A Northern Ireland-based sole trader is seeking clarity on whether they must comply with the new General Product Safety Regulation (GPSR) when importing products from China and the EU for resale exclusively to Great Britain. They also want to know if they can serve as their own compliance officer using a virtual address.
Key Compliance Requirements:
As an importer selling to GB, compliance with UK GPSR (2023) is mandatory, even without selling to EU/NI markets
The trader is considered an “economic operator” responsible for ensuring products meet safety standards
Must maintain product records and technical documentation for 10 years
Product labeling must include the importer’s name and address
Responsible Person Role:
Can act as own compliance officer/Authorised Representative
Requires a legitimate UK-based address (virtual offices acceptable if they handle mail properly; PO boxes alone insufficient)
Responsibilities include risk assessments, maintaining compliance documentation, and cooperating with authorities
EU GPSR Context:
Came into full effect December 13, 2024
Non-EU manufacturers need an EU-based Responsible Person
Expanded requirements include comprehensive risk assessments and technical documentation
Non-compliance risks include product recalls, fines, and market access loss
The discussion remains informational with no unresolved questions, though implementation details require ongoing attention.
Summarized with AI on October 30.
AI used: claude-sonnet-4-5-20250929.
I am a sole trader in Northern Ireland. I am absolutely confused by this new regulation coming soon.
I import products from China and European Union and resell them to Great Britain. Do I need to comply with the new regulation if I do not intend to sell to EU or Northern ireland, but I am based here?
And second question
I can be my own compliance agent/ officer but where can i find any regulations on what are requirements to do this? I do not have actual physical premises, can I just have a virtual address that I used to register as a sole-trader? Many thanks for any advice
You would typically be considered the economic operator under GPSR, which means you’re responsible for ensuring compliance.
Here’s what that means for you:
Responsible Person (RP) – If you’re selling into the EU/NI, you’ll need an EU-based RP to handle compliance documentation, report safety issues, and liaise with authorities. This can be a third-party compliance service, a distributor, or a fulfillment partner that offers this service.
Supplier Documentation – You don’t necessarily need to provide supplier details in listings, but you must ensure that all components meet EU safety standards. If suppliers provide declarations of conformity, safety test reports, or material composition details (e.g., nickel content in metals), keep these on file.
Labelling & Documentation – The product itself or packaging must include your name/address (or that of your RP), along with any relevant safety warnings or compliance markings.
It’s definitely a lot, and unfortunately, compliance costs hit small sellers hardest. If you’re looking for a service to help navigate this, EaseCert.com specializes in GPSR compliance, documentation, and EU RP services.
Let me know if you need more details—you’re not alone in this!
I totally get why you’re feeling confused about the new General Product Safety Regulation (GPSR)—it’s a big change, and there’s a lot of information to digest. Let’s break it down so you know exactly where you stand as a sole trader based in Northern Ireland but selling to Great Britain (GB).
Do You Need to Comply with the GPSR?
Since you’re importing from China and the EU and reselling in GB (England, Scotland, Wales), YES, you will need to comply with the new GPSR. Here’s why:
The UK’s new GPSR (2023) will apply to all products placed on the market in Great Britain (even if you’re based in Northern Ireland).
Because you are bringing goods from outside of GB and selling them there, you are considered an importer under the law, which means you have compliance responsibilities.
Even though you don’t sell to the EU or within Northern Ireland, the fact that you import products and resell them in GB makes you responsible for ensuring that those products meet UK safety standards.
Can You Be Your Own Compliance Officer?
Yes, you can act as your own compliance officer—this is often called an Authorised Representative or Responsible Person in legal terms. But there are specific requirements for this role, and you need to make sure you meet them.
Here’s what you’ll need to do:
Ensure the products meet UK safety standards (risk assessments, compliance documentation, proper labeling).
Maintain product records for 10 years (test reports, conformity certificates, and safety information).
Cooperate with authorities if there’s ever a product safety issue.
Ensure your name & address is on the product or packaging (as the importer, your details must be visible to consumers).
Do You Need a Physical Address? Can You Use a Virtual One?- You must have a UK-based address that authorities and customers can use to contact you regarding product safety issues.
If you don’t have a physical premises, a virtual office or business address can work as long as it allows for proper communication (e.g., mail handling).
The key thing is that your address is real and accessible—PO Boxes alone do not meet the requirement.
I know this is a lot, but once you set up your compliance process, it should be manageable! Hope this clears things up for you.
If you need extra help, just let me know asap. Thanks Daisy.
The European Union has introduced the General Product Safety Regulation (GPSR), which replaces the previous General Product Safety Directive (GPSD). This regulation came into full effect on December 13, 2024, and applies to all consumer products placed on the EU market, including those imported from countries such as the United States, Canada, the UK, Switzerland, and Australia.
For importers and manufacturers selling goods in the EU, it is essential to understand the expanded obligations under the GPSR to ensure compliance and maintain market access.
Key Updates Under the GPSR###
Expanded Scope and Definitions- A manufacturer is defined as a company that produces or commissions the production of a product and markets it under its name or trademark.
An importer is an entity established within the EU that places products from third countries onto the EU market.
The GPSR broadens the definition of “safe products”, emphasizing that safety considerations must account for foreseeable misuse, evolving functionalities, and other threats.
New Risk Analysis and Technical Documentation Requirements- Manufacturers / importers must conduct a comprehensive risk assessment and prepare technical documentation that demonstrates the product’s safety.
Importers must retain copies of this technical documentation and ensure manufacturers have conducted proper risk assessments.
Introduction of the “EU Responsible Person” Requirement- Non-EU manufacturers must designate an EU-based Responsible Person who will act as a point of contact for compliance and product safety issues.
This entity can be an authorized representative, importer, distributor, or fulfillment service provider.
The Responsible Person is required to hold access to technical documentation and cooperate with EU regulators.
Stronger Product Traceability and Labeling Obligations- All products must carry a serial number or equivalent identifier that is visible and legible.
A manufacturer’s or importer’s name, registered trade name, and a physical and electronic address must be clearly displayed on the product or its packaging.
Enhanced Market Surveillance and Online Marketplace Compliance- Online marketplaces must verify that third-party sellers comply with EU safety regulations.
Operators of an online marketplace in the EU Market, for example a Shopify store, are required by law to register their business with the Safety Gate Portal. Registration ensures compliance with EU regulations and facilitates communication with national market surveillance authorities.
Importers and manufacturers distributing via e-commerce must ensure their products meet the same safety requirements as those sold in physical stores.
Ensure Full Product Traceability: Implement batch tracking and serial numbering systems to facilitate recall management and regulatory compliance.
Conduct a GPSR Risk Assessment: Ensure your products comply with EU safety regulations, addressing foreseeable risks and potential misuse.
Update Packaging and Labeling: Confirm that all required identification details (manufacturer / importer name, address, and contact information) are correctly displayed.
The GPSR represents a significant shift in EU product safety laws, particularly for importers and manufacturers from third countries. By proactively updating compliance strategies, businesses can avoid costly penalties and ensure a smooth transition into the new regulatory landscape.
For more insights or assistance in navigating the GPSR, stay updated through industry portals and the European Commission’s official channels.
Responsible Person (RP) – If you’re selling into the EU/NI, you’ll need an EU-based RP to handle compliance documentation, report safety issues, and liaise with authorities. This can be a third-party compliance service, a distributor, or a fulfillment partner that offers this service.