralnummer)
| Sales Channel | PZN Required? | On Packaging? |
|---|---|---|
| Amazon.de | NO | NO |
| Own online shop | NO | NO |
| Online pharmacies | YES | YES |
| Pharmaceutical wholesalers | YES | YES |
6. Labelling - Where Polish Manufacturers Make Mistakes
Most common errors:
- Incomplete translation into German.
- Unauthorised health claims.
- Missing mandatory warnings in the exact required wording.
- Lack of a responsible entity within the EU on the label.
7. Real Costs and Timelines (2025 Summary)
| Service / Stage | Estimated Cost | Processing Time |
|---|---|---|
| BVL Notification | EUR 0 - 400 | 1-5 days |
| German VAT | EUR 0 - 300 | 2-6 weeks |
| uvZTA (7% VAT) | EUR 0 - 500 | 4-6 weeks |
| PZN (for pharmacies) | EUR 80-150 / year | 7-14 days |
| Label verification | EUR 300-800 | 5-10 days |