What an EU or UK product launch needs, by product type
Published · Last updated · By Eldris · Compiled from the official texts
This guide covers three things that apply to many consumer products sold into the EU: the safety rules for the product, a business established in the EU that is responsible for it, and producer registrations for packaging, electrical equipment and batteries in each country where the law treats you as the producer, for example where you sell directly to end users from another country. For cosmetics, the EU-established person is a Responsible Person under the Cosmetic Products Regulation, and the product also needs a safety report, a product information file and a notification.
In Great Britain, cosmetics need a Responsible Person established in the United Kingdom and a notification before sale. For other consumer products, the General Product Safety Regulations 2005 place duties on the "producer".
Key dates
- Regulation (EU) 2019/1020 applies, including its Article 4 rule on an EU-established economic operator. Official text
- The General Product Safety Regulation (EU) 2023/988 applies. Official text
- Battery producer registration and extended producer responsibility (Chapter VIII of Regulation (EU) 2023/1542) apply, and all batteries must carry the separate collection symbol. Official text
- The Packaging and Packaging Waste Regulation (EU) 2025/40 applies. Official text
- All batteries must carry a QR code. Official text
Requirements at a glance
Which rule sets each obligation, for the EU and for Great Britain. "Not covered" means this guide does not cover it, not that no rule exists.
| Obligation | European Union | Great Britain |
|---|---|---|
| Someone established locally who is responsible for the product | GPSR products: an EU economic operator (Art. 16). Products under the acts listed in Reg. 2019/1020 Art. 4(5): the same rule (Art. 4). Cosmetics: an EU Responsible Person (Reg. 1223/2009 Art. 4). | Cosmetics: a Responsible Person established in the UK (Schedule 34). Other products: duties fall on the "producer" (GPSR 2005, reg. 2); for a manufacturer outside the UK, that is its UK representative if it has one, otherwise the UK-established person who places the product on the market. |
| Safety assessment and documentation | GPSR: internal risk analysis and technical documentation, kept for 10 years. Cosmetics: a safety assessment and a cosmetic product safety report before sale. | General products: must be safe (GPSR 2005, reg. 5). Cosmetics: a safety assessment by a qualified assessor before sale (GOV.UK guidance). |
| Product information file (cosmetics) | Kept for ten years after the last batch, and made readily accessible at the Responsible Person's address on the label. | Must be in English (Schedule 34); kept for 10 years after the last batch (GOV.UK guidance). |
| Notification before sale (cosmetics) | Electronic notification to the European Commission (Art. 13), made through the Commission's Cosmetic Products Notification Portal (CPNP). | Electronic notification to the Secretary of State; GOV.UK guidance says to notify OPSS using the "Submit cosmetic product notifications" service. |
| Identification and contact details on the product | GPSR: a type, batch or serial number, and the manufacturer's and the responsible operator's name and postal and electronic address. Cosmetics: the Responsible Person's name and address, and country of origin for imports. | General products: the producer's name and address and a product reference or batch, where reasonable. Cosmetics: the Responsible Person's name and address, and country of origin for imports (GOV.UK guidance). |
| Packaging registration | In each Member State where packaging is first made available; an authorised representative where you sell directly to end users without being established there. PPWR applies from 12 August 2026. | UK law not covered by this guide; Eldris's country data is in the country table. |
| Electrical and electronic equipment | Distance sellers: registration in each Member State they sell to; a seller established in another Member State registers through an authorised representative (Arts 16(1), 17(2)). A Directive, applied through national law. The crossed-out wheeled bin symbol. | UK law not covered by this guide; Eldris's country data is in the country table. |
| Batteries | Registration in each Member State where a battery is first made available; an authorised representative for distance sellers; the separate collection symbol. Registration and extended producer responsibility have applied since 18 August 2025. | UK law not covered by this guide; Eldris's country data is in the country table. |
What does the GPSR require?
The General Product Safety Regulation (EU) 2023/988 sets the EU's essential safety rules for consumer products and has applied since 13 December 2024. Every economic operator may place or make available on the EU market only safe products. It applies in so far as no specific EU rules with the same objective regulate a product's safety; where a product is subject to specific EU safety requirements, it applies only to the aspects and risks those requirements do not cover.
- It covers new, used, repaired and reconditioned products.
- Before placing a product on the market, the manufacturer carries out an internal risk analysis and draws up technical documentation, kept for 10 years.
