Product compliance for imports (2026): CE marking, UKCA, GPSR and North American rules

Sample approved, price negotiated, freight booked: one question often comes too late. Is this product allowed to be sold on your market? An authority, a marketplace or a distributor can ask you to prove it at any time.

This guide explains the logic of compliance for an importer selling in the EU, the UK and North America. It does not replace the advice of a lawyer or a laboratory on a given product. The acronyms are also defined in the import glossary.

Who is responsible: manufacturer, importer or authorized representative?

In the EU, the importer is the person established in the Union who places a product from a third country on the market. For the Blue Guide, the European Commission's rulebook on product rules, this is not a mere reseller: the importer must make sure the manufacturer has fulfilled its obligations.

The most surprising point: placing a product on the market under your name or your brand makes you its manufacturer. That is the case with private label ordered in China: you carry all the manufacturer's obligations, even without ever having seen the production line.

The importer's own obligations

Even when the factory is the manufacturer, the importer must, under sector-specific texts as well as the GPSR:

• verify that the conformity assessment has taken place, that the technical documentation exists, and that the markings, type, batch or serial number and the manufacturer's address appear on the product;
• state its own name, brand and address on the product (failing that, on the packaging or a document), without hiding those of the manufacturer;
• provide the instructions and safety information in a language understood in the country of sale;
• keep the declaration for 10 years, be able to produce the technical documentation and identify suppliers and professional customers for 10 years;
• in case of doubt, do not sell; in case of risk, act and alert the authorities.

According to the Blue Guide, the importer is not required to systematically have third-party testing done, but nothing prevents it: it is often the only way to know whether production matches the tested sample.

The economic operator established in the EU

Since July 16, 2021, Article 4 of Regulation (EU) 2019/1020 on market surveillance requires an operator established in the Union for a list of harmonized products: toys, electrical equipment, radio equipment, personal protective equipment (PPE), machinery, construction products…

This operator is the manufacturer if established in the EU, otherwise the importer, otherwise a representative designated in writing. Failing that, it is the fulfillment service provider: the fulfillment warehouse that stores, packs, labels or ships without owning the products. A postal service, a parcel delivery company or a freight carrier cannot hold this role.

The GPSR extends this requirement to the consumer products it covers (Article 16). The operator keeps the documents available, regularly checks the product and its labeling, and cooperates with the authorities. Its contact details appear on the product, the packaging, the parcel or a document: postal address for harmonized products, postal and electronic addresses under the GPSR.

CE marking: the logic in six steps

CE marking is neither a quality label nor a public authorization. It is a declaration by the manufacturer: the product complies with the European texts that require it. It is mandatory for the products covered by those texts and prohibited on the others.

Two texts are about to change: Regulation (EU) 2023/1230 replaces the Machinery Directive on January 20, 2027, and Regulation (EU) 2025/2509 replaces the Toy Safety Directive on August 1, 2030. The Low Voltage Directive covers 50 to 1,000 V AC and 75 to 1,500 V DC. The EMC Directive excludes radio equipment, which falls under the RED (Radio Equipment Directive). RoHS (Restriction of Hazardous Substances) applies only to electrical and electronic equipment.

A product often falls under several texts. The process stays the same:

1. Identify all applicable texts.
2. Find the harmonized standards (European "EN" standards) published in the Official Journal of the EU: a product that complies with them is presumed compliant with the requirements they cover.
3. Choose the procedure: self-assessment when the text allows it, otherwise a notified body, which you can find in the Commission's NANDO database (New Approach Notified and Designated Organisations). Its four-digit number follows the CE marking when it is involved in production control, not for a simple type examination.
4. Build the technical documentation: description, intended use, design, risk analysis, test reports, standards applied, product versions.
5. Sign the EU declaration of conformity: product, manufacturer, texts and standards (with their version), notified body if any, date. A single declaration covers all texts.
6. Apply the marking, visible, legible and indelible, at least 5 mm unless a rule says otherwise.

Documentation and the declaration are kept for 10 years after each unit is placed on the market, unless the text sets a different period.

Chemicals and food contact: the rules outside the CE

For all items, electrical or not (textiles, toys, plastics, jewelry, leather…), chemical restrictions come first from REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), Regulation (EC) No. 1907/2006:

• its Annex XVII limits or bans certain substances in articles, including imported ones;
• above 0.1% by mass of a substance of very high concern (SVHC, Substance of Very High Concern) on the candidate list, the supplier informs its customers and answers a consumer who asks within 45 days;
• Regulation (EU) 2019/1021 on persistent organic pollutants (POPs) covers other substances.

Food contact articles (dishes, utensils, water bottles) fall under Regulation (EC) No. 1935/2004: they must not transfer their constituents to food in dangerous quantities. For plastics, Regulation (EU) No. 10/2011 sets the authorized substances and migration limits, and requires a declaration of conformity at every stage of the chain, retail excluded.

GPSR: the foundation for consumer products

Regulation (EU) 2023/988 on general product safety has applied since December 13, 2024 and replaces Directive 2001/95/EC. Its principle: only safe products may be placed on the market.

It first covers consumer products with no specific regulation: candles, furniture, decorative items… For CE-marked products, it only covers the risks their own text does not address, and its operator obligations do not apply: the sector-specific text sets them. Its rules on online sales and accidents, however, apply to all.

For the products it fully covers, the key requirements are:

• risk analysis and technical documentation by the manufacturer, kept for 10 years; the importer keeps a copy available to authorities for 10 years;
• identification: visible type, batch or serial number, plus the name, brand and postal and electronic addresses of the manufacturer and the importer;
• public complaint channels and a register of complaints and recalls;
• serious accidents reported without undue delay via the Safety Business Gateway portal.

