GPSR for UK Sellers: Selling into the EU After Brexit (2026)

If you are a UK seller whose EU listings were deactivated, the cause is the General Product Safety Regulation (Regulation (EU) 2023/988, GPSR), applicable since 13 December 2024.

The Brexit-specific point that catches most UK sellers out: for EU product law, Great Britain is a third country. Your obligations selling into the EU are now the same as a seller in the US or Australia — not the same as an EU seller. And because the UK and the EU now run separate product-safety regimes, you may be subject to both at once.

Two regimes, not one

You are selling to	Which rules apply	Do you need an EU Responsible Person?
Customers in EU member states	EU GPSR	Yes
Customers in Great Britain (England, Scotland, Wales)	UK domestic product safety law	No — GPSR does not apply
Customers in Northern Ireland	EU goods rules continue to apply under the Windsor Framework	Usually yes — treated as EU market access

Two practical consequences:

1. Compliance with UK product safety law does not make you EU-compliant, and vice versa. They are separate obligations that happen to overlap in substance.
2. An EU Responsible Person does not cover your GB sales, and a UK address does not satisfy the EU requirement. If you sell into both, you need both sides covered.

Northern Ireland is the one to verify rather than assume, because arrangements there have changed more than once. Check the current position with gov.uk guidance before relying on an NI address for EU purposes.

The requirement you cannot satisfy from the UK

Article 16 GPSR requires a responsible economic operator established in the EU — meaning in one of the 27 member states. A UK company, a UK address and a UK phone number do not qualify, however long you have been trading in Europe.

Your realistic options:

Option	Works when	Rough cost
Your EU importer	You sell wholesale to a business in the EU who imports your goods	Free — they are the operator
An EU entity of your own	You kept or opened a subsidiary in an EU member state	Cost of maintaining the entity
A paid EU Responsible Person service	You ship direct to EU consumers	Typically €150–400/year
A fulfilment provider in the EU	Only if they accept the Article 4 duties in writing	Most do not by default

A common and expensive misunderstanding: using Amazon's European fulfilment network does not make Amazon your Responsible Person. Storing your stock in Germany is not the same as accepting legal responsibility for the product. See what an EU Responsible Person costs for a provider comparison.

What goes on the EU listing

Article 19 GPSR requires that the offer shows, before purchase:

• Manufacturer — name, postal address, electronic address. If you sell under your own brand, that is you, even if a factory elsewhere makes it.
• The EU responsible operator — name and full contact details.
• Product identification — picture, type, batch or serial number.
• Safety warnings — in a language the consumer in that country easily understands.

English is not sufficient across the EU. Selling into France means French warnings; into Germany, German. This surprises UK sellers more than most, because it was not a practical issue while the UK was a member state.

Platform specifics: Amazon EU compliance fields · Etsy · eBay · Shopify.

The documentation nobody asks you to upload

Article 9(2) GPSR requires manufacturers to carry out an internal risk analysis and keep technical documentation for ten years. No marketplace collects it at listing time, which is why most sellers discover the requirement only when an authority asks.

• Building the risk assessment · free generator
• What goes in the technical file · free generator

What GPSR does not require

• There is no GPSR certificate or registration. No body issues one. Anyone selling you GPSR certification is selling a product that does not exist.
• CE marking is not a GPSR requirement, and UKCA is not an EU marking. UKCA has no standing in the EU market whatsoever.
• An EU Declaration of Conformity is usually not needed — it belongs to CE-scope legislation, not GPSR. Check first: when you actually need one.
• There is no small-seller or handmade exemption. Turnover and volume do not change the obligation, only the amount of work.

Is the EU market still worth it?

This deserves an honest answer rather than a sales pitch. The fixed annual cost of an EU Responsible Person is roughly €150–400. If your EU revenue is a few hundred pounds a year, the compliance cost may exceed the margin — and deciding to stop selling into the EU is a legitimate business answer.

What is not a legitimate answer is continuing to sell without an EU operator and hoping the listing stays up. Marketplaces are required under Article 22 GPSR to cooperate with enforcement, which is why suspensions arrive without negotiation.

If you start today

1. Decide whether EU sales justify the annual operator cost.
2. Appoint an EU Responsible Person and get their details in writing.
3. Fill the listing fields on every EU marketplace, with warnings in the destination language.
4. Build the risk assessment and technical file, best sellers first.
5. Keep your GB obligations separate and current — they did not go away.

Official sources: Regulation (EU) 2023/988 (GPSR) · Regulation (EU) 2019/1020 (market surveillance) · gov.uk — product safety guidance · EU Safety Gate

General information, not legal advice. Northern Ireland arrangements in particular have changed over time — verify the current position before relying on it.

Check your product and generate the documents — €14