- The product carries a type, batch or serial number or other identifier, or has it on the packaging or an accompanying document where size or nature does not allow.
- The manufacturer's name, registered trade name or trade mark, and postal and electronic address go on the product, or failing that on its packaging or an accompanying document.
- Instructions and safety information are in a language consumers can easily understand, as decided by the Member State where the product is sold.
- Manufacturers publish channels, such as a phone number, email address or a section of their website, for consumers to complain and report accidents or safety issues.
- A manufacturer who believes a product it placed on the market is dangerous informs the market surveillance authorities immediately, through the Safety Business Gateway.
Products that complied with the old General Product Safety Directive and were placed on the market before 13 December 2024 may still be made available.
When do you need someone established in the EU?
A product covered by the GPSR may not be placed on the EU market unless an economic operator established in the EU is responsible for it (Article 16, headed "responsible person" for products placed on the Union market). The operator carries out the tasks in Article 4(3) of Regulation (EU) 2019/1020.
Regulation (EU) 2019/1020, which has applied since 16 July 2021, sets the same rule for products covered by the EU acts listed in its Article 4(5). As published in 2019, that list includes the acts on toys, electrical equipment designed for use within certain voltage limits, electromagnetic compatibility, radio equipment, restriction of hazardous substances (RoHS), machinery and personal protective equipment.
Cosmetics follow their own rule. The GPSR section containing Article 16 does not apply to products subject to specific requirements imposed by EU harmonisation legislation, which the GPSR defines as the legislation listed in Annex I to Regulation (EU) 2019/1020 and any other EU legislation harmonising the conditions for marketing the products that Regulation covers. Annex I includes the Cosmetic Products Regulation, which requires a Responsible Person within the EU.
Who can be the EU operator
A manufacturer established in the EU; an importer, where the manufacturer is outside the EU; an authorised representative established in the EU with a written mandate from the manufacturer; or, where none of those exists in the EU, an EU fulfilment service provider for the products it handles.
What the EU operator does
- Where the product's legislation requires them, verifies that the EU declaration of conformity and technical documentation exist, keeps the declaration available and makes sure the documentation can be supplied on request.
- On a reasoned request from a market surveillance authority, supplies the information and documentation showing conformity, in a language the authority can easily understand.
- Informs the authorities when there is reason to believe the product presents a risk.
- Cooperates with the authorities, including, following a reasoned request, making sure corrective action is taken.
- Under the GPSR, where appropriate to the product's risks, regularly checks that the product matches its technical documentation and the rules on identification, manufacturer contact details and instructions (Article 9(5) to (7)), and can show evidence of those checks.
- Under the GPSR, has its name, registered trade name or trade mark and postal and electronic address on the product, its packaging, the parcel or an accompanying document.
Do you need a UK Responsible Person?
For cosmetics sold in Great Britain, yes. A cosmetic product may not be placed on the market unless there is a responsible person established in the United Kingdom.
For other consumer products, the General Product Safety Regulations 2005 put the duties on the "producer". That includes a manufacturer established in the UK, anyone presenting themselves as the manufacturer by putting their name or mark on the product, and the person who reconditions it; where the manufacturer is outside the UK, it is the manufacturer's UK-established representative if it has one, otherwise the UK-established person who places the product on the market of Great Britain. A producer may only place safe products on the market, and the Regulations apply to a product only in so far as no specific product-safety rules with the same objective apply to it.
The producer's measures include showing its name and address and a product reference or batch on the product or its packaging, where reasonable, and a producer or distributor who knows a product poses risks to consumers incompatible with the general safety requirement must notify an enforcement authority in writing, forthwith.
The 2005 Regulations have a separate version for Northern Ireland. GOV.UK guidance from 2021 says that for cosmetics there the Responsible Person must be established in Northern Ireland or the EU; this guide does not check Northern Ireland's current position.
What do cosmetics need in the EU?
Under the Cosmetic Products Regulation (EC) No 1223/2009, which has applied since 11 July 2013, a cosmetic may be placed on the EU market only if a legal or natural person within the EU is designated as its Responsible Person. That person makes sure the product meets the Regulation's core obligations.
- For imported cosmetics, the importer is the Responsible Person for the products it places on the market, unless it designates an EU-established person by written mandate, accepted in writing.
