Consumer Goods Compliance
Across Every Market You Sell Into.

Regulation (EU) 2023/988 became binding on 13 December 2024, replacing the General Product Safety Directive 2001/95/EC. The GPSR applies to all consumer products not covered by more specific EU product safety legislation and introduces several significant new requirements. The most operationally immediate is the mandatory EU Responsible Person: every product placed on the EU market must display the full name and physical postal address of a designated EU Responsible Person who acts as the contact point for market surveillance authorities. The Responsible Person can be the manufacturer, authorised representative, importer, distributor, or a fulfillment service provider - but they must be legally established in the EU and their details must appear on or with the product.

Online marketplaces are separately obligated under Article 22 to register with the EU Safety Gate portal, provide manufacturer and representative details on product listings, display safety warnings and product images, and cooperate with removal requests for unsafe products. Economic operators must also implement internal complaint-handling processes and product traceability systems. The GPSR does not replace sector-specific legislation such as the Toys Directive, Low Voltage Directive, or Machinery Regulation - those continue to apply to their product categories with GPSR filling in for products not covered by specific legislation.

REACH Regulation (EC) 1907/2006 is the EU's comprehensive chemicals regulation. Its most direct impact on consumer goods manufacturers is through the SVHC Candidate List - the list of Substances of Very High Concern maintained by ECHA. As of February 2026, the list contains 253 substances following the addition of n-Hexane and BPAF. If any article in your product contains an SVHC at a concentration above 0.1% by weight, two obligations arise: you must provide sufficient information to your supply chain customers to allow safe use; and if you are supplying to consumers, you must provide that information free of charge within 45 days of a consumer request. Source: ECHA, Candidate List.

The key compliance challenge is that the list is updated twice per year by ECHA, and each new addition creates obligations for all products containing that substance - regardless of when the product was designed or last reviewed. A product that was fully REACH-compliant in January may have new information obligations by July if a substance present in one of its components is added to the Candidate List. Maintaining current compliance requires a continuous SVHC monitoring process linked to ECHA's update calendar, not a point-in-time assessment.

Following the UK Product Safety and Metrology (Amendment) Regulations 2024, which came into force on 1 October 2024, CE marking is accepted indefinitely in Great Britain for 21 product regulations - including toys, radio equipment, machinery, low voltage electrical equipment, pressure equipment, and several others. The previous deadline of 31 December 2024 for mandatory UKCA compliance was removed. For most consumer product categories that previously required CE marking, CE marking remains a valid route to UK market access without requiring a separate UKCA conformity assessment. Source: UK Government, CE Marking Recognition Guidance.

UKCA marking remains available as a parallel route and may be required for certain product categories where CE marking is not recognised, or where a manufacturer chooses to use UK-approved bodies. Northern Ireland is a separate case - under the Windsor Framework, Northern Ireland follows EU product rules, and CE marking (not UKCA) is required for products placed on the Northern Ireland market. The UK Product Regulation and Metrology Act 2025 (Royal Assent 21 July 2025) creates a flexible framework enabling the UK to align with EU requirements or introduce UK-specific rules through secondary legislation - the direction of future UK product regulation will depend on implementing measures developed under this Act.

The Consumer Product Safety Improvement Act (CPSIA) 2008 requires that all consumer products primarily designed or intended for children aged 12 and under be tested by a CPSC-accepted accredited third-party laboratory. Manufacturers must issue a Children's Product Certificate (CPC) - a written document certifying that the product conforms to all applicable children's product safety rules, referencing the specific test reports and standards. Tracking labels identifying the manufacturer, production location, and date of manufacture are required on children's products and their packaging. Re-testing must occur whenever there is a material change in product design, component sourcing, or manufacturing process.

CPSIA also sets specific substance limits: lead in surface coatings is limited to 90 ppm; total lead in substrate materials to 100 ppm; and phthalate concentrations in toys and childcare articles are restricted (DEHP, DBP, and BBP permanently banned at above 0.1%; DINP, DPENP, DHEXP, DCHP also banned in products that can be placed in a child's mouth). These requirements apply equally to imported children's products - CPSC has authority to detain imports at the US border and can require mandatory recalls for non-compliant products.

China Compulsory Certification (CCC) is mandatory for 109 products across 17 categories currently listed in China's CCC Catalogue - including electrical appliances, audio and video equipment, IT equipment, lighting products, children's products, and fire safety equipment. Products in the catalogue cannot be imported into or sold in China without a valid CCC certificate, and the CCC mark must be affixed to each product unit or its packaging. Source: China Certification, CCC Product List.

The certification process involves application to a CNCA-approved certification body, product sample testing by a designated laboratory, a factory quality inspection, and certificate issuance. CCC certificates are product-model specific - different models or significant design changes require separate certificates or certificate amendments. Annual surveillance audits are required to maintain certificate validity. CCC certificates have a validity period and must be renewed before expiry. Lead times from application to certificate issuance typically range from 3 to 9 months, depending on product complexity, laboratory scheduling, and factory inspection timing. Businesses planning Chinese market entry must account for this timeline at the product development stage.

Regulation (EU) 2024/1781 - the Ecodesign for Sustainable Products Regulation (ESPR) - entered into force on 18 July 2024, replacing and significantly expanding the Ecodesign Directive 2009/125/EC. Where the old Directive applied only to energy-related products, ESPR extends to almost all consumer and industrial goods. It introduces sustainability performance requirements covering durability, repairability, recyclability, recycled content, and carbon footprint, alongside a prohibition on destroying unsold consumer products (applying to large enterprises from July 2026). A key new mechanism is the Digital Product Passport (DPP), which will require products to carry machine-readable data linking to sustainability and compliance information - the DPP registry is due to become operational from July 2026.

The ESPR itself does not impose product-specific requirements directly - these come through delegated acts specifying requirements for particular product groups. The first delegated acts, expected to cover textiles and steel among the earliest categories, are anticipated from 2026, with transition periods of at least 18 months before obligations apply. This means most sector-specific ESPR obligations are expected to begin taking effect from 2027 or 2028 at the earliest for the first product groups, with broader coverage rolling out through the late 2020s. Consumer goods businesses should begin mapping their product portfolios against the ESPR framework now - the regulation is a significant structural change to EU product requirements, not a minor amendment.