GPSR for UK Sellers: EU, Northern Ireland and Great Britain Explained

Yes and no, depending on the market. A UK seller needs an operator established in the EU to sell consumer products into the EU-27, and an operator established in Northern Ireland or the EU to sell into Northern Ireland, because the GPSR applies in both. In Great Britain the rules are different: the General Product Safety Regulations 2005 apply, and for most general consumer products we found no requirement to appoint a "UK Responsible Person".

This guide separates three things: what the law says, what official guidance says and what is our own judgement. We flag each. The legal position was checked against the sources listed at the end on 31 October 2026. For the EU label rules in detail, see our guide to the EU responsible person address on the label.

Five short answers:

1. EU-27: the GPSR applies and the responsible operator must be established in the EU. A UK address does not count.
2. Northern Ireland: the GPSR applies since 13 December 2024. The operator must be established in Northern Ireland or the EU. A Great Britain only business does not meet that.
3. Great Britain: the GPSR does not apply. The 2005 Regulations apply, and a UK Responsible Person is not a general legal requirement for consumer products.
4. Some GB product types are different: cosmetics, and goods under UKCA or CE rules, name a UK-established person.
5. Reform is proposed, not in force: the UK consulted in 2026 on online marketplace duties and a UK-based responsible person for some high-risk products.

Which product safety law applies to a UK seller in each market?

The table summarises the position. The exact provisions are in the sources table at the end.

Do UK sellers need an EU responsible person?

Yes, for consumer products placed on the EU market. The GPSR is law in all EU Member States. It says a product covered by it may not be placed on the market unless an economic operator established in the Union is responsible for it. The United Kingdom left the EU, so a UK company, warehouse or address is not "established in the Union".

Three further points apply to UK sellers:

1. Selling online counts. The regulation treats products offered online as made available on the EU market if the offer is targeted at consumers in the EU. Shipping from a UK warehouse does not take you outside it.
2. Four routes exist. The EU operator can be an EU manufacturer, an EU importer, an authorised representative with a written mandate, or a fulfilment service provider where none of the others exists. For the difference between the roles, see EU responsible person vs authorised representative and whether an EU importer can be your responsible operator.
3. A Northern Ireland company is not automatically an EU operator. Northern Ireland is not an EU Member State. The GPSR asks for an operator established in the Union for the EU market. We found no EU source that treats a business established only in Northern Ireland as established in the Union, so do not assume it for EU-27 sales. This is our caution, not a ruling.

Our broader checklist for UK and US sellers is in what you need to sell in Europe.

Does the GPSR apply in Northern Ireland?

Yes. GOV.UK's guidance from the Office for Product Safety and Standards (OPSS) states that Regulation (EU) 2023/988 applies directly in respect of Northern Ireland from 13 December 2024. A Northern Ireland Assembly committee letter of 4 December 2024 describes the regulation as existing EU law that applies in Northern Ireland under the Windsor Framework. The regulation's own text does not mention Northern Ireland, so the basis is the Windsor Framework and the UK guidance.

The facts that matter:

1. Date. The GOV.UK guidance says the regulation applies only to products placed on the market from 13 December 2024. Products already on the Northern Ireland market before that date that complied with the 2005 Regulations may stay on sale.
2. Replacement. GOV.UK states that the 2005 Regulations were superseded in Northern Ireland on 13 December 2024.
3. Great Britain stays outside. The same guidance says the regulation does not apply to products placed on, or made available to, the Great Britain market.
4. GB sellers are named. The guidance says it is particularly relevant to businesses in Great Britain that sell products to the Northern Ireland market.
5. Marketplaces follow it. Etsy lists Northern Ireland among its GPSR destinations. eBay's help page also refers to the EU or Northern Ireland. See the marketplace section below.

This is where many UK sellers are surprised. A parcel from Manchester to Belfast stays inside the UK, but the product is placed on a market where the GPSR applies.

Can a UK company be the responsible person for Northern Ireland?

Only if it is established in Northern Ireland or the EU. GOV.UK says a product can be placed on the Northern Ireland market if there is a responsible economic operator established in either Northern Ireland or the EU, and that "established" means having a presence in one of them. The operator can be the manufacturer when established there, an authorised representative the manufacturer appoints, an importer where the manufacturer is not established there, or a fulfilment service provider where none of the others exists.

What follows from that:

1. A business based only in England, Scotland or Wales does not meet the test. Its place of business is in Great Britain. This follows from the guidance's wording and is our reading, not a sentence the guidance spells out.
2. A business with a real presence in Northern Ireland may qualify. OPSS's factsheet deals with businesses present in both Great Britain and Northern Ireland or the EU and says the answer depends on their circumstances. Do not rely on a mailing address alone.
3. An EU operator covers Northern Ireland too. A single responsible operator can serve the EU-27 and Northern Ireland, which is how our own service is set up.
4. GOV.UK expects GB sellers to look outside. It notes that private sector services exist where an EU or Northern Ireland based representative is required, and that online marketplaces may also provide one.

What applies in Great Britain?

The General Product Safety Regulations 2005 apply in Great Britain. GOV.UK says they require consumer products to be safe in normal or reasonably foreseeable use. The EU GPSR does not apply there.

The 2005 Regulations speak of a "producer", not a responsible person. The definition, as it now reads for Great Britain, works in three steps:

1. The producer is the manufacturer, when it is established in the United Kingdom.
2. If the manufacturer is not established in the United Kingdom, the producer is its representative established in the United Kingdom, if it has one.
3. If there is no such representative, the producer is the person established in the United Kingdom that places the product on the market from a country outside the UK.

GOV.UK's guidance summarises this as including GB-based manufacturers and UK-based importers. Distributors have separate duties. For importers, OPSS allows a time-limited alternative way to show the importer's address, for example on a batch document or outer packaging label, and says those options may not be used after 31 December 2027.

The guidance does not explain how the Regulations work when a seller outside the UK ships directly to a consumer in Great Britain with no UK importer. We do not read the rules as creating a general duty to appoint a UK-based person in that case, but the guidance is silent, so this is our judgement and not an official statement.

What is the status of UK product safety reform?

As of 31 October 2026, the reform is a set of proposals, not law:

1. The Act is in force but empty of seller duties. The Product Regulation and Metrology Act 2025 was passed in July 2025 and, apart from one provision, came into force when passed. It is an enabling Act. It lets ministers make product regulations, including rules for products sold through an online marketplace and rules requiring the appointment of authorised representatives. The duties themselves must come from regulations.
2. A consultation ran in 2026. The government published proposals on 31 March 2026 and closed responses on 23 June 2026. They include a duty on online marketplaces to act with due care against dangerous products and a UK-based responsible person for some high-risk products.
3. No outcome yet. The consultation page still said the government was analysing feedback. We found no regulations made under the Act that place new duties on sellers or marketplaces.

If the proposals become law, the UK side could start to look more like the EU one for some products. Today, it does not. Check GOV.UK before relying on this part, because it can change quickly.

Do you need a UK Responsible Person to sell in Great Britain?

For most general consumer products, we found no legal requirement. The 2005 Regulations and GOV.UK's general product safety guidance do not use the term "UK Responsible Person". But the term is real in some regimes, and other regimes name a UK-established person under a different title:

1. Cosmetics. Every cosmetic product available to consumers in Great Britain must have a Responsible Person with a UK established address, and the container and packaging carry its name and address. A PO box or mail forwarding address does not count. The same guidance says that for Northern Ireland the Responsible Person must be established in Northern Ireland or the EU. GOV.UK pages differ slightly in wording on cosmetics addresses, so check the current text for your product. Our cosmetics guide covers the EU side.
2. UKCA and CE regulated goods. For goods under product-specific legislation, GOV.UK's guidance for Great Britain uses the terms importer and authorised representative, both defined as established in the UK. Manufacturers and importers indicate their name and postal address on the product, or on packaging or a document where the product is too small. GOV.UK says the UK continues to recognise the CE marking, alongside or in place of UKCA, for many product regulations.
3. Northern Ireland product regimes. GOV.UK says the UKNI marking is never used on its own and always accompanies an EU conformity marking.

Check which regime your product falls under before you decide. The product-specific rules usually take precedence over the general rules where they overlap, according to GOV.UK's product safety advice for businesses.

Marketplaces are a separate reason sellers add a UK address. A UK Responsible Person may be requested on a marketplace listing because of marketplace policy, not because the 2005 Regulations ask for it. We could not find a marketplace help page that makes it a requirement for Great Britain listings, so we do not state that it is.

Which address goes on the label in each market?

Each market has its own set of names and addresses. A practical split:

1. EU-27 and Northern Ireland: the manufacturer's name or trade mark, postal address and electronic address; the importer's, where there is one; and the name or trade mark, postal and electronic address of the EU or Northern Ireland responsible operator. These go on the product, packaging, parcel or an accompanying document as the rules allow. The EU operator's address must be a real point of contact.
2. Great Britain (general products): the producer's name and address where reasonable. For a non-UK manufacturer, that is the UK representative or UK importer.
3. Great Britain (cosmetics, UKCA goods): the Responsible Person, UK importer or authorised representative named in the product regime.

One label can serve all three markets if each name and address is present and labelled by role. Do not merge roles: write "EU Responsible Person", "UK importer" or "UK Responsible Person" as it applies. The full EU rules are in our GPSR labelling requirements guide. For warnings and instructions, remember that the GPSR language requirement follows the country of sale.

What do Amazon, eBay and Etsy ask UK sellers?