- Safety report (CPSR). Before sale, a safety assessment and a cosmetic product safety report in two parts: Part A, safety information, and Part B, the safety assessment, carried out by someone with a university qualification in pharmacy, toxicology, medicine or a similar discipline, or a course a Member State recognises as equivalent.
- Product information file (PIF). It includes a product description, the safety report, the manufacturing method with a statement of good manufacturing practice and, where justified, proof of claimed effects. It is kept for ten years after the last batch was placed on the market and made readily accessible at the Responsible Person's address on the label.
- Notification. Before the product is placed on the market, an electronic notification to the European Commission and, once it is on the market, the original labelling and, where reasonably legible, a photograph of the packaging. Notification is made through the Cosmetic Products Notification Portal (CPNP), the European Commission's free online notification system for the Regulation.
- Labelling. The Responsible Person's name and address, the country of origin for imports, nominal content, a date of minimum durability or period after opening, precautions for use, a batch number, the product's function where not clear, and an ingredients list, with nanomaterials followed by "(nano)".
- The language of the content, durability, precautions and function information is set by the law of the Member State where the product reaches the end user.
- A distributor that translates any labelling element on its own initiative to sell in another Member State must submit its own notification.
What do cosmetics need in Great Britain?
- An importer placing a cosmetic on the GB market is its Responsible Person, unless it designates a UK-established person by written mandate, accepted in writing.
- GOV.UK guidance says the Responsible Person needs a UK established address; mail-forwarding and PO box addresses do not count.
- Before sale, the Responsible Person notifies the product electronically, including the address where the product information file is kept and an urgent contact, and then the original labelling and, where reasonably legible, a photograph of the packaging. GOV.UK guidance says to notify the Office for Product Safety and Standards (OPSS) using the "Submit cosmetic product notifications" service. Changes are updated without delay.
- The product information file must be in English and, per GOV.UK guidance, kept for 10 years after the last batch.
- GOV.UK guidance says a qualified safety assessor must check the product's safety before it is made available, and the safety report forms part of the product information file.
- GOV.UK guidance says labels show the Responsible Person's name and address and, for products imported to the UK, the country of origin.
- Serious undesirable effects are reported to OPSS immediately, per GOV.UK guidance.
Packaging registration and the PPWR
The Packaging and Packaging Waste Regulation (EU) 2025/40 applies from 12 August 2026. Packaging producers carry extended producer responsibility for the packaging they first make available in a Member State, must register in that Member State's producer register, and may not make packaging or packaged products available there unless they, or their authorised representative, are registered.
- A business established in another Member State or outside the EU that sells packaged products directly to end users in a Member State counts as a producer there.
- If you sell directly to end users in a Member State where you are not established, you must appoint an authorised representative for extended producer responsibility there, by written mandate.
- Member States may also require producers established outside the EU to appoint an authorised representative when they first make packaging available.
- Registered producers report data to the register by 1 June for the previous calendar year; the register authority issues a registration number within 12 weeks of complete information.
- Online marketplaces that let consumers make distance contracts with producers must, before letting a producer use their services, obtain its registration details for the Member State where the consumer is located and a self-certification that it meets its extended producer responsibility duties there.
- Member States set up their PPWR registers within 18 months of the entry into force of the first implementing act on the register format, which the Commission was due to adopt by 12 February 2026.
Electrical and electronic products (WEEE)
Since 15 August 2018 the WEEE Directive 2012/19/EU applies to all electrical and electronic equipment, subject to its exclusions. It is a Directive, so it reaches businesses through each Member State's national law. Each Member State keeps a register of producers, including those selling at a distance, and a distance seller must be registered in each Member State it sells to. Where it is not registered there itself, the Directive says it registers through an authorised representative under Article 17(2), which covers sellers established in another Member State. How sellers from outside the EU register is set by national law, which this guide does not cover.
- A business in another Member State or outside the EU that sells equipment at a distance directly to users in a Member State counts as a producer there.
- A distance-selling producer established in one Member State appoints an authorised representative in each other Member State it sells to, by written mandate.
- Equipment carries the crossed-out wheeled bin symbol, printed visibly, legibly and indelibly.
Batteries
Under the Batteries Regulation (EU) 2023/1542, producer registration and extended producer responsibility have applied since 18 August 2025. Producers register in each Member State where they first make a battery available, and batteries, including those built into appliances, may be made available only if the producer or its authorised representative is registered there.
