Compliance Checklist

GPSR (General Product Safety Regulation)
Automotive
United Kingdom 🇬🇧

UK product safety for automotive accessories on Amazon UK: General Product Safety Regulations 2005, distinction from UNECE/E-mark approval, GB CLP for car care products, UK Responsible Person and OPSS.

Overview

After Brexit, general automotive accessories on Amazon.co.uk are no longer subject to the EU GPSR (EU) 2023/988 but continue to fall under the General Product Safety Regulations 2005 (SI 2005/1803) as the UK's safety framework law, enforced by the Office for Product Safety and Standards (OPSS) and local Trading Standards Authorities. This covers phone holders, organisers, seat covers, floor mats, car care products and interior accessories. Safety-critical vehicle parts (brake pads, tyres, child seats, lighting) do NOT fall under the GPSR 2005 but under the UNECE type-approval system: after Brexit, the UK remains a contracting party in its own right to the 1958 UN Agreement and continues to issue and recognise E-marks under its own country code E11, alongside its own 'GB type approval' scheme operated by the Vehicle Certification Agency (VCA), which has existed as an alternative for the GB market since 1 January 2021. Chemical car care products (cleaners, polishes) fall under the standalone GB CLP Regulation, administered by the HSE instead of ECHA. Non-UK manufacturers need a UK Responsible Person.

Does this apply to my product?

This checklist applies to all non-type-approval automotive products sold to consumers in Great Britain on Amazon.co.uk: car phone holders, organisers, seat covers, floor mats, car care products (cleaners, polishes, de-icers), sun shades, steering wheel covers, boot mats, charging cables (unless falling under radio/low-voltage rules), air fresheners, ice scrapers. NOT covered (regulated instead by UNECE/GB type approval): brake pads, tyres, child seats, headlights/tail lights with E-mark, seat belts, airbag components. For shipments to Northern Ireland, EU law continues to apply via the Windsor Framework (including EU CLP instead of GB CLP for chemical products).

Step-by-Step Guide

Progress0/10 (0%)

Classify product category: UK product safety vs. UNECE type-approval

The most important first step: check whether your product falls under general UK product safety or requires UNECE/GB type-approval.

Estimated time: 1-2 days

Product classified as GPSR-relevant or requiring type-approvalRequired

General accessories with no impact on vehicle safety (phone holders, seat covers, floor mats, care products) fall under the General Product Safety Regulations 2005. Safety-critical parts (brakes, lighting, tyres, child seats) need an E-mark under UNECE regulations or GB type-approval from the VCA. As a contracting party to the 1958 UN Agreement in its own right, the UK recognises and issues E-marks under country code E11.

Own role as economic operator determinedRequired

Manufacturer, importer (places goods from outside GB on the market), distributor or fulfilment service provider (Amazon FBA) – each role carries its own obligations under the GPSR 2005.

Appoint UK Responsible Person and conduct risk assessment

Since 1 January 2021, non-UK manufacturers need a UK Responsible Person and a risk assessment that considers automotive-specific hazards.

Estimated time: 3-7 days

UK Responsible Person appointedRequired

Required under the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019: a Responsible Person based in Great Britain must be stated on the product or packaging with contact details and must keep the technical documentation available.

Appointment agreement with the UK Responsible Person

Risk analysis with automotive-specific hazards completedRequired

Automotive-specific risks: distraction risk from phone holders restricting the field of view, slip risk from floor mats blocking pedals, chemical risks from car care products, fire risk from sun shades under sun exposure.

Written risk analysis evaluating all identified hazards

Comply with GB CLP for chemical car care products

Car care products (cleaners, polishes, de-icers) are often chemical mixtures. Since Brexit, Great Britain applies the standalone GB CLP Regulation, administered by the HSE.

Estimated time: 3-5 days

Classification under GB CLP completedRequired

GB CLP is the retained, UK-administered version of the former EU CLP Regulation. Notifications are made to the HSE (which maintains its own GB Mandatory Classification and Labelling list), not to ECHA. EU CLP with notification to ECHA continues to apply in Northern Ireland.

Safety Data Sheet (SDS) under GB CLP

GB CLP-compliant labelling appliedRequired

Hazard pictograms, signal word and H and P statements in English on the packaging. The substantive classification criteria largely mirror the former EU CLP status but may diverge over time.

Technical documentation and labelling for Amazon.co.uk

All mandatory information must be applied to the product or packaging. For the UK market, safety instructions in English are required.

Estimated time: 2-4 days

Contact details and traceability appliedRequired

Name, trade name or trademark, postal address and electronic contact of the manufacturer and the UK Responsible Person, plus a batch or model number for traceability.

