Compliance Checklist

GPSR (General Product Safety Regulation)
Food & Beverages
United Kingdom 🇬🇧

Complete compliance checklist for food and beverages on Amazon.co.uk under UK post-Brexit law: General Food Law, FIC labelling, FSA requirements, and UK Responsible Person obligations.

Overview

Selling food and beverages on Amazon.co.uk is governed by the UK's post-Brexit regulatory framework. Key legal bases include retained EU General Food Law (Regulation (EC) 178/2002 as retained UK law), the retained Food Information to Consumers Regulation (EU FIC, retained as UK law), the Food Safety Act 1990, the General Product Safety Regulations 2005 (SI 2005/1803), and the Food Information Regulations 2014 (FIR 2014). Enforcement is carried out by the Food Standards Agency (FSA) for England, Wales, and Northern Ireland, Food Standards Scotland (FSS) for Scotland, and local Trading Standards officers. Since Brexit, a UK Responsible Person (UK RP) is mandatory for imported food products. Amazon.co.uk additionally requires specific grocery compliance documentation for selling in the Food & Beverages category.

Does this apply to my product?

This checklist applies to all sellers offering food and beverages (including dietary supplements, drinks, packaged foods, snacks, and speciality products) to UK consumers via Amazon.co.uk. It is particularly relevant for EU-based businesses exporting to the UK post-Brexit, and for third-country manufacturers fulfilling via Amazon FBA UK or Seller Fulfilled Prime.

Step-by-Step Guide

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UK Responsible Person and Business Registration

Appoint a UK Responsible Person and register the food business with the relevant local authority under the Food Safety Act 1990 and retained General Food Law.

Estimated time: 1-2 weeks

Appoint UK Responsible PersonRequired

Designate a UK-based Responsible Person (UK RP) who is accountable for food safety compliance. The UK RP must be a natural or legal person established in Great Britain and serve as the point of contact for the FSA and Trading Standards. This has been mandatory for all imported food products since Brexit.

UK Responsible Person appointment agreementProof of GB establishment (Companies House extract or utility bill)

Every food business must register with the relevant Local Authority at least 28 days before commencing operations (Food Safety Act 1990, Section 19). Registration is free and can be done online via the FSA portal or directly with the local council.

Local Authority registration confirmation

Unlock Amazon.co.uk Seller Account for GroceryRequired

The 'Grocery & Gourmet Food' category on Amazon.co.uk is a gated category. An ungating application must be submitted, including evidence of food safety compliance, labelling conformity, and business registration.

Amazon Grocery ungating application with product photos and invoice evidenceLabel photos (all sides) in English language

Food Labelling under UK FIC/FIR 2014

Complete labelling in accordance with the retained Food Information to Consumers Regulations and the Food Information Regulations 2014 (FIR 2014), adapted to UK-specific post-Brexit requirements.

Estimated time: 1-2 weeks

Verify mandatory labelling elementsRequired

Ensure all mandatory elements are present on the label: name of the food, ingredients list, allergen declaration (14 major allergens emphasised in bold), net quantity, best before or use by date, storage conditions, name and address of the UK food business operator, country of origin/place of provenance, nutrition declaration, alcohol content (if applicable), and lot/batch number.

Label mock-up with all mandatory informationNutritional analysis report from an accredited laboratory

UK-specific post-Brexit adaptationsRequired

Implement post-Brexit adaptations: replace EU flag and EU organic logo with UK equivalents, replace CE marking with UKCA where applicable, verify EU geographical indications (PDO/PGI apply in GB only if registered in the UK GI register), list a GB address as food business operator instead of an EU address, and ensure the label is in English.

Updated labels with GB address and UK logos

Meet Amazon product listing requirementsRequired

Amazon.co.uk requires additional information in the product listing: complete ingredients list in the backend, allergen information in product attributes, nutrition information per 100g/ml, storage instructions, and correct classification in Amazon browse nodes for grocery. Best before dates must be correctly maintained in FBA inventory.

Amazon flat file with all mandatory grocery attributes

Food Safety and HACCP

Implementation of a food safety management system based on HACCP principles under retained Regulation (EC) 852/2004 and ensuring traceability under retained General Food Law.