- A business selling batteries, including inside appliances, at a distance directly to end users in a Member State where it is not established counts as a producer there and appoints an authorised representative there, by written mandate, who can register on its behalf.
- Since 18 August 2025 all batteries carry the separate collection symbol, covering at least 3% of the largest side (1.5% of the surface area for cylindrical cells), up to 5 x 5 cm; if it would be smaller than 0.47 x 0.47 cm, a symbol of at least 1 x 1 cm goes on the packaging instead.
- Batteries containing more than 0.002% cadmium or 0.004% lead are also marked Cd or Pb.
- A general-information label applies from 18 August 2026 or 18 months after the labelling implementing act, whichever is later, and a QR code from 18 February 2027.
What must an online listing show?
A product offered online is treated as made available on the EU market when the offer targets EU consumers, meaning the seller directs its activities to one or more Member States. Under the GPSR, the offer must clearly show:
- the manufacturer's name, registered trade name or trade mark, and postal and electronic address;
- where the manufacturer is outside the EU, the name and postal and electronic address of the responsible person under GPSR Article 16(1) or Article 4(1) of Regulation (EU) 2019/1020;
- information identifying the product, including a picture and its type;
- any warnings or safety information, in a language consumers can easily understand.
What online marketplaces must do
- Let traders provide, and show consumers on the listing, those details, and collect a self-certification that the trader will offer only compliant products.
- Designate single points of contact for the authorities and for consumers, and register on the Safety Gate Portal.
- Act on an authority's order about a dangerous listing within two working days, and process product-safety notices within three working days.
- Suspend, after a warning, traders that frequently offer non-compliant products, and notify affected buyers of product safety recalls they know of.
Registers and schemes by country
The packaging, WEEE and battery registers or schemes listed in Eldris's own country data for each market. The names are Eldris's short labels, not official titles. Eldris's data file records them as web-verified on 31 May 2026; the markets marked * keep earlier entries and may not be covered by that check. Each country links to its page on epr.eldris.ai. The table is licensed CC BY 4.0 (terms).
| Country | Packaging | WEEE | Batteries |
|---|---|---|---|
| Austria | ARA (Altstoff Recycling Austria) | EAK (Elektroaltgeräte Koord.) | EAK collective system |
| Belgium | Fost Plus / Valipac | Recupel | Bebat |
| Bulgaria | Ecopack Bulgaria | ExEA / NWIS register | ExEA / NWIS register |
| Croatia | FZOEU (Environmental Fund) | FZOEU (Environmental Fund) | FZOEU (Environmental Fund) |
| Cyprus | Green Dot Cyprus | WEEE Cyprus (Electrocyclosis) | AFIS Cyprus |
| Czech Republic | EKO-KOM | ASEKOL (Min. of Environment) | ECOBAT |
| Denmark | DPA-System + collective scheme | DPA-System | DPA-System |
| Estonia | Pakendiregister | Problemtoodete register | Problemtoodete register |
| Finland | RINKI (Finnish Packaging Prod.) | SER / ERP Finland | Recser Oy |
| France* | Citeo or Leko | ADEME / SYDEREP | Corepile or Screlec |
| Germany* | LUCID + Dual System | Stiftung EAR | Stiftung EAR |
| Greece | HERRCO | Appliances Recycling / EOAN | AFIS |
| Hungary | MOHU | MOHU / NWMA | MOHU / NWMA |
| Ireland | Repak | WEEE Ireland / ERP | WEEE Ireland / ERP |
| Italy* | CONAI + Consortia | Centro di Coord. RAEE | National Battery Reg. |
| Latvia | Latvijas Zaļais punkts | Elektroregistrs (LETERA) | Latvijas Zaļais punkts |
| Lithuania | GPAIS | GPAIS (Environmental Prot. Agency) | GPAIS |
| Luxembourg | Valorlux | Ecotrel | Ecotrel (battery scheme) |
| Malta | GreenPak | GreenPak (ERA) | GreenPak |
| Netherlands* | Afvalfonds Verpakkingen | Wecycle / Stichting Open | Stibat |
| Poland* | BDO + Recovery Org | GIOŚ / BDO | BDO Collection Scheme |
| Portugal | Sociedade Ponto Verde | APA / SILiAmb | APA / SILiAmb |
| Romania | Eco-Rom Ambalaje | National EEE Register (AFM) | AFM National Register |
| Slovakia | SEWA | Min. of Environment / SEWA | SEWA |
| Slovenia | ARSO | ARSO (Slovene Environment Agency) | ARSO |
| Spain* | Ecoembes | Registro Industrial | Battery SIG |
| Sweden | Naturvårdsverket / FTI | Naturvårdsverket (EEB register) | Naturvårdsverket / Batterikretsen |
| United Kingdom | PackUK (pEPR / Defra) | EA-approved schemes (e.g. ERP) | Approved battery scheme |
Quick answers
Since when does the EU General Product Safety Regulation apply?
