Written for online shops in the UK selling on their own site or on marketplaces: direct-to-consumer brands, private-label and FBA sellers, dropshippers and subscription sellers.
The short version
- Check whether the law treats you as producer.Own-branding goods, or importing them when the maker is not in the UK, puts the producer's duties on you, whatever the supplier says.
- Hold the safety paperwork before you list.Get the supplier's Declaration of Conformity and test reports, and the marking your category needs. Make the paperwork a condition of payment.
- Act at once on an unsafe product.Stop selling on every channel, tell Trading Standards or OPSS straight away, recall it from buyers and tell your insurer.
An online shop rarely makes what it sells, but the law often treats it as if it did. A business that puts its own brand on goods, or imports them when the manufacturer is not in the UK, takes on the producer's duties. Dropshippers and white-label sellers are usually in that position, whatever the supplier's paperwork says.
Only safe products may be supplied
Producers (the manufacturer, an own-brander, or the importer where the manufacturer is not in the UK) must give warnings and traceability (name, address, batch), monitor their products and recall them. Distributors must not supply what they know or should presume is unsafe. Both must notify the enforcement authority forthwith on finding a product unsafe. This applies in Great Britain. As of Oct 2026.
General Product Safety Regulations 2005 (SI 2005/1803), including reg 9
Strict liability for defects
Strict liability for defective products falls on the producer, an own-brander and whoever imported the product into the UK. A supplier who cannot name its own supplier or the importer within a reasonable time of a request is liable too. As of Oct 2026.
Consumer Protection Act 1987 s.2(2) and (3)
Markings: UKCA and CE
Where the product regime requires a mark (toys, electrical equipment, radio equipment, PPE, machinery), use UKCA or CE. Great Britain recognises CE marking indefinitely for most of these regimes; Northern Ireland needs CE. The importer's name and UK address go on the product or its packaging. As of Oct 2026.
Listings for Northern Ireland and EU buyers
Since 13 December 2024, products sold to Northern Ireland or EU consumers need an EU-established responsible economic operator. Each online listing must show the manufacturer, the responsible person, a product identifier, an image and any warnings. As of Oct 2026.
Regulation (EU) 2023/988 (General Product Safety Regulation) Arts 16 and 19
The government extended CE recognition in GB indefinitely for most regimes in 2023, so relabelling is often wasted work.
Category rules that catch online sellers
- Cosmetics: a GB Responsible Person, a product information file, a safety report signed by a qualified safety assessor, SCPN notification before the product goes on sale, and an English label with the Responsible Person's GB address, ingredients, batch and durability. Northern Ireland and EU sales need an EU Responsible Person and CPNP notification instead.
- Toys: technical file, Declaration of Conformity, marking and age warnings. Small parts and magnets cause most listing removals and recalls.
- Electricals: UK mains plugs to BS 1363. Connectable products must meet the PSTI security regime: no universal default passwords, a published way to report vulnerabilities, and a stated minimum security update period.
- Food supplements: only authorised health claims, authorisation for novel foods (CBD included), and registration as a food business with your local authority at least 28 days before trading. As of Oct 2026.
- Textiles and furniture: fibre names and percentages on textiles, and fire-safety labels on upholstered furniture.
- Electrical waste (WEEE): if you import electrical goods or sell them under your own brand, you are a WEEE producer and join a compliance scheme, or register directly with the regulator if you place under 5 tonnes a year on the market. As a seller you also offer free like-for-like take-back or join the Distributor Take-back Scheme and tell customers where to recycle. As of Oct 2026.
- Batteries: selling 32 kg or more of portable batteries a year means taking back waste portable batteries free of charge. As of Oct 2026.
Packaging: are you a producer?
Packaging EPR applies if your turnover is over £1 million and you handle over 25 tonnes of packaging a year, counting own-brand packaging, the mailers, boxes and void fill you add, and filled packaging you import. Small producers (£1 million to £2 million and over 25 tonnes, or over £1 million and 25 to 50 tonnes) report once a year by 1 April and pay no waste management fees. Large producers (over £2 million and over 50 tonnes) report twice a year, by 1 October and 1 April, pay waste management fees invoiced by PackUK and meet recycling obligations with PRNs or PERNs. Every producer registers through the Report Packaging Data service. As of Oct 2026.
