Product safety and supply chain

Product safety responsibilities across the supply chain

Who is responsible for product safety at each stage of the supply chain. Explains the duties of manufacturers, importers, distributors, and online marketplace operators under the General Product Safety Regulations 2005 and the Product Regulation and Metrology Act 2025, including the new UK Responsible Person requirement.

UK-wide
Guide summary

You must know your role in getting products to customers. The law gives different duties to manufacturers, importers, distributors and online marketplaces. You are responsible for product safety based on what you do, not what you call yourself. Check your role and follow the rules to avoid enforcement action.

  • Identify your supply chain role (manufacturer, importer, distributor)
  • Manufacturers must design safe products and create technical documents
  • Importers must check products meet UK rules before selling
  • Distributors must check products have correct markings
  • Online marketplaces must prevent sale of unsafe products
  • Keep product safety records for up to 10 years
  • Notify OPSS immediately if a product is unsafe
  • Trading Standards can take action against any business
  • New rules for online marketplaces coming in 2025
  • You can have more than one role for different products
On this page
UK-wide

Related guides in International Trade

Product safety law does not impose a single blanket duty on everyone involved in getting a product to consumers. Instead, it assigns specific obligations to each role in the supply chain. A manufacturer has different duties from an importer, and an importer has different duties from a distributor.

Getting your role wrong, or failing to understand the duties that attach to it, is one of the most common causes of enforcement action. OPSS and local Trading Standards can take action against any business in the chain that fails to meet its obligations, regardless of where the product was designed or made.

This matters because:

  • Liability follows role, not intention. If you import a product, you carry importer duties whether or not you realise it. Ignorance of your supply chain position is not a defence.
  • Multiple roles can apply. A business that manufactures some products and imports others has different obligations for each. A retailer that also sells online through a marketplace may have distributor duties and, under future legislation, marketplace duties.
  • The law is changing. The Product Regulation and Metrology Act 2025 introduces new roles (UK Responsible Person) and new obligations (online marketplace duties) that will take effect through secondary legislation.

The five supply chain roles

UK product safety law recognises five distinct roles. Each carries specific legal obligations. A single business may hold more than one role depending on the product and the supply arrangement.

How to identify your role

Your supply chain role is determined by what you actually do, not by what you call yourself. A business that describes itself as a "distributor" but places its own branding on a product may be treated as a manufacturer under the law.

You are a manufacturer if:

  • You design and produce the product yourself
  • You commission another business to produce the product to your specification
  • You put your own name, trade mark, or branding on a product (even if someone else made it)
  • You substantially modify a product before placing it on the market

You are an importer if:

  • You are established in the UK and you bring a product into Great Britain from outside the UK
  • The manufacturer is based outside the UK and has not appointed a UK-based authorised representative

You are a distributor if:

  • You make products available on the market but you are neither the manufacturer nor the importer
  • This includes retailers, wholesalers, and other intermediaries in the supply chain

If you are unsure which role applies to you for a particular product, the critical question is: who takes responsibility for placing that product on the GB market? If it is you, you carry the primary obligations.

Detailed obligations by role

The following snippets set out the specific obligations that apply to producers, distributors, and importers under current legislation.

The UK Responsible Person: a new role under PRMA 2025

The Product Regulation and Metrology Act 2025 introduces powers to require a UK Responsible Person (UKRP) for products placed on the GB market by overseas manufacturers. This addresses a gap in the current framework where products from non-UK manufacturers can reach consumers without any UK-based entity being accountable for their safety.

The UKRP requirement will affect you if:

  • You import products from manufacturers based outside the UK
  • You are a non-UK manufacturer selling directly to UK consumers (for example, via an online marketplace)
  • You are considering offering UKRP services to overseas manufacturers

PRMA 2025 is an enabling Act. The detailed requirements for the UK Responsible Person, online marketplace duties, and other new obligations will be set out in secondary legislation (statutory instruments) that has not yet been made as of February 2026.

Businesses should monitor GOV.UK for consultations and new regulations. Existing obligations under the General Product Safety Regulations 2005 remain fully in force.

What happens when things go wrong

Understanding your supply chain role becomes especially important when a safety issue arises. The obligations to notify OPSS, initiate a recall, or take corrective action fall on different parties depending on their role:

  • Manufacturers carry the primary obligation to investigate safety concerns, notify OPSS, and initiate corrective action including recalls
  • Importers must notify OPSS if they become aware of a safety risk and must cooperate with the manufacturer on corrective action. If the manufacturer cannot be contacted or refuses to act, the importer may need to take independent action
  • Distributors must stop supplying a product they know or suspect is unsafe, and must notify the manufacturer or importer and cooperate with enforcement authorities

Under the Consumer Protection Act 1987, strict liability for defective products can extend to the producer, own-brander, importer, and (as a fallback) any supplier who cannot identify their own supplier. This means every business in the chain has an interest in maintaining clear records of who supplied what to whom.

Official guidance and legislation