Estimated time: 2-4 weeks

Create or update HACCP planRequired

A HACCP-based food safety management system (FSMS) is legally required for all food businesses in the UK (retained Regulation (EC) 852/2004, Article 5). The plan must identify all critical control points (CCPs), establish limits, define monitoring procedures, and document corrective actions. For SMEs, the FSA provides simplified SFBB guides (Safer Food, Better Business).

HACCP plan with flow diagram and CCP analysisSFBB documentation (for SMEs)

Ensure traceabilityRequired

Under retained General Food Law (Article 18), full traceability must be ensured — one step back (supplier) and one step forward (customer). All batches must be identifiable, and records must be kept for at least 5 years. This is particularly important for importers who must document the supply chain across the GB border post-Brexit.

Traceability documentation with batch recordsSupplier certificates and import documentation

Import and Customs Clearance (Post-Brexit)

Import of food products into Great Britain under post-Brexit customs regulations, including IPAFFS pre-notification, Border Target Operating Model (BTOM), and sanitary controls.

Estimated time: 1-2 weeks

EORI number and customs registrationRequired

A GB EORI number (Economic Operators Registration and Identification) is required for all food imports into Great Britain. Since the full implementation of border controls (BTOM Phase 3, 2025), food imports from the EU must be fully declared. Customs declarations are submitted via the Customs Declaration Service (CDS).

GB EORI number confirmationCustoms declarations and tariff codes (HS codes)

IPAFFS pre-notification and health certificatesRequired

Food products of animal origin (POAO) require pre-notification via IPAFFS (Import of Products, Animals, Food and Feed System) and an Export Health Certificate (EHC) from the country of origin. Since BTOM Phase 2/3, food products of non-animal origin are also subject to risk-based checks. The risk category classification determines the frequency of checks at the GB border.

IPAFFS pre-notification confirmationExport Health Certificate (EHC) for products of animal originPhytosanitary certificate (if applicable for plant products)

Product-Specific Regulations and Testing

Compliance with product-specific UK regulations for certain food categories, including Novel Food authorisation, food supplement regulations, and contaminant limits.

Estimated time: 2-4 weeks

Verify Novel Food status and FSA authorisationRequired

Check whether the product or individual ingredients are classified as Novel Food (retained Regulation (EU) 2015/2283). The UK's FSA maintains its own Novel Food register, which may differ from the EU register. Products containing CBD, certain algae, exotic fruits, or novel proteins frequently require Novel Food authorisation. The FSA has managed a separate authorisation process since Brexit.

Novel Food status assessment or FSA authorisation evidenceSafety dossier (if application required)

Laboratory analysis and contaminant testingRequired

Conduct relevant laboratory analyses through a UKAS-accredited laboratory: nutritional analysis (to verify the nutrition declaration), microbiological testing (under retained Regulation (EC) 2073/2005), contaminant analysis (heavy metals, pesticides, mycotoxins under retained Regulation (EC) 1881/2006), and allergen testing. For food supplements, additionally test declared active ingredient levels.

Laboratory analysis certificates (UKAS-accredited)Microbiological test reportContaminant analysis report

Packaging Compliance and UK pEPR

Compliance with UK packaging regulations including Extended Producer Responsibility for packaging (pEPR) and food contact material requirements.

Estimated time: 1-2 weeks

UK pEPR registration and data reportingRequired

The UK Extended Producer Responsibility for packaging (pEPR) system is gradually replacing the former PRN system. Businesses placing packaging on the UK market (including imported food packaging) must register and report packaging data. Obligations apply above certain turnover thresholds and include registration with the Environment Agency, annual data reporting, and from 2026 the payment of fees to fund packaging collection.

pEPR registration confirmation with the Environment AgencyAnnual packaging data report

Food Contact Materials (FCM) complianceRequired

All packaging materials in direct contact with the food must comply with retained EU FCM Regulations (Regulation (EC) 1935/2004 and Regulation (EU) 10/2011 for plastics). A Declaration of Compliance from the packaging manufacturer is required, confirming that no migration of harmful substances occurs above the legal limits.

Packaging manufacturer's Declaration of ComplianceMigration test reports (if applicable)

Common Mistakes to Avoid

EU address instead of GB address on the label

Consequence: Product will be challenged by Trading Standards and may be seized. Amazon.co.uk may suppress the listing. Fine of up to GBP 5,000 per offence in the Magistrates' Court.

Prevention: Always include a GB address of the UK Responsible Person or UK food business operator on the label. For Northern Ireland, additionally ensure EU compliance under the Windsor Framework.