An online offer targeting EU consumers places the product on the European market, even from Asia. The listing then shows the manufacturer's contact details and, if it is outside the Union, those of the person responsible in the EU, a photo and the product identification, and the warnings in the country's language. Each Member State sets the penalties.

UK: UKCA and CE

A distinction must be made between Great Britain (England, Scotland, Wales) and Northern Ireland.

For Great Britain, the government continues to recognize CE marking, alongside or instead of UKCA marking (UK Conformity Assessed), for many products, under the Product Safety and Metrology (Amendment) Regulations 2024. Its official guide, updated on August 21, 2026, flags sector-specific rules (construction, medical devices, rail…).

• "Fast-Track UKCA" allows UKCA to be applied on the basis of European requirements.
• UK Approved Bodies certify for UKCA; European notified bodies certify for CE.
• UKCA may appear on a label or an accompanying document until December 31, 2027.
• The importer established in the UK states name, brand and postal address; instructions are in English; documentation is generally kept for 10 years.
• The producer of electrical equipment registers every year (WEEE Regulations 2013) and marks its products with the crossed-out wheeled bin and a date mark; batteries have their own registration.

In Northern Ireland, CE marking is applied, supplemented by UKNI marking when a notified body established in the UK has carried out the mandatory third-party assessment; UKNI is never used alone. The EU GPSR applies there since December 13, 2024, while the General Product Safety Regulations 2005 remain in force in Great Britain.

United States and Canada: a different logic

North America has no universal marking comparable to CE: obligations depend on the competent federal agency and sometimes on the state.

CPSC: GCC and CPC certificates

The Consumer Product Safety Commission (CPSC) requires the US manufacturer or the importer to certify in writing products subject to its rules:

• GCC (General Certificate of Conformity) for general-use products subject to a rule, a ban or a standard enforced by the CPSC (mattresses, for example), based on testing or a reasonable testing program;
• CPC (Children's Product Certificate) for products intended primarily for children 12 years or younger, based on testing by a CPSC-accepted third-party laboratory.

Each certificate, in English, contains seven elements: product, rules, certifier, holder of the test results, date and place of manufacture, date and place of testing, laboratory. The CPSC provides that from July 8, 2026, most importers of regulated products file them electronically with customs (CBP, Customs and Border Protection): check the procedures with your customs broker.

Children's products bear a permanent tracking label, on the product and its packaging. Toys and child care articles may not contain more than 0.1% of eight regulated phthalates in their accessible plasticized parts. Note: a childlike design or a play value may be enough to classify an ordinary product as a children's product.

FCC and Proposition 65

• FCC (Federal Communications Commission): unless exempt, any radiofrequency device must be authorized before being marketed or imported, either by a supplier's declaration of conformity (SDoC), or by certification through an accredited laboratory recognized by the FCC and an approved body (TCB, Telecommunication Certification Body).
• Proposition 65 (California): warning required in case of exposure to a substance listed as carcinogenic or toxic for reproduction; businesses with fewer than 10 employees are exempt. Since January 1, 2025, the shortened "safe harbor" warning (the standard wording that protects the business) must name at least one substance. The transition runs until January 1, 2028, and products manufactured and labeled before then may be sold without limit.

Canada

• The Canada Consumer Product Safety Act prohibits manufacturing, importing, advertising or selling a product that poses a danger to human health or safety.
• An incident must be reported to Health Canada within two days, after which the manufacturer (or the importer if the manufacturer is abroad) submits a written report within 10 days.
• Radio transmitters, such as a Bluetooth speaker, fall under certification by Innovation, Science and Economic Development Canada (ISED): check that the model appears on its list of certified radio equipment.
• On a prepackaged product, the product identity and net quantity appear in English and in French.

Labeling: the markings that get overlooked

A technically compliant product can be held up for a missing marking or incomplete instructions.

The Waste Electrical and Electronic Equipment (WEEE) Directive recommends the European standard EN 50419 for the symbol and requires the producer to register in each country of sale. The battery collection symbol covers at least 3% of their largest face (5 × 5 cm at most) and goes on the packaging only if the battery is too small. The battery information label will apply 18 months after a Commission implementing act, never before August 18, 2026: check the date in force.

For textiles sold in the EU, the fiber composition must be shown as a percentage of weight, in descending order, visible before purchase, including online; the importer is responsible if the manufacturer is outside the Union. In the United States, the Federal Trade Commission (FTC) requires the composition, the country of origin and the name of a responsible company or its RN (Registered Identification Number). Multilingual labels and packaging are prepared from the packaging design stage by market.

Lab testing and inspections: reducing risk

A test report is evidence for your technical documentation, not an authorization to sell. It is only as good as the laboratory (recognized by the authority when the rule requires it), the standards applied and, above all, the sample tested.

Yet the product tested is often the reference sample: in the meantime, the factory may change the plastic, the battery or the cable. Hence the value of testing parts pulled from production, then verifying at shipment that what leaves matches what was tested. For a custom-designed product, the test plan is set up from the product development stage.

The pre-shipment inspection (PSI) draws a sample according to ISO 2859-1 and the acceptance quality limit selected (AQL): see the AQL guide. It can check every marking, the instructions and the packaging. The pre-production inspection (PPI) and the during-production inspection (DUPRO) are detailed in the guide PPI, DUPRO, PSI and loading; our quality control service organizes them on site.

Customs declaration, duties and VAT follow their own rules:

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