{
  "type": "problem",
  "slug": "uk-and-eu",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/uk-and-eu/",
  "markdown": "https://www.conphora.com/solutions/problem/uk-and-eu.md",
  "title": "We sell in both the UK and the EU",
  "description": "Selling in Great Britain, Northern Ireland and the EU: the EU responsible person, CE recognition and UKCA in Great Britain, one technical file for both.",
  "answer": "Treat Great Britain, Northern Ireland and the EU as three markets. For the EU, the product needs an economic operator established in the Union under Regulation (EU) 2019/1020 and the General Product Safety Regulation, named on the product or parcel. Great Britain recognises the CE marking for many product rules alongside UKCA. Northern Ireland follows the EU product rules listed in the Protocol on Ireland/Northern Ireland, as amended.",
  "theme": {
    "id": "placing-on-market",
    "label": "Placing a product on the market"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "GPSR"
  ],
  "path": [
    "regulation-library",
    "knowledge-articles"
  ],
  "trigger": "A business established in the UK starts shipping to EU customers, or an EU business starts selling into Great Britain, and the labels, documents and contact details were made for one market only",
  "keep": null,
  "why": [
    {
      "text": "Since the United Kingdom left the Union, one product can face three sets of rules. In the EU, the deciding question is who answers for the product inside the Union. Regulation (EU) 2019/1020 says that products under the harmonisation acts listed in Article 4(5), among them the low voltage, EMC, radio, toy, machinery and RoHS rules, may be placed on the market only if an economic operator established in the Union is responsible for set tasks (Article 4(1)). That operator is a manufacturer established in the Union, an importer where the manufacturer is not, an authorised representative with a written mandate, or a fulfilment service provider established in the Union where none of the others is (Article 4(2)). Its tasks are to verify and keep the declaration and documentation, answer reasoned requests from authorities, report risks and cooperate on corrective action (Article 4(3)), and its name and contact details go on the product, packaging, parcel or an accompanying document (Article 4(4)).",
      "sources": [
        2
      ]
    },
    {
      "text": "The General Product Safety Regulation extends the same rule to consumer products. A product covered by it may not be placed on the market without an economic operator established in the Union responsible for those tasks, and that operator also checks regularly that the product matches its technical documentation and labelling (Article 16(1) and (2)). Online offers to EU consumers are covered as soon as they are targeted at the Union (Article 4), and must show the manufacturer, the responsible person where the manufacturer is outside the Union, product identifiers and warnings in the language the Member State determines (Article 19).",
      "sources": [
        1
      ]
    },
    {
      "text": "Northern Ireland follows a separate rule. Under Article 5(4) of the Protocol on Ireland/Northern Ireland in the Withdrawal Agreement, the provisions of Union law listed in Annex 2 apply to and in the United Kingdom in respect of Northern Ireland. Annex 2 lists the Union's product legislation; under the heading on goods in general it still names, in the consolidated text of 3 February 2026, Directive 2001/95/EC on general product safety, Regulation (EC) No 765/2008 and Decision No 768/2008/EC. Article 13(3) reads a reference to a Union act as that act as amended or replaced. Since Joint Committee Decision No 1/2023, Article 13(3a) lets the United Kingdom, under strict conditions and a set procedure, notify that a listed act shall not apply as amended or replaced by a specific later Union act. Whether and how the General Product Safety Regulation applies in Northern Ireland therefore has to be checked for the current position.",
      "sources": [
        3
      ]
    },
    {
      "text": "Great Britain sets its own rules, described by the UK Department for Business and Trade. Its guidance, last updated on 21 August 2026, explains that the UK continues to recognise the CE marking, alongside or in place of UKCA, for many product regulations under the Product Safety and Metrology (Amendment) Regulations 2024, and offers a Fast-Track UKCA route based on EU requirements. UK Approved Bodies can only certify for UKCA; EU notified bodies certify against EU requirements, which can be used in Great Britain under CE recognition. A UKCA marking may be placed on a label or accompanying document until 11pm on 31 December 2027, an importer established in the UK puts its details on the product, and instructions must be in easily understandable English. Documentation is typically kept for 10 years after each product is placed on the Great Britain market.",
      "sources": [
        4
      ]
    },
    {
      "text": "A UK business selling into the EU therefore needs an EU-established operator, EU labels and EU declarations, while an EU business selling into Great Britain needs a UK importer or representative and a check of the UK sector rule for its product. The technical evidence behind both can be the same file.",
      "sources": [
        2,
        4
      ]
    }
  ],
  "steps": [
    {
      "name": "Map the three markets separately",
      "text": "Write down where each product goes: Great Britain (England, Scotland and Wales), Northern Ireland, and EU Member States. The rules, the marking choices and the economic operator you need differ between them, so one product can need different label content per route.",
      "item": "regulation-library"
    },
    {
      "name": "Give EU sales an operator established in the Union",
      "text": "A manufacturer established only in Great Britain is not established in the Union. Appoint an importer, an authorised representative with a written mandate, or in some cases a fulfilment service provider in the EU, and put its name and postal and electronic address on the product, packaging, parcel or an accompanying document."
    },
    {
      "name": "Choose the marking route for Great Britain",
      "text": "The UK government states that many UK product regulations recognise the CE marking alongside or in place of UKCA, and that UK Approved Bodies certify only for UKCA. Check the sector regulation for your product. A UK importer's name and address goes on goods imported into Great Britain."
    },
    {
      "name": "Keep one technical file that serves both declarations",
      "text": "The test reports, risk analysis and design documents can serve both markets. The EU declaration of conformity cites the EU acts; a UK declaration cites UK legislation or the recognised EU rules. Keep each declaration current and the file available for the period each regime sets, typically 10 years."
    },
    {
      "name": "Adapt the language and the online listing per market",
      "text": "EU offers show the manufacturer, the EU responsible person where the manufacturer is outside the Union, product identifiers and warnings in the language each Member State determines. Instructions for Great Britain must be in easily understandable English."
    }
  ],
  "documents": [
    {
      "name": "The written mandate or contract with the EU economic operator",
      "from": "The manufacturer and the EU operator",
      "ground": "Regulation (EU) 2019/1020 Articles 4(2) and 5; GPSR Article 16(1)"
    },
    {
      "name": "EU declaration of conformity citing the EU acts, where a harmonisation act applies",
      "from": "The manufacturer",
      "ground": "The applicable Union harmonisation act"
    },
    {
      "name": "UK declaration of conformity for Great Britain, where the UK regulation requires one",
      "from": "The manufacturer or its UK authorised representative",
      "ground": "UK product regulations as described by the Department for Business and Trade"
    }
  ],
  "risks": [
    {
      "title": "No EU operator, no placing on the EU market",
      "text": "A product covered by the GPSR may not be placed on the market unless an economic operator established in the Union is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020 (GPSR Article 16(1)); the same applies to products under the acts listed in Article 4(5) of that regulation.",
      "source": 1
    },
    {
      "title": "Online offers to EU consumers count as EU sales",
      "text": "An offer is deemed to be made available on the EU market if it is targeted at consumers in the Union, which is the case where the operator directs its activities by any means to one or more Member States (GPSR Article 4).",
      "source": 1
    },
    {
      "title": "Enforcement in Great Britain",
      "text": "The UK government states that an economic operator that fails to cooperate with an enforcement body over non-conforming UKCA or CE products must withdraw or recall them and may be liable for a fine and imprisonment.",
      "source": 4
    }
  ],
  "faq": [
    {
      "q": "Can our UK company be the EU responsible person?",
      "a": "No. The economic operator must be established in the Union: a manufacturer established there, an importer where the manufacturer is not, an authorised representative with a written mandate, or an EU fulfilment service provider where no other is established (Regulation (EU) 2019/1020 Article 4(2))."
    },
    {
      "q": "Can we sell CE-marked products in Great Britain?",
      "a": "The UK government states that the UK continues to recognise the CE marking, alongside or in place of UKCA, for many product regulations under the Product Safety and Metrology (Amendment) Regulations 2024. The sector regulation for your product has to be checked."
    },
    {
      "q": "Is a UK Approved Body certificate valid for the EU?",
      "a": "According to the UK government's guidance, UK Approved Bodies can only certify products for UKCA marking. Where an EU act requires a notified body, the certificate has to come from an EU notified body."
    },
    {
      "q": "What about Northern Ireland?",
      "a": "The Union law listed in Annex 2 to the Protocol on Ireland/Northern Ireland applies in Northern Ireland (Article 5(4)), and a reference to a Union act is read as that act as amended or replaced (Article 13(3)), subject to the procedure in Article 13(3a) added by Joint Committee Decision No 1/2023. Check the current position for your product; the UK government publishes a separate guide for Northern Ireland."
    },
    {
      "q": "Do we need two technical files?",
      "a": "The same evidence can support both. The UK guidance describes a technical file of test reports, design documents and risk assessments, and a UK declaration that may reference UK legislation or recognised EU product regulations."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    },
    {
      "title": "Agreement on the withdrawal of the United Kingdom from the European Union, Protocol on Ireland/Northern Ireland (consolidated text of 3 February 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02020W/TXT-20260203",
      "accessed": "2026-10-04"
    },
    {
      "title": "Placing UKCA or CE marked products on the market in Great Britain",
      "publisher": "UK Department for Business and Trade (GOV.UK)",
      "url": "https://www.gov.uk/guidance/placing-ukca-or-ce-marked-products-on-the-market-in-great-britain",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "no-eu-responsible-person",
    "new-eu-country",
    "sell-in-europe",
    "label-no-eu-address",
    "language-requirements"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}