Allergens not correctly emphasised

Consequence: Breach of FIR 2014 — potentially life-threatening for allergy sufferers. Trading Standards can order a recall. Amazon removes the product immediately upon complaint. Criminal prosecution under the Food Safety Act 1990 possible.

Prevention: Emphasise all 14 major allergens in bold in the ingredients list. Add a separate 'Contains:' allergen statement. Have labels reviewed by a UK food law specialist.

Missing IPAFFS pre-notification on import

Consequence: Goods are rejected at the GB border or placed in quarantine. Additional storage costs at the border. Delay of Amazon FBA UK inbound by weeks.

Prevention: Submit IPAFFS pre-notification at least 24 hours before goods arrive at the GB border. Work with an experienced UK customs agent familiar with BTOM requirements.

Amazon FBA inbound with too short shelf life

Consequence: Amazon rejects the entire shipment and returns it at the seller's expense. Disposal fees or return transport costs. Loss of FBA inventory and revenue.

Prevention: Ensure all products have at least 105 days remaining shelf life at FBA inbound. Align supply chain and production planning accordingly. Correctly maintain expiry dates in Seller Central inventory.

Nutrition declaration based on EU calculation without UK verification

Consequence: UK tolerance values for nutrition information may differ. Incorrect declarations lead to challenges by Trading Standards and loss of consumer trust. Amazon listing suppression upon customer complaints.

Prevention: Have nutritional analysis performed by a UKAS-accredited laboratory. Follow UK-specific FSA tolerance guidance. Cross-check nutrition information in the Amazon backend against laboratory results.

Frequently Asked Questions

Q1Do I need a UK Responsible Person for food on Amazon.co.uk after Brexit?

Yes, since Brexit all imported food products must have a UK-based food business operator or UK Responsible Person designated. Their name and GB address must appear on the label. An EU address alone is no longer sufficient. SpaceGoats can assist you in finding a suitable UK RP and correctly implementing the labelling requirements.

Q2Which allergens must be declared on UK food labels?

The UK FIR 2014 requires declaration of 14 major allergens: cereals containing gluten, crustaceans, eggs, fish, peanuts, soya, milk, tree nuts, celery, mustard, sesame, sulphur dioxide/sulphites, lupin, and molluscs. These must be emphasised in bold in the ingredients list. The list is identical to the EU list, but the UK FSA may independently make changes in the future.

Q3Does CE marking still apply to food in the UK?

Food products themselves do not carry CE or UKCA marking — these apply to non-food products. However, food contact materials and certain kitchen/preparation equipment sold with the food may require UKCA marking. CE marking is still accepted for these products in GB until 2027, after which only UKCA will be valid.

Q4How does Amazon.co.uk Grocery ungating work?

The 'Grocery & Gourmet Food' category is gated on Amazon.co.uk. To get ungated, you must submit an application through Seller Central providing: three recent invoices from a UK wholesaler (at least 10 units per ASIN each), high-resolution photos of all label sides in English, proof of food business operator registration, and additional certificates if required. The process typically takes 1-3 weeks.

Q5What special rules apply to food supplements in the UK?

Food supplements in the UK are governed by the retained Food Supplements (England) Regulations 2003 (and equivalent regulations for Wales, Scotland, NI). They must be labelled as 'food supplement', state the recommended daily dose, carry the warning 'Do not exceed the recommended daily dose', and must not make medicinal claims (retained Nutrition & Health Claims Regulation). Vitamin and mineral amounts must be stated in absolute values and as a percentage of UK NRV (Nutrient Reference Values).

Q6What happens to my food product during an FSA recall?

During an FSA recall you must act immediately as the food business operator: remove the product from sale (including from Amazon FBA via Removal Order), notify the relevant Local Authority, inform affected customers, and cooperate with the FSA on recall notices. The FSA publishes all recalls on food.gov.uk/news-alerts. Amazon automatically removes affected ASINs and may suspend the entire seller account until the matter is resolved.

GPSR (General Product Safety Regulation)Food & BeveragesUnited Kingdom 🇬🇧

UK Responsible Person and Business Registration

Food Labelling under UK FIC/FIR 2014

Food Safety and HACCP

Import and Customs Clearance (Post-Brexit)

Product-Specific Regulations and Testing

Packaging Compliance and UK pEPR

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