A retailer in Manchester sells the same kettle to a customer in Leeds and a customer in Belfast. Both are in the United Kingdom. Both orders leave the same warehouse. Only one of them is legally straightforward.
That is the situation under the Windsor Framework, and it is the single most common question we get from British clients. Northern Ireland follows EU product safety rules, Great Britain does not, and the gap between the two has widened rather than closed since the General Product Safety Regulation took effect on 13 December 2024.
This article sets out what actually applies, what does not, and what a GB business needs in place to keep selling into Northern Ireland without interruption. We are Westwood Sourcing, based in Breda, and we act as EU Authorised Representative for over 300 non-EU brands, a growing share of them British.
The short version
If you are established in Great Britain and you sell consumer products to customers in Northern Ireland:
- GPSR applies to those sales, because Northern Ireland follows EU product safety law under the Windsor Framework
- You need a Responsible Person established in the EU or in Northern Ireland, because Great Britain no longer counts as inside
- Their contact details go on the product, the packaging or accompanying documents, and on your online listings
- CE marking remains valid in Northern Ireland. UKCA is not required there
- For the same product sold in Great Britain, GPSR does not apply and UKCA becomes mandatory from 1 January 2028
In other words: one product, two regimes, and they are moving in opposite directions.
Why Northern Ireland is different
The Windsor Framework, agreed in 2023, keeps Northern Ireland aligned with EU rules for goods in order to avoid a hard border on the island of Ireland. For product safety that means the EU rulebook applies in Northern Ireland while Great Britain follows its own, increasingly divergent, UK regime.
Most British businesses understood this as a customs and paperwork issue about moving goods across the Irish Sea. What caught people out is that it is also a product compliance issue, and GPSR made that visible. From 13 December 2024, every consumer product placed on the EU market, and therefore the Northern Ireland market, needs a named economic operator established inside that market.
A company registered in Birmingham is not established inside that market. It is, from the perspective of the regulation, a third-country business. The fact that Belfast is in the same country is legally irrelevant.
What this means in practice
You need a Responsible Person
The Responsible Person must be established in the EU or in Northern Ireland. In practice most GB businesses appoint an EU-based Authorised Representative, partly because the same appointment then also covers sales into the Republic of Ireland and the rest of the EU, and partly because there are simply more providers.
Their role is to hold your product safety documentation, be the contact point for market surveillance authorities, and coordinate corrective action if a product turns out to be unsafe. It is not a rubber stamp: authorities do contact them, and they do have obligations.
Their details go on the product
Product identification, manufacturer details, the Responsible Person contact and a traceability code such as a batch or serial number all need to be visible on the product, its packaging or accompanying documents. Warnings and safety information need to be in a language the consumer understands.
This is where the dual-market problem becomes physical. Most British brands we work with now dual-label: one label carrying both the UK and the EU or NI information, so a single stock pool serves both markets. Separating stock into GB and NI streams is possible but expensive, and it tends to go wrong