Compliance Checklist

GPSR (General Product Safety Regulation)
Jewelry & Watches
United Kingdom 🇬🇧

UK product safety for jewelry and watches on Amazon UK: General Product Safety Regulations 2005, Hallmarking Act, UK REACH nickel limits, UK Responsible Person and Batteries Regulation.

Overview

After Brexit, jewelry and watches sold on Amazon.co.uk are not subject to the EU General Product Safety Regulation (EU) 2023/988 (GPSR) but continue to fall under the General Product Safety Regulations 2005 (SI 2005/1803) as the UK's general safety framework law. This is enforced by the Office for Product Safety and Standards (OPSS) and local Trading Standards Authorities. Non-UK manufacturers must appoint a UK Responsible Person based in Great Britain. Chemical safety (in particular nickel release) has fallen under UK REACH since 1 January 2021, a standalone regime administered by the Health and Safety Executive (HSE) that is NO LONGER identical to the EU REACH Regulation, even though the substantive nickel limits were carried over unchanged. Precious metal jewelry is additionally subject to the Hallmarking Act 1973, which requires hallmarking at one of the four UK Assay Offices. Battery-powered watches fall under the UK Batteries and Accumulators Regulations 2009. Amazon.co.uk requires complete UK Responsible Person details and supporting documents as a condition of sale.

Does this apply to my product?

This checklist applies to all economic operators (manufacturers, importers, distributors, fulfilment service providers) selling jewelry (rings, necklaces, bracelets, earrings, piercing jewelry, brooches) and watches (wristwatches, battery-powered and mechanical watches) to consumers on Amazon.co.uk, regardless of whether the goods are manufactured in the UK, the EU or a third country. Particular attention applies to products with prolonged skin contact (nickel relevance), precious metal products (hallmarking obligation) and battery-powered watches (Batteries Regulation). A special case applies to shipments to Northern Ireland: under the Windsor Framework, EU law (EU REACH rather than UK REACH) continues to apply there, which must be tracked separately for mixed GB/NI shipping areas.

Step-by-Step Guide

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Identify the UK product safety legal framework

Determine all applicable UK regulations for jewelry and watches. UK law mirrors the former EU directive but is a standalone British legal regime with its own authorities and deadlines.

Estimated time: 2-5 days

General Product Safety Regulations 2005 (SI 2005/1803) checkedRequired

The GPSR 2005 is the UK's general product safety framework law and applies to jewelry and watches as consumer goods. Unlike the EU GPSR 2023, it has not been updated in the UK. Suppliers must ensure that only safe products are placed on the market.

Risk assessment under General Product Safety Regulations 2005

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 and the Consumer Protection Act 1987.

Check chemical safety under UK REACH

Since 1 January 2021, UK REACH is a standalone regime administered by the HSE as the competent authority (no longer ECHA). For jewelry, nickel release is the key concern.

Estimated time: 1-3 weeks

Nickel release tested under UK REACH Annex 17Required

UK REACH carried over the limit from REACH Annex XVII Entry 27 unchanged: max. 0.5 µg/cm²/week for products with prolonged skin contact and for piercing jewelry, tested per EN 1811 (recognised in the UK as a 'designated standard'). An accredited test report (e.g. from a UKAS-accredited laboratory) is required.

Nickel release test report per EN 1811 from a UKAS-accredited laboratory

Northern Ireland special case checked (Windsor Framework)

For shipments to Northern Ireland, EU REACH continues to apply instead of UK REACH. While the substantive nickel limits are identical, the documentation, competent authority (ECHA instead of HSE) and formal labelling obligations differ.

Internal risk analysis documentedRequired

Written risk analysis under the GPSR 2005: chemical risks (nickel, lead, cadmium), mechanical risks (swallowable small parts in children's jewelry, sharp edges), electrical risks for battery-powered watches.

Internal risk analysis / risk assessment document

Appoint UK Responsible Person and check hallmarking

Non-UK manufacturers have needed a UK Responsible Person since 1 January 2021. Precious metal jewelry above the exemption weights must be hallmarked under the Hallmarking Act 1973.

Estimated time: 1-2 weeks

UK Responsible Person appointedRequired

Required under the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, in force since 1 January 2021: a Responsible Person based in Great Britain must be stated on the product or packaging with name, address and contact details.

Appointment agreement with the UK Responsible Person

Hallmarking obligation checked by weightRequired

The Hallmarking Act 1973 (most recently amended by the Hallmarking Act 1973 (Amendment) Regulations 2023, in force since 1 January 2023) requires hallmarking by one of the four UK Assay Offices (London, Birmingham, Sheffield, Edinburgh) when precious metal items above the exemption weights are described as gold, silver, platinum or palladium. Exemption weights since 2023: gold 1 g, silver 7.78 g, platinum 0.5 g, palladium 1 g. Selling unhallmarked items above these weights while using a precious metal description is a criminal offence.

