Amazon Product Compliance Requirements in the United Kingdom

Planning to sell on Amazon in the UK? In this guide, we explain what you must know about UKCA marking, CE marking, GPSR 2005, REACH and other compliance requirements for Amazon sellers shipping to the United Kingdom.

You will also learn how Amazon seller requirements can differ between Great Britain (England, Scotland, and Wales) and Northern Ireland.

Which regulations and standards must Amazon sellers in the UK comply with?

Companies selling products on Amazon in the United Kingdom must generally comply with UK product regulations covering safety, labelling, documentation, testing, and other requirements.

Here are some examples of UK regulations:

• The General Product Safety Regulations 2005
• REACH Regulation (EC) 1907/2006 – Articles
• The Toys (Safety) Regulations 2011
• Textile Labelling and Fibre Composition Regulation (EU) 1007/2011
• The Nightwear (Safety) Regulations 1985

Note that the regulations referencing the EU are not the actual EU regulations but the versions assimilated by the United Kingdom.

UKCA Marking

If you sell toys, electronics, PPE, machinery, or medical devices on Amazon in the UK, then UKCA marking is likely applicable. UKCA marking must be supported by documentation, such as:

• UK Declaration of Conformity
• Technical documentation
• Test reports
• Instructions

Amazon UK can request UK DoC, test reports, and label files to verify that your product is currently UKCA marked.

The General Product Safety Regulation 2005

The General Product Safety Regulation 2005 mandates that all products sold in the United Kingdom are safe. This regulation is of particular relevance to products not covered by product-specific UK regulations, such as those requiring UKCA marking.

In general, Amazon UK sellers must take the following steps:

1. Identify applicable safety standards

2. Arrange safety testing

3. Affix the UK GPSR 2005 labelling

4. Provide instructions (if necessary for the particular product)

In many cases, compliance with the GPSR 2005 is trivial. However, the process is more complex for something like a baby carrier or gym machine, which have inherent risks.

Amazon can request test reports, label files, and other information from sellers to demonstrate compliance with the GPSR 2005. This is more likely to occur if you sell children’s products, furniture, gym equipment, bikes, or other products with a higher risk level.

UK REACH

The UK REACH regulation sets restrictions for chemicals and heavy metals in all products sold in the United Kingdom. I know from experience that Amazon can request test reports demonstrating that a certain product is compliant with the regulation.

UK Food Contact Materials (FCM) Regulations

Coffee cups, lunch boxes, kitchen appliances, and other products made for contact with food or beverages must comply with UK food contact materials regulations.

Here are some examples:

• Food Contact Materials Framework Regulation (EC) 1935/2004
• Good Manufacturing Practice for FCM Regulation (EC) 2023/2006
• Plastic FCM Regulation (EU) 10/2011
• Restriction of Use of Certain Epoxy Derivatives in FCM Regulation (EC) 1895/2005
• Recycled Plastic FCM Regulation (EC) 282/2008
• Active and Intelligent FCM Regulation (EC) 450/2009
• Use of Bisphenol A in Varnishes and Coatings Regulation (EU) 2018/213
• Polyamide and Melamine Plastic Kitchenware from China and Hong Kong SAR (China) Regulation (EU) 284/2011
• The Materials and Articles in Contact with Food (England) Regulations 2012
• The Materials and Articles in Contact with Food (Wales) Regulations 2012
• The Materials and Articles in Contact with Food (Scotland) Regulations 2012

Compliance can be demonstrated by providing the required documentation:

• Declaration of Compliance (for some FCM)
• Lab test reports (substance content and migration)

These are also the documents that Amazon can request from UK sellers. Note that some UK FCM regulations also set labelling requirements.

Selling to Northern Ireland

Northern Ireland remains aligned with EU regulations for many products. If you ship to Northern Ireland, then compliance with EU regulations and standards is likely necessary.

For example, Amazon has required UK sellers to demonstrate compliance with the EU General Product Safety Regulation (which is quite different from the UK GPSR 2005) on the basis that they were selling to Northern Ireland.

Further, UKCA marking is not accepted for products sold in Northern Ireland. Instead, companies selling via Amazon to Northern Ireland may need to affix the CE mark (if required for their products).

FAQ

Do UK sellers need to comply with EU compliance requirements?

Amazon sellers shipping to Great Britain (England, Scotland and Wales) must generally comply with UK regulations for consumer products.

As mentioned above, you will likely need to comply with EU regulations and standards if you sell in Northern Ireland.

Can UK sellers opt out of selling to Northern Ireland?

Yes, it should be possible to opt out of shipping to Northern Ireland and thus avoid the need to comply with EU regulations (in addition to UK regulations).

Source: Amazon Seller Central UK (Link)

How does Amazon check if products comply with UK safety requirements?

Amazon UK applies the same methods to check compliance documentation in other markets. They generally request declarations, test reports, and label files.

The exact documentation requirements depend on what is mandated by the applicable UK regulations.

Can CE marked products be sold on Amazon in the UK?

The UK accepts CE marking for certain products. As Amazon generally does not make up their own rules but reflects those in the United Kingdom, it is likely that Amazon is aware of this and accepts that products sold on Amazon in the UK are CE marked as long as they belong to the listed categories.

Which products require UKCA marking when selling on Amazon?

Here are some examples of products which require UKCA marking when selling on Amazon in the UK:

• Toys
• Electronics
• Machinery
• PPE (i.e., sunglasses and protective gloves)
• Medical devices

Do I need an authorised representative when selling on Amazon UK?

Not in the same sense as in the EU, where it is required for all Amazon sellers to have an EU-authorised representative if they sell directly to consumers in the EU without having a company there.

That said, the concept of “authorised representatives” still exists in the UK and can be required for certain products.

Note: Contains public sector information licensed under the Open Government Licence v3.0.