Importer responsibilities for the GB market

If you import products into Great Britain (England, Scotland, and Wales) from manufacturers based outside the UK, you have specific legal responsibilities under product safety legislation. As an importer, you are the first link in the GB supply chain and carry significant obligations. You cannot simply pass products through — you must actively verify they are safe and compliant before placing them on the market.

This guide explains what the law requires of you as an importer, how to verify manufacturer compliance, and what to do when problems arise.

Who is an importer?

Under UK product safety legislation, an importer is any natural or legal person established in the United Kingdom who places a product from a non-UK manufacturer on the GB market. If you purchase goods from an overseas manufacturer and make them available for sale in Great Britain, you are the importer regardless of whether you sell directly to consumers or supply to other businesses.

Key distinction: If the manufacturer is established in the UK, there is no importer in the supply chain — the manufacturer places the product on the market directly. If you are a UK business that has a non-UK manufacturer produce goods under your own brand, you may be treated as the manufacturer under product safety law, not just the importer.

Verifying manufacturer compliance before import

Before placing any product on the GB market, you must verify that the manufacturer has fulfilled their obligations. This is not optional — importing a non-compliant product makes you liable for enforcement action even if the manufacturer was at fault.

You must check that:

1. The manufacturer has carried out the appropriate conformity assessment procedure for the product (self-declaration or third-party assessment by a UK Approved Body or EU Notified Body, as required by the applicable regulation)
2. The manufacturer has drawn up the required technical documentation and that it is available for inspection
3. The product bears the correct UKCA marking or CE marking (CE marking is accepted indefinitely for the 21 covered product regulations under the October 2024 policy)
4. The product is accompanied by the required UK Declaration of Conformity (or EU Declaration of Conformity for CE-marked products)
5. The manufacturer's name and contact address appear on the product or its packaging
6. The product bears appropriate type, batch, or serial identification for traceability

You should obtain and retain copies of the conformity assessment documentation from the manufacturer. If the manufacturer cannot or will not provide this documentation, do not import the product.

Importer labelling obligations

As an importer, you must ensure your own details appear on the product in addition to the manufacturer's details. This is a legal requirement for traceability purposes.

You must place on the product or its packaging:

• Your business name (or registered trade name or trade mark)
• Your postal contact address in the United Kingdom

Where the size or nature of the product makes it impossible to place this information on the product itself, you may place it on the packaging or in an accompanying document.

You must not alter the product in a way that affects its compliance with the applicable safety requirements. If you do alter the product (rebranding, modifying, repackaging in a way that could affect safety), you may be treated as the manufacturer and assume the full manufacturer obligations.

Storage, transport, and ongoing duties

Your responsibilities do not end at the point of import. You must ensure that:

• Storage and transport conditions do not jeopardise the product's compliance with safety requirements. Products must be stored in conditions that maintain their safety and integrity.
• You keep a copy of the UK Declaration of Conformity (or EU Declaration of Conformity) for 10 years after the last product of that type is placed on the market.
• You can provide technical documentation to OPSS or Trading Standards on request. You must be able to produce this within a reasonable timeframe when asked.

Responding to unsafe or non-compliant products

If you have reason to believe a product you have imported does not comply with applicable safety requirements, you must:

1. Not place the product on the market (or immediately stop further supply if already on the market)
2. Notify OPSS immediately if the product presents a risk to consumers
3. Take corrective action — this may include informing the manufacturer, withdrawing the product from the market, or cooperating with a product recall
4. Keep records of all complaints, non-conforming products, product withdrawals, and recalls
5. Keep distributors informed of any safety issues and the monitoring steps you are taking

Due diligence defence: Under the General Product Safety Regulations 2005, you have a defence if you can prove you took all reasonable steps and exercised all due diligence to avoid committing an offence. Robust verification procedures, documented checks, and clear records of your supplier due diligence are essential to relying on this defence.

Authorised representatives

A non-UK manufacturer may appoint an authorised representative established in the UK to act on their behalf for certain limited tasks. The authorised representative can hold copies of the Declaration of Conformity and technical documentation, and cooperate with enforcement authorities. However, the authorised representative cannot be held responsible for the design or manufacture of the product itself. The importer's obligations remain even where an authorised representative has been appointed.