UK GPSR Rules for Sellers: Great Britain vs Northern Ireland (EU GPSR under the Windsor Framework)

Three markets, two rulebooks

“Do I need GPSR for Amazon UK?” depends on where the buyer is. Since Brexit, Great Britain (GB: England, Scotland and Wales) applies UK law, while Northern Ireland (NI) continues to apply certain EU product rules under the Windsor Framework (formerly the Northern Ireland Protocol). The EU GPSR is one of them.

If one product is listed on Amazon.de and Amazon.co.uk, prepare for both regimes. For the EU side see what is GPSR; the UK side is below.

Great Britain: the General Product Safety Regulations 2005

The General Product Safety Regulations 2005 (SI 2005/1803) came into force on 1 October 2005 and originally transposed the old EU Directive 2001/95/EC. They were retained after Brexit and amended by 2019 EU Exit regulations so that they now apply to Great Britain only. The UK government's GB guidance (December 2024) summarises the duties:

• Who is the producer: a manufacturer established in the UK; anyone presenting themself as the manufacturer by putting their name or trade mark on the product; the person who reconditions the product. Where the manufacturer is not established in the UK, its UK-established representative, or otherwise the UK-established person who brings the product into the GB market from outside the UK. Other professionals in the supply chain count insofar as their activities affect safety.
• Producer duties: place only safe products on the market; give consumers the information they need to assess risks; where reasonable, mark the producer's name and address and the product reference or batch on the product or packaging; monitor safety (sample testing, complaints register); notify the enforcement authority in writing if a product is unsafe.
• Distributor duties: act with due care, do not supply products known to be dangerous, keep records of who supplied the goods, cooperate with authorities and recalls.

One deadline to note: where a UK importer cannot yet put its address on each item or its packaging, the guidance allows alternatives such as batch documents, invoices or outer-carton labels, but these options may not be used after 31 December 2027.

Toys, electrical goods, radio equipment and other sectors have their own regulations; the 2005 Regulations fill the gaps. UK guidance updated in August 2026 says GB continues to recognise the CE marking for many product types, alongside UKCA, under the Product Safety and Metrology (Amendment) Regulations 2024. Check the specific UK regulation for your product.

Northern Ireland: EU GPSR, with a responsible operator in NI or the EU

UK government guidance for Northern Ireland (last updated 4 November 2025) confirms that Regulation (EU) 2023/988 superseded the 2005 Regulations in NI on 13 December 2024. Consumer products sold into NI must therefore meet the full EU GPSR: risk analysis and technical documentation (Article 9), product identifier and manufacturer details (Article 9(5) and (6)), instructions and safety information in an easily understood language (Article 9(7)) and online offer information (Article 19).

The responsible operator is the key point. The guidance says products may only be placed on the NI market if there is a responsible economic operator established in NI or the EU: a manufacturer, authorised representative, importer or, where none of those exists, a fulfilment service provider. “Established” means a real presence such as a registered office, headquarters or permanent place of business; a PO box is not enough.

For sellers outside the UK and EU this means: a UK representative based in England is neither in NI nor in the EU, so it cannot act as your NI GPSR responsible person. If you already have an EU responsible person, it can cover NI. The UK guidance states that a single responsible economic operator can be used for supplies to both the EU and NI, regardless of which of the two it is established in.

Can an NI-based operator serve the EU-27? The Commission's Blue Guide 2022 (section 2.9.6) says that, for Union harmonisation legislation (CE products), importers, authorised representatives and other operators required to be established in the Union may be established in Northern Ireland. We found no equivalent Commission statement specific to the GPSR for non-CE consumer products (to be re-checked). The safe choice for EU-27 sales is an EU-established responsible person, which also covers NI.

UK Responsible Person vs EU responsible person

“UK Responsible Person” or “UKRP” is a market label; its legal meaning depends on the product. UK law requires a UK-based responsible person in some sectors such as cosmetics. For general consumer goods in GB, the 2005 Regulations define the producer, which is the UK representative or UK importer when the manufacturer is outside the UK.

Selling to the EU, NI and GB therefore usually means one EU responsible person covering the EU and NI, plus a UK-based representative or importer for GB. One company can hold both roles if it has the right written mandate and capability for each. Check that your EU mandate names Northern Ireland in its territory clause; see EU Responsible Person and economic operator roles.

Labels and listings for EU and UK on one product

One label can serve all three markets if every required item is there and nothing misleads:

• Manufacturer: name or registered trade mark, postal address and electronic contact (GPSR Article 9(6); the 2005 Regulations require the producer's name and address).
• EU/NI responsible person: name, postal and electronic address (GPSR Article 16(3)), on the product, packaging, parcel or an accompanying document.
• UK representative or importer: name and address for GB traceability.
• Type, batch or serial number: both regimes require the product to be identifiable.

The NI guidance adds that an accompanying document can be a receipt or dispatch note that does not have to sit inside the product packaging, as long as it travels with the product. Online, listings that sell into NI must show the manufacturer and responsible person details required by Article 19; eBay and Etsy have publicly said the GPSR covers NI, and the exact fields are whatever the platform currently shows (see online GPSR information). You can draft a label at gpsrtools.com and check it against this list.

Goods shipped from Great Britain to Northern Ireland count as imported products under the EU framework (Blue Guide, section 2.9.6), so stock moved from an English warehouse to NI customers needs the importer-style set-up for responsible person and labels.

What is changing: the Product Regulation and Metrology Act 2025

The Product Regulation and Metrology Act 2025 (2025 c. 20) received Royal Assent on 21 July 2025. It is an enabling Act: it does not itself set label or responsible-person duties for sellers, but lets the government update product rules through secondary legislation, including rules for online marketplaces.

On 31 March 2026 the government opened three consultations: the UK's new product safety framework, a market surveillance and enforcement framework, and fire safety of domestic upholstered furniture. All closed on 23 June 2026. Proposals in the framework consultation include:

• three categories of duty holder: producers, onward suppliers and online marketplaces;
• where the manufacturer is not UK-based, its UK-established authorised representative, or otherwise the importer, takes on producer duties;
• a duty on online marketplaces to act with due care to prevent, identify and remove dangerous products, and to verify seller contact details;
• a UK-wide framework that takes account of the Windsor Framework, leaving the EU GPSR in place in NI where it applies.

These are proposals. As of 8 November 2026 the consultation page shows it as closed with no published government response, and we found no new general product safety regulations replacing the 2005 Regulations on legislation.gov.uk (to be re-checked). Until new regulations are made and in force, GB follows the 2005 Regulations. We track updates in the GPSR timeline.