If you find a product is unsafe
- Stop selling.Take the listing down on every channel.
- Notify.Tell Trading Standards or OPSS forthwith.
- Recall.Contact the customers who bought it and get the product back.
- Tell your insurer.Notify the insurer at once, admit nothing, and keep batch and supplier records so the claim can pass upstream.
Make the supplier's Declaration of Conformity and test reports a condition of payment, and ask for a product liability indemnity backed by insurance that names you. Getting them after a listing is pulled is much harder.
Asked in Greymill
In Great Britain, warnings, traceability (name, address, batch), monitoring and recalls are your job. You are also liable for defects even without fault, whatever the factory's paperwork says.
Hold before you list:
Declaration of Conformity and test reports
UKCA or CE mark: GB recognises CE indefinitely for most regimes (As of Oct 2026)
Importer's name and UK address on the lamp or packaging
UK mains plugs to BS 1363
Electrical waste: own-brand electricals make you a WEEE producer. Join a compliance scheme, or register directly if you put under 5 tonnes a year on the market (As of Oct 2026).
Put it in the contract: make that paperwork a condition of payment, with a product liability indemnity backed by insurance that names you. Once a listing is pulled, they are much harder to get.
LEO can draft those supplier terms.
Ask it about your own business
Paste this into Greymill with your own figures, and Rules & Licensing works it through for your business.
I run an online shop in the UK. I sell [product category] that I [import, own-brand, dropship or buy from a UK wholesaler]. Tell me whether I count as the producer or importer, list the safety documents, markings and registrations I need before listing, and check whether I am a packaging producer: turnover [£], packaging handled [tonnes a year].
More for online retail and ecommerce in the UK
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- What your returns policy can say, and what the law has already decidedOnline customers have a right to cancel and a separate right to reject faulty goods, so write terms that match both and refund disputes stop costing you.Read the lesson
- Staffing the Christmas peak with agency pickers, temps and freelancersBlack Friday to the January returns needs extra hands: the agency, pay, safety and freelancer rules that apply to an online shop's peak team.Read the lesson
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Open the interactive lesson · Every online retail and ecommerce lesson · What Greymill knows about the trade
Sources
The primary sources behind this lesson, checked Oct 2026.
- regs 5, 7, 8 and 9 (Product safety, markings and category rules)
- Product Regulation and Metrology Act 2025, ss. on online marketplaces (Product safety, markings and category rules)
- Announcement, 1 Aug 2023 (Product safety, markings and category rules)
- Arts 16 and 19; Art 52 (Product safety, markings and category rules)
- Responsible person; product information file; notification (Product safety, markings and category rules)
- technical file, DoC, marking, warnings (Product safety, markings and category rules)
- Online marketplace operators (Packaging EPR, WEEE and batteries)
- Reporting deadlines (Packaging EPR, WEEE and batteries)
- Base fees table (Defra, June 2025) (Packaging EPR, WEEE and batteries)
- regs 43 to 46 (distributors); small producer registration (Packaging EPR, WEEE and batteries)
- reg 36 (Packaging EPR, WEEE and batteries)
- When you need to register (Packaging EPR, WEEE and batteries)
- Consumer Protection Act 1987 s.2(2) and (3) (Insurance and product liability)
- Limitation Act 1980 s.11A(3) (Insurance and product liability)
- Overview; fines (Insurance and product liability)
- HSE40 page 4 family-business and sole-owner exemptions; page 1 overseas visits (Insurance and product liability)
- regs 34(5), (9), (11), (12); reg 35 (Hard cases: returns, products and marketing)
- s.29(2) (Hard cases: returns, products and marketing)
- reg 28(1)(b) (Hard cases: returns, products and marketing)
- Sch 20 (Hard cases: returns, products and marketing)
- reg 9; CPA 1987 s.2(2) (Hard cases: returns, products and marketing)
- Part 4 Chapter 2; commencement regulations (Pitfalls that embarrass the product)
- IOSS scope (Pitfalls that embarrass the product)
- s.22(3) (Pitfalls that embarrass the product)
- GOV.UK, "Complete a road consignment note" (Contract red flags)