Safety and usage instructions in EnglishRequired

Mounting instructions for phone holders (do not mount in field of view), installation notes for floor mats (use securing hooks, check pedal clearance), warnings for chemical products (GB CLP pictograms).

Safety instructions and user manual in English

Meet Amazon.co.uk compliance requirements

Amazon.co.uk requires complete compliance information in Seller Central as a condition of sale.

Estimated time: 3-5 days

UK Responsible Person registered in Amazon Seller CentralRequired

Register the UK Responsible Person's name, UK address, phone number and email under 'Product Compliance'. Amazon may immediately suspend listings without this information.

Compliance documents uploaded to AmazonRequired

Upload the risk assessment, GB CLP Safety Data Sheet if applicable, and test reports for safety-relevant accessories. Amazon often issues compliance requests with short deadlines (5-7 days).

Risk assessment, Safety Data Sheet, test reports as PDF

Common Mistakes to Avoid

Confused UK product safety law with the EU GPSR

Consequence: The UK does not apply the EU GPSR 2023 but the General Product Safety Regulations 2005. Documentation referencing the EU regulation is formally insufficient for the UK market.

Prevention: Prepare separate compliance dossiers for the UK and EU referencing the correct legal basis in each case.

Safety-critical vehicle parts incorrectly treated only under the GPSR 2005

Consequence: Products that need an E-mark or GB type-approval (e.g. LED replacement bulbs for headlights) but are treated only as general accessories can be removed from the market by OPSS/Trading Standards and risk criminal consequences.

Prevention: Before listing, check against the VCA type-approval list whether your product affects vehicle safety.

Treated GB CLP and EU CLP as identical

Consequence: Since Brexit, GB CLP and EU CLP are separate regimes with different competent authorities (HSE instead of ECHA) and their own Mandatory Classification and Labelling list. EU CLP continues to apply in Northern Ireland. A notification only to ECHA does not formally cover the GB market.

Prevention: Notify chemical car care products separately to the HSE for the GB market and check your Northern Ireland shipping settings.

No UK Responsible Person for non-UK manufacturers

Consequence: Without a UK Responsible Person, sales on the UK market have not been permitted since 1 January 2021. Amazon can suspend the listing, and OPSS and Trading Standards can prohibit distribution.

Prevention: Appoint a UK Responsible Person in good time – your UK importer or a specialised service provider can fulfil this role.

Floor mats sold without securing system and warning

Consequence: Unsecured floor mats can slide under pedals and cause accidents – a well-known and serious safety risk that has already led to recalls.

Prevention: Equip floor mats with securing hooks or anti-slip coating and add clear warnings.

Frequently Asked Questions

Q1Does my car accessory need an E-mark or is UK general product safety sufficient?

It depends on whether the product affects vehicle safety. General accessories (phone holders, seat covers, floor mats, care products) fall under the General Product Safety Regulations 2005 – no E-mark needed. Safety-critical parts (brake pads, headlights, tyres, child seats) need an E-mark (country code E11 for GB) or GB type-approval from the VCA.

Q2Does the EU GPSR 2023 also apply to automotive accessories in the UK?

No. Great Britain continues to apply the General Product Safety Regulations 2005 as its general safety framework law, not the EU GPSR 2023. Northern Ireland, however, continues to apply EU law via the Windsor Framework.

Q3Is GB CLP the same as EU CLP for car care products?

No. GB CLP is a standalone continuation of the former EU CLP Regulation, administered by the HSE with its own Mandatory Classification and Labelling list. Notifications are made to the HSE instead of ECHA. EU CLP with notification to ECHA continues to apply in Northern Ireland.

Q4Can I keep using my EU E-mark approval for the UK market?

For parts falling under the 1958 UNECE Agreement (E-marks), the UK is a contracting party in its own right and generally recognises valid E-marks regardless of whether they were originally issued via an EU or a UK approval authority. For aspects previously covered by EU whole-vehicle type-approval (2007/46/EC), the VCA's standalone GB type-approval system has applied instead since 1 January 2021. If in doubt, clarify the exact classification of your part with the VCA.

Q5What happens if Amazon.co.uk suspends my car accessory listing due to missing compliance data?

Promptly complete the missing fields under 'Product Compliance' in Seller Central: UK Responsible Person details, manufacturer information, and upload the risk assessment and GB CLP Safety Data Sheet if applicable. The listing is typically reactivated within a few days once the information is complete.

GPSR (General Product Safety Regulation)AutomotiveUnited Kingdom 🇬🇧