Marketplace rules are not law, and they change. What each platform's own pages say, as we read them:

1. Amazon. A 2024 Amazon announcement to sellers said the GPSR applies in the European Union including Northern Ireland, that sellers must have a Responsible Person established within the EU for non-food products, and that for listings on Amazon's UK store they did not need to submit information to Amazon. Check Seller Central for the current rule. See the Amazon GPSR guide.
2. eBay. eBay's help page says sellers may be asked to add manufacturer contact details for certain products sold to the EU or Northern Ireland, and lets them add an EU responsible person when the manufacturer is not based in the EU or Northern Ireland. It does not mention Great Britain.
3. Etsy. Etsy lists Northern Ireland with the EU and EEA countries in its GPSR workflow, and lets sellers opt out of those destinations. Opting out stops buyers there from purchasing. See the Etsy GPSR guide.

For the duties the marketplaces themselves carry, see online marketplace obligations under the GPSR.

What should a UK seller do first?

A sensible order:

1. Decide where you sell. List the EU countries, Northern Ireland and Great Britain you actually ship to. Opting out of Northern Ireland is a commercial decision, but then you must stop selling there.
2. Check your product regime. Is it a general consumer product, or does cosmetics, toy, electrical or other product-specific law apply?
3. Confirm your operator for the EU and Northern Ireland. Is there an EU manufacturer, importer or representative with a written mandate that covers it?
4. Check the UK side by product. Identify whether a UK importer, authorised representative or Responsible Person is needed, or whether a marketplace asks for a UK address.
5. Fix labels and listings last, once. Use the same names and addresses on the product, packaging, insert and every listing.

How can Grüner Baum GmbH help?

Grüner Baum GmbH acts as an EU responsible person for manufacturers outside the EU. Our service covers the EU-27 and Northern Ireland, which fits the GPSR rules above. Before we accept a product family, we check the technical documentation, the label and the online listing. Our address may be printed only after we have accepted the product family in writing.

For Great Britain, we offer an EU + UK Responsible Person package with our UK partner Lantara Compliance Ltd, a company registered in England and Wales. The UK mandate is signed with Lantara Compliance Ltd directly. Depending on the product, it acts as your UK Responsible Person for cosmetics, your UK authorised representative for UKCA and CE regulated goods, or your UK contact for general products; it does not act as your UK importer. As explained above, a UK Responsible Person is not a legal requirement for most general consumer products in Great Britain. See the pricing page for the packages, or contact us with your product categories and the markets you sell to.

Frequently asked questions about GPSR for UK sellers

Do UK sellers need an EU responsible person?

Yes, for consumer products placed on the EU market. The GPSR says a product may not be placed on the market unless an operator established in the EU is responsible for it, and the UK is not in the EU. That operator can be an EU manufacturer, an EU importer, an authorised representative with a written mandate or, in defined cases, a fulfilment service provider. An online offer aimed at EU consumers counts as placing the product on the market.

Does the GPSR apply in Northern Ireland?

Yes. GOV.UK guidance states that Regulation (EU) 2023/988 applies directly in respect of Northern Ireland from 13 December 2024, under the Windsor Framework, and that it replaced the General Product Safety Regulations 2005 there. Products placed on the Northern Ireland market need a responsible economic operator established in Northern Ireland or the EU.

Can a UK company be my responsible person for Northern Ireland?

Only if it is established in Northern Ireland or the EU. GOV.UK says 'established' means having a presence in Northern Ireland or the EU. A company that exists only in England, Scotland or Wales does not meet that test, even though Northern Ireland is part of the UK. A company with a real presence in both Great Britain and Northern Ireland may qualify, depending on its circumstances.

Do I need a UK responsible person to sell in Great Britain?

For most general consumer products, we found no rule that requires one. The General Product Safety Regulations 2005 do not use that term. They give producer duties to a manufacturer established in the UK, otherwise to its UK representative, otherwise to the UK-established person who places the product on the market from abroad. Some regimes do require a UK-established person: cosmetics need a Responsible Person with a UK address, and UKCA or CE product rules involve a UK importer or authorised representative.

Is the UK GPSR the same as the EU GPSR?

No. The UK General Product Safety Regulations 2005 apply in Great Britain and come from the earlier EU directive. The EU GPSR, Regulation (EU) 2023/988, applies in the EU-27 and Northern Ireland. They share an acronym and a general safety principle, but only the EU regulation asks for a responsible operator established in the EU or Northern Ireland.

Can one label serve the EU, Northern Ireland and Great Britain?

It can, if every required name and address appears and each is clearly labelled by role. The EU and Northern Ireland markets need the manufacturer and the EU or Northern Ireland operator. Great Britain may need a UK importer, representative or Responsible Person, depending on the product. Keep language rules in mind: instructions and warnings must be understood in the country of sale.

Is there a new UK law for online marketplaces and product safety?

Not yet in force, as far as we found. The Product Regulation and Metrology Act 2025 gives ministers powers to make rules for online marketplaces and for authorised representatives. The government consulted on proposals from 31 March to 23 June 2026, and on 31 October 2026 its consultation page still showed no outcome. Proposals are not law.

Official and technical sources

This article is general information, not legal advice.