Hallmarking certificate / assay mark evidence from the Assay Office

Traceability ensured (batch/serial number)Required

Each product or its packaging must carry a unique identification. For very small jewelry items, information on the packaging or a tag is sufficient.

Battery obligations for battery-powered watches

Battery-powered watches fall under the UK Batteries and Accumulators Regulations 2009 (as amended and retained after Brexit) – a standalone system, separate from the EU Battery Regulation.

Estimated time: 1-2 weeks

Registration as a battery producerRequired

Anyone placing battery-powered watches on the market in Great Britain for the first time must register as a producer of portable batteries through a Producer Compliance Scheme (PCS) approved by the Environment Agency.

Registration confirmation from the Producer Compliance Scheme

Battery marking appliedRequired

The battery or product must bear the crossed-out wheelie bin symbol. If mercury, cadmium or lead thresholds are exceeded, the chemical symbols must also be shown.

Packaging EPR and Amazon.co.uk listing compliance

The UK's Extended Producer Responsibility (EPR) system for packaging is standalone. Amazon.co.uk additionally requires complete compliance information in Seller Central.

Estimated time: 3-5 days

UK Packaging EPR registration with the Environment AgencyRequired

Registration and reporting obligation from 25 tonnes of packaging/year or GBP 1m annual turnover; full financial EPR obligations (modulated fees) apply since 2025. Jewelry packaging (boxes, velvet inserts, plastic windows) must be reported by material fraction.

EPR registration confirmation and volume report

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.

Completed compliance fields in Amazon Seller Central (screenshot/export)

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 EU regulations is formally insufficient for the UK market. OPSS and Trading Standards can remove products from the market.

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

Precious metal jewelry sold without hallmarking above the exemption weight

Consequence: Selling unhallmarked items above the exemption weights (gold 1 g, silver 7.78 g, platinum 0.5 g, palladium 1 g) under a precious metal description is a criminal offence under the Hallmarking Act 1973 and can lead to seizure and fines.

Prevention: Have all precious metal items above the exemption weight hallmarked at one of the four UK Assay Offices before using terms like 'gold' or 'silver' in the listing.

Treated UK REACH and EU REACH as identical

Consequence: Since 1 January 2021, UK REACH and EU REACH are separate legal regimes with different authorities (HSE instead of ECHA). EU REACH continues to apply in Northern Ireland. Keeping evidence for only one of the two regimes risks gaps for mixed GB/NI shipments.

Prevention: Check your Amazon shipping settings for deliveries to Northern Ireland and, if applicable, keep additional EU REACH evidence on file.

No UK Responsible Person appointed

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 – a UK importer, authorised representative or specialised service provider can fulfil this role.

Battery regulations for battery-powered watches ignored

Consequence: Without registration through a Producer Compliance Scheme and correct battery marking, distribution restrictions and Amazon listing suspensions can result.

Prevention: Register with an approved Producer Compliance Scheme before distributing battery-powered watches and apply the crossed-out wheelie bin symbol, including chemical symbols where required.

Frequently Asked Questions

Q1Does the EU GPSR 2023 also apply to jewelry on Amazon.co.uk?

No. The UK market continues to apply the General Product Safety Regulations 2005, not the EU GPSR 2023. Providing only EU GPSR documentation does not formally satisfy UK requirements.

Q2Do I need to have my gold jewelry hallmarked at a UK Assay Office?

Yes, if the item is above the exemption weights (gold 1 g, silver 7.78 g, platinum 0.5 g, palladium 1 g since the 2023 amendment) and you use a precious metal description in the listing. Fineness already tested under a different EU system does not replace UK hallmarking – it must be done at one of the four UK Assay Offices (London, Birmingham, Sheffield, Edinburgh).

Q3Is UK REACH the same as EU REACH?

No, since 1 January 2021 they are separate legal regimes with different competent authorities (HSE instead of ECHA). The substantive nickel limits were carried over unchanged, but Northern Ireland continues to fall under EU REACH – anyone shipping there may need evidence for both regimes.

Q4Do I need a UK Responsible Person for fashion jewelry (no precious metals)?

Yes. The UK Responsible Person obligation applies to all consumer goods, regardless of whether precious metals are involved. Only the hallmarking obligation does not apply to pure fashion jewelry without a precious metal description. Nickel testing remains relevant, however, since fashion jewelry frequently uses nickel-containing alloys.

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

Promptly complete the missing fields under 'Product Compliance' in Seller Central: UK Responsible Person details, manufacturer information and, where applicable, hallmarking evidence. Upload test reports as PDFs. The listing is typically reactivated within a few days once the information is complete.

GPSR (General Product Safety Regulation)Jewelry & WatchesUnited Kingdom 🇬🇧