The four major consumer goods markets — the EU, UK, US, and China — share a broad objective of ensuring that products placed on the market are safe for consumers and the environment, but differ significantly in their regulatory structures, pre-market obligations, and enforcement mechanisms. The EU operates through a combination of the GPSR general safety framework and product-specific directives and regulations (CE marking legislation, RoHS, REACH), each with its own conformity assessment and documentation requirements. The UK largely mirrors the EU approach but has diverged following Brexit — CE marking is now accepted indefinitely for most product categories, but the Product Regulation and Metrology Act 2025 creates a framework for further divergence. The US takes a more fragmented approach with category-specific legislation under CPSC authority (CPSIA for children's products, CPSA more broadly) alongside FCC requirements for electronic products and state-level Proposition 65 obligations in California. China's framework centres on mandatory pre-market CCC certification for listed product categories, with China RoHS requirements for EEE products running in parallel.
Understanding where these frameworks converge and diverge is essential for any business selling consumer goods across multiple markets. The table below sets out the core obligations side by side.
Core Regulatory Comparison
| Requirement | EU | United Kingdom | United States | China |
|---|---|---|---|---|
| General product safety | GPSR (EU) 2023/988 — binding from 13 Dec 2024. EU Responsible Person mandatory. Online marketplace obligations under Article 22. | General Product Safety Regulations 2005 (retained); Product Regulation and Metrology Act 2025 framework — secondary legislation pending. CE marking accepted indefinitely for most product categories from Oct 2024. | Consumer Product Safety Act (CPSA); CPSC oversight. CPSIA for children's products — third-party testing and CPC mandatory. No single pre-market approval requirement for most non-children's categories. | Product Quality Law; Law on Protection of Consumer Rights and Interests. CCC certification mandatory for 109 product types across 17 categories before import, manufacture, or sale. |
| Market access marking | CE marking required for products covered by specific EU regulations (LVD, EMC, RED, Toy Safety, Machinery). Declaration of Conformity and technical file required. | CE marking accepted indefinitely for most categories (from 1 Oct 2024). UKCA marking available as alternative via UK-approved bodies. Northern Ireland follows EU rules under Windsor Framework. | No single mandatory product mark. FCC ID required for intentional RF emitters. UL mark voluntary but often required by retailers. No CPSC certification mark. | CCC mark (3C mark) mandatory on all CCC catalogue products — must be affixed before sale or import. China RoHS marking required for EEE products. |
| Chemical substance restrictions | REACH — 253 SVHC substances on Candidate List (Feb 2026); information obligations above 0.1% w/w. RoHS — 10 substances restricted in EEE. Toy chemicals under EN 71-3 and Toy Safety Regulation. | UK REACH — independent SVHC list (fewer entries than EU; managed by HSE). UK RoHS — equivalent restrictions to EU. Businesses must check both lists for dual-market products. | CPSIA — lead (100 ppm) and phthalate limits for children's products. California Prop 65 — 1,000+ chemicals, warning required for California sales. | China RoHS — 6 restricted substances in EEE, materials declaration required. GB 6675 — chemical migration limits for toys. GB 9685 — food contact materials. |
| Third-party testing | Required for CE marking in regulated categories. Notified Body involvement mandatory for higher-risk products. Test reports form part of technical file. | CE marking test reports accepted. UKCA requires testing by UK Approved Bodies for higher-risk products. Broadly equivalent framework to EU. | Mandatory for children's products (CPSIA) by CPSC-accepted lab. FCC testing by TCB for intentional RF emitters. Voluntary for most other categories unless specifically required. | Mandatory for all CCC-listed products by CNCA-designated laboratory. Annual surveillance audits required to maintain CCC certificate. |
| Online marketplace obligations | GPSR Article 22 — online marketplaces must register with Safety Gate, display Responsible Person details, cooperate with removal of unsafe products. Non-compliance is an Article 22 violation independent of product safety status. | UK Product Safety framework review ongoing under PRMA 2025. Current rules require marketplace compliance with general product safety obligations. | CPSC authority to require marketplaces to report and address unsafe products. INFORM Consumers Act 2023 requires high-volume third-party seller disclosures. | E-commerce platforms must verify sellers and products meet CCC requirements. Cross-border e-commerce subject to CBEC-specific import regulations. |
