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Which EU rules apply to consumer goods imported from the United Kingdom?

Consumer goods brought in from the United Kingdom: two product-safety regimes, why a UK entity does not qualify, and what else applies. This page is one fixed set of answers to the product check, written out in full. The wording comes from the same rule set the questionnaire uses, so the two cannot drift apart.

Triage, not a clearance. It sorts this situation into the right regimes; it does not classify your specific product, and classification is where most of the cost sits. Your own case may differ on any of the answers below; run the check with your own.

The answers this rests on

Open the check with these answers →

4 regimes apply to this situation

GPSR; General Product Safety Regulationapplies, no threshold

Every consumer product placed on the EU market falls under it. There is no turnover threshold and no small-importer exemption, and marketplaces enforce it themselves by suspending listings.

  • An EU Responsible Person must be established in the Union and named visibly to the buyer. A UK entity does not qualify.
  • Manufacturer and Responsible Person name and address on the product or packaging, plus a type, batch or serial number; and, as importer, your own name and postal and electronic address alongside them.
  • Warnings and safety information in the language of every country you sell into.
  • A copy of the manufacturer's technical documentation kept at the disposal of the market surveillance authorities for ten years from placing on the market. Drawing it up is the manufacturer's job; having it is yours.
Regulation (EU) 2023/988, Articles 2(1), 4, 9, 11 and 16, applicable since 13 December 2024 · 2023/988 on EUR-Lex · read the full answer

EPR; extended producer responsibilityper member state

You are the producer in every country where you first place the goods on the market, and registration is national. There is no EU-wide register: each state has its own scheme, number, fee and report.

  • Packaging triggers it on its own, whatever the product is.
  • You named 2 member states; that many separate registrations, each with its own register, number and fee.
  • Germany: packaged goods need the LUCID register; marketplaces like Amazon.de ask for the number before you can list.
  • Register before the first sale into that country; several states treat selling without a number as an offence.
  • From 12 August 2026, if you make packaging or packaged products available for the first time in another member state directly to end users, you must appoint an authorised representative for extended producer responsibility there, by written mandate and per country. Sell to a distributor established in that country instead and he is the producer there, not you.
  • That first rule already covers you if you sit outside the EU and supply end users directly: Article 3(1), point (15)(c) and (d) says established in a member state or in a third country. Only if you sell to a distributor in that country instead is the mandate a member-state option rather than a duty.
National EPR regimes implementing Directive 2008/98/EC, Article 8a; Regulation (EU) 2025/40 (packaging), Article 45(3) read with Article 3(1), point (15)(c) and (d), and Article 71 (applies from 12 August 2026) · 2025/40 on EUR-Lex · read the full answer

United Kingdom; a separate regimetwo systems

Great Britain runs its own product-safety regime while Northern Ireland follows EU rules under the Windsor Framework. Goods moving both ways need both sides checked.

  • A UK entity cannot be your EU Responsible Person.
  • Selling into GB may require a UK Responsible Person of its own.
UK Product Regulation and Metrology Act 2025 (2025 c. 20), Royal Assent 21 July 2025; Windsor Framework · 2025 c. 20 on legislation.gov.uk · read the full answer

Sanctions screeningscreen before you pay

EU sanctions prohibit making funds or economic resources available to listed persons, directly or indirectly. There is no turnover threshold, a breach does not require intent, and a new or non-EU counterparty is exactly where this bites.

  • Screen the name free on this site before you pay an invoice.
  • Ownership above 50% by a listed person catches a supplier that is not itself listed.
  • Your bank's screening is not your screening, and it is not a defence.
  • If you may have to show later that you checked, keep a dated record naming the list versions.
Regulation (EU) 269/2014 Article 2 and equivalents; Directive (EU) 2024/1226 · 269/2014 on EUR-Lex · read the full answer

This is the list of things to check, not a clearance. It leaves out CE, RoHS/WEEE, EUDR, food and cosmetics law and customs. Something wrong or missing? Corrections are made with the source noted.

What to do next, in this order

  1. Check the counterparty exists and who may sign find the company in its home register, free
  2. Screen the name against nine sanctions lists before you pay, not after
  3. Pin down the goods code duty, CBAM scope and restrictions all hang off it
  4. Work out duty and VAT you bring the TARIC rate, the tool does the arithmetic
  5. Verify the VAT number on the day you invoice VIES, and keep the response
  6. Walk the fifteen GPSR checks ticks are saved on your own device

Where each of these is worked out

Does this not fit your case, or is something missing? Ask it here; questions are answered with the regulation and the article, and the questionnaire gets fixed. Providers who do this work are listed separately; being named there is not a recommendation.

Other situations, worked out the same way

What this does not cover

Named, because a triage tool that stays quiet about its edges is worse than none: