GPSR in Northern Ireland, not in Great Britain
10 min readRepresenta GmbH
Since December 2024 the GPSR applies in Northern Ireland, while Great Britain keeps its 2005 rules. Who you need in each market and why GB is not enough.
You make consumer products outside Europe and sell them in Germany, in England and to retailers in Belfast. For product safety, the UK is two markets: the EU General Product Safety Regulation (GPSR) applies in Northern Ireland, while Great Britain keeps its own rules from 2005. Here is who you need in each market, why a company in Great Britain does not cover Northern Ireland, and what the planned UK reform changes.
Why the GPSR applies in Northern Ireland but not in Great Britain
Great Britain (England, Scotland and Wales) and Northern Ireland form one country, but product safety law splits along the Irish Sea. The UK regulator, the Office for Product Safety and Standards (OPSS), states that the General Product Safety Regulation (EU) 2023/988 (opens in a new tab) (GPSR) superseded the General Product Safety Regulations 2005 in Northern Ireland on 13 December 2024, while the 2005 Regulations continue to apply in Great Britain (OPSS guidance for Northern Ireland (opens in a new tab)).
No single article says so. We derive it from three provisions:
- Windsor Framework, Article 5(4): the EU acts listed in Annex 2 apply in the UK in respect of Northern Ireland; section 8 of Annex 2 lists the former General Product Safety Directive 2001/95/EC.
- Windsor Framework, Article 13(3): a reference to an EU act means that act as amended or replaced.
- Article 50(2) GPSR: references to the repealed Directive are construed as references to the GPSR.
The Commission’s Blue Guide adds the reading rule: where EU product law applies in Northern Ireland, “the EU” includes Northern Ireland and “the United Kingdom” means Great Britain only (section 2.9.6).
GPSR and the UK compared: EU, Great Britain, Northern Ireland
Where the three markets differ for consumer products; sector law, for example for toys or electrical equipment, comes on top:
| Topic | EU | Great Britain | Northern Ireland |
|---|---|---|---|
| Consumer product safety law | GPSR, since 13 December 2024 | General Product Safety Regulations 2005 | GPSR, since 13 December 2024 |
| Local presence required | Economic operator in the EU (Art. 16(1) GPSR) | No general duty; the producer is the UK manufacturer, else its UK representative, else the UK importer (reg. 2) | Economic operator in Northern Ireland or the EU |
| Is a company in Great Britain enough? | No (Blue Guide 2.9.5.2) | Yes | No: goods from Great Britain count as imported (Blue Guide 2.9.6) |
| Details on the product | Manufacturer and Responsible Person, postal and electronic address (Art. 9(6), 16(3)) | Producer’s name and address, product reference, where reasonable (reg. 7(4)(a)) | As in the EU |
| Online listing | Details under Art. 19 GPSR | No product safety listing duty yet | As in the EU |
| CE-marked products | CE | UKCA or CE in most sectors | CE, or CE with UKNI; not UKCA |
UKCA (UK Conformity Assessed) is the British marking; UKNI is added to CE when a Northern Ireland notified body has assessed the product. Your EU setup already does most of the work for Northern Ireland, while Great Britain needs a plan of its own.
Northern Ireland: what you need to do
OPSS calls the role from Article 16 GPSR the “responsible economic operator”; in the EU it is usually called the Responsible Person. Our article on who can be your GPSR Responsible Person explains the options.
- Check the scope: consumer products, new or used, supplied in the course of a commercial activity (OPSS detailed guidance, section 2). Borderline cases are in our GPSR guidelines article.
- Appoint one operator in the EU or Northern Ireland. OPSS confirms that one operator can serve both markets, whichever of the two it is established in (section 3): manufacturer, Authorized Representative with a written mandate, importer or, as a fallback, a fulfilment service provider.
- Make sure “established” is real: a registered office, headquarters or permanent place of business, not simply a PO box (section 3).
- Label the product with the operator’s name, postal and electronic address on the product, packaging, parcel or an accompanying document (Article 16(3) GPSR; see our label matrix).
- Update every listing aimed at Northern Ireland with the details of Article 19 GPSR.
- Agree who reports dangerous products and accidents through the Safety Business Gateway, which OPSS also names for Northern Ireland (sections 2 and 5).
Shipping from Great Britain to Northern Ireland
A product shipped from Great Britain to Northern Ireland is an imported product (Blue Guide, section 2.9.6), and a business in Northern Ireland that brings in goods from Great Britain is likely to be an importer (OPSS factsheet, question 3). A warehouse or distributor in England does not cover Belfast. Products placed on the Northern Ireland market before 13 December 2024 under the old rules may still be sold (Article 51 GPSR; OPSS detailed guidance, section 7).
Great Britain: what applies today
In Great Britain, the General Product Safety Regulations 2005 (opens in a new tab) remain the baseline for consumer products without specific sector rules; “the market” in them means the market of Great Britain (regulation 2).
- Producer: the UK manufacturer, or whoever presents itself as manufacturer by putting its name or mark on the product; for a manufacturer outside the UK, its UK representative, otherwise the UK-established person placing the product from abroad on the market (regulation 2).
- Safety: producers place only safe products on the market (regulation 5).