| Key 2026–2030 change | ESPR — destruction of unsold goods ban July 2026; Digital Product Passport operational July 2026. New Toy Safety Regulation (EU) 2025/2509 fully applies August 2030. | Secondary legislation under PRMA 2025 expected from 2026 — scope of UK-EU alignment vs divergence to be determined. | CPSC ongoing rulemaking on e-bikes, lithium battery products, and button cell batteries. Prop 65 list continues to expand. | CCC catalogue review and potential expansion to new product categories; China RoHS evolution ongoing. |
Product Safety Philosophy: GPSR vs CPSA vs China's Mandatory Certification
The most fundamental difference between the EU GPSR and the US CPSA approach is the role of pre-market documentation. Under the GPSR, every consumer product that enters the EU market must have a designated Responsible Person who holds the required technical documentation — there is no formal pre-market approval, but there is a mandatory accountability structure. Under the US CPSA, most non-children's products can be marketed without pre-market testing or documentation submission to CPSC — enforcement is primarily reactive, triggered by incident reports, consumer complaints, or targeted surveillance. China's CCC regime sits at the other extreme: mandatory third-party certification by a CNCA-designated body is required before any CCC-catalogue product can enter the Chinese market, and no product may be sold without the physical CCC mark affixed.
The UK, following Brexit, has moved away from automatic alignment with the EU system while maintaining broadly comparable outcomes. CE marking is accepted indefinitely, meaning UK market access does not require separate conformity assessment for most product categories — but the Product Regulation and Metrology Act 2025 creates authority for the UK to diverge. Businesses should monitor secondary legislation under this Act carefully, particularly for sectors such as toys, electrical equipment, and machinery where the EU has significant ongoing regulatory activity under the ESPR and the new Toy Safety Regulation.
Chemical Restrictions: REACH vs Prop 65 vs China RoHS
The EU REACH SVHC Candidate List and California Proposition 65 serve broadly similar purposes — identifying substances of concern and requiring manufacturers to communicate their presence to customers or consumers — but they operate through entirely different mechanisms. REACH is a regulatory obligation that applies at the point of supply: if a substance is on the Candidate List above 0.1% in an article, the supplier must notify customers. Proposition 65 is an exposure warning requirement: if a product exposes consumers to a listed chemical above safe harbour levels, a warning must be provided at the point of sale. A business that complies with REACH SVHC notification requirements is not automatically compliant with Prop 65, and vice versa. Both lists are updated regularly — REACH twice yearly, Prop 65 throughout the year — requiring ongoing monitoring programmes rather than one-time assessments.
China RoHS applies to the same six restricted substances as EU RoHS Phase 1 but uses a distinct materials declaration and marking format that has no equivalent in the EU system. A CE-marked product with a valid EU RoHS declaration must still carry a separate China RoHS materials declaration and the appropriate China RoHS mark to enter the Chinese market legally. This is one of the most common documentation gaps for businesses entering China from the EU or UK market.
Planning for Multi-Market Consumer Goods Compliance
Businesses selling consumer goods across all four markets face a compliance programme that spans four distinct legal systems with limited mutual recognition. EU CE marking is accepted in the UK (for now), but GPSR Responsible Person obligations are EU-specific. CCC certification for China has no recognition outside China. CPSIA testing obligations for the US are independent of any EU conformity assessment. Proposition 65 screening in California requires independent substance mapping against a list that now exceeds 1,000 chemicals. The common thread across all four markets is that compliance requires maintenance — not just initial assessment — because substance lists, enforcement priorities, and legislative frameworks are all actively evolving.
Selling consumer goods across multiple markets?
TGC's team provides multi-market consumer goods compliance assessments — covering GPSR Responsible Person requirements, REACH SVHC supply chain screening, CE and UKCA marking, CPSIA testing obligations, and China CCC management — with a prioritised action plan.
Talk to a Specialist Learn about audits