The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. It sets the EU's essential safety rules for consumer products and applies in so far as no specific EU rules with the same objective regulate a product's safety; where specific EU safety requirements apply, it covers only the aspects and risks they do not cover.
Does a product sold into the EU need someone established in the EU?
For a product covered by the GPSR, yes: it may not be placed on the EU market unless an economic operator established in the EU is responsible for it. Regulation (EU) 2019/1020 sets the same rule for products under the EU acts listed in its Article 4(5), such as toys, radio equipment and electrical equipment designed for use within certain voltage limits (the list as published in 2019). Cosmetics need an EU Responsible Person under the Cosmetic Products Regulation.
Do I need a UK Responsible Person?
For cosmetics sold in Great Britain, yes: a cosmetic may not be placed on the market unless there is a responsible person established in the United Kingdom. For other consumer products, the General Product Safety Regulations 2005 place duties on the 'producer', which for a manufacturer outside the UK is its UK representative if it has one, otherwise the UK-established person who places the product on the market.
What does a cosmetic need before it is sold in the EU?
A Responsible Person established in the EU, a safety assessment with a cosmetic product safety report, a product information file kept for ten years after the last batch, an electronic notification to the European Commission before the product is placed on the market, and a label showing, among other things, the Responsible Person's name and address and an ingredients list.
When does the EU Packaging and Packaging Waste Regulation apply?
The PPWR, Regulation (EU) 2025/40, applies from 12 August 2026. Producers must register in each Member State where they first make packaging or packaged products available, and a producer selling directly to end users in a Member State where it is not established must appoint an authorised representative for extended producer responsibility there.
What must an online product listing show under the GPSR?
The manufacturer's name, registered trade name or trade mark and postal and electronic address; for a manufacturer outside the EU, the name and postal and electronic address of the responsible person under GPSR Article 16(1) or Article 4(1) of Regulation (EU) 2019/1020; information identifying the product, including a picture and its type; and any required warnings or safety information.
How this guide was compiled
Every statement about the law on this page is backed by an exact quote from an official source, kept in a claim ledger. The texts were read on : the six EU acts on EUR-Lex, the European Commission's CPNP page, the General Product Safety Regulations 2005 and Schedule 34 on legislation.gov.uk, and the GOV.UK guidance on cosmetics in Great Britain. The country table comes from Eldris's own data.
Limits
- The EU acts were read in their original published form. Later amendments were not checked.
- The UK texts were read on legislation.gov.uk: the General Product Safety Regulations 2005 as valid from 27 February 2025, and Schedule 34 as amending text. The consolidated GB version of Regulation 1223/2009 and any UK changes after 27 February 2025 were not checked.
- National rules are not covered: the language each Member State requires, which countries require an authorised representative for packaging from producers outside the EU, national WEEE law, and UK law on packaging, WEEE and batteries.
- Northern Ireland is mentioned only where the texts above address it.
- This page is general information, not legal advice. What applies to your product depends on the product, where you are established, how you sell and where.
Sources
- Regulation (EU) 2023/988, General Product Safety Regulation (EUR-Lex)
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)
- Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
- Cosmetic product notification portal (European Commission)
- Regulation (EU) 2025/40, Packaging and Packaging Waste Regulation (EUR-Lex)
- Directive 2012/19/EU on waste electrical and electronic equipment (EUR-Lex)
- Regulation (EU) 2023/1542, Batteries Regulation (EUR-Lex)
- The General Product Safety Regulations 2005 (legislation.gov.uk)
- Schedule 34, Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 (legislation.gov.uk)
- Making cosmetic products available to consumers in Great Britain (GOV.UK)
- Eldris country data (epr.eldris.ai), recorded by the data file as web-verified on 31 May 2026