- Traceability: risk information for consumers and, where reasonable, the producer’s name and address and the product reference or batch on product or packaging (regulation 7).
- Notification: unsafe products are reported in writing to the enforcement authority, usually local trading standards (OPSS guidance for Great Britain (opens in a new tab), sections 5 and 7).
There is no general duty to appoint a UK Responsible Person for consumer products. In practice, your UK importer or representative carries the producer’s duties and puts its address on the product. Where marking each item is not yet reasonable, OPSS accepts the importer’s address on documents accompanying the batch, but only until 31 December 2027.
UK reform: announced, not in force
The Product Regulation and Metrology Act 2025 (opens in a new tab), which received Royal Assent on 21 July 2025, lets the government make product regulations, including rules for online marketplaces and for the appointment of authorized representatives (sections 1 and 2).
From 31 March to 23 June 2026, OPSS and the Department for Business and Trade consulted on the UK’s new product safety framework (opens in a new tab) to modernize the regime built on the 2005 Regulations. Proposals relevant to sellers from abroad:
- Producer: also the overseas seller in distance sales where there is no UK manufacturer, representative or importer.
- UK-based responsible person: considered only for some high-risk products (proposal A9).
- Online listings: seller and producer details, product identifier, warnings and markings (proposal A13).
- Digital labels as the default in Great Britain (proposal A12).
- Scope: UK-wide, taking account of the Windsor Framework.
Practical example: a U.S. kitchenware brand in the EU and the UK
A U.S. brand sells non-electric kitchen tools, GPSR products without CE marking, through four channels:
| Channel | Local role | What the brand arranges |
|---|---|---|
| EU marketplace, stock in Germany | EU Authorized Representative as Responsible Person | Written mandate; its details on packaging and listings |
| Own shop, parcels from the U.S. to Belfast | The same representative | Northern Ireland included in the mandate; same details |
| UK distributor in Manchester supplies shops in Great Britain | The distributor, as importer and producer (reg. 2) | Its name and address on product or packaging |
| The distributor ships a pallet to a Belfast retailer | The EU representative; the retailer is importer | Details of both on the units (Art. 11(3), 16(3) GPSR) |
One mandate covers the EU and Northern Ireland; Great Britain runs through the distributor. We recommend fixing the label text for all three markets before the first print run.
Common mistakes when selling in the EU and the UK
- Treating the GPSR as UK law. It applies in Northern Ireland only.
- Assuming UK sellers are exempt. For the EU and Northern Ireland, a business in Great Britain needs an operator established in the EU or Northern Ireland.
- Serving Belfast from England. Goods moved from Great Britain to Northern Ireland count as imported.
- Using a mailbox address. A PO box does not make an operator established (OPSS).
- Printing UKCA for Northern Ireland. The government’s marking table lists CE, or CE with UKNI; UKNI never stands alone.
- Treating proposals as law. A UK-based responsible person is a consultation idea, not a requirement.
Conclusion: one EU appointment, a separate plan for Great Britain
The GPSR in Northern Ireland follows the EU model: one operator in the EU or Northern Ireland, its details on product and listing, reports through the Safety Business Gateway. Great Britain needs a producer under the 2005 Regulations and a close watch on the reform. Our EU and UK market entry checklist puts both markets into one plan, and Authorized Representative or importer helps you choose the EU role.
Representa acts as your GPSR Responsible Person in the EU and, for CE-marked products, as your EU Authorized Representative, within the agreed scope and mandate; you remain the manufacturer. As we are established in the EU, the same appointment can also serve Northern Ireland. We also cover the United Kingdom as part of Representation; UKCA marking support belongs to Compliance.
Frequently asked questions
Does the GPSR apply in the UK?
Only in Northern Ireland. The EU General Product Safety Regulation (EU) 2023/988 has applied there since 13 December 2024 under the Windsor Framework. England, Scotland and Wales still apply the General Product Safety Regulations 2005, according to the UK Office for Product Safety and Standards.
Can a company in Great Britain be the responsible economic operator for Northern Ireland?
No. For Northern Ireland, the operator must be established in Northern Ireland or the EU (Article 16(1) GPSR; OPSS guidance, section 3). The Commission’s Blue Guide treats Great Britain as outside the EU and goods shipped from Great Britain to Northern Ireland as imported (sections 2.9.5.2 and 2.9.6).
Do I need separate Responsible Persons for the EU and Northern Ireland?
No. OPSS states that a single responsible economic operator can be used for both the EU and Northern Ireland, whichever of the two it is established in (detailed guidance, section 3). Its details go on the product, packaging, parcel or an accompanying document (Article 16(3) GPSR).
Do I need a UK Responsible Person for consumer products in Great Britain?
Not under the General Product Safety Regulations 2005. Their duties fall on the producer: the UK manufacturer, else its UK representative, else the UK importer (regulation 2). The 2026 consultation considered a UK-based responsible person for some high-risk products; on 30 September 2026 the outcome was open.
What about products placed on the Northern Ireland market before 13 December 2024?
They may still be made available if they complied with the rules in force when they were placed on the market (Article 51 GPSR). OPSS confirms that no action is needed for them (detailed guidance, section 7). Units placed on the market later must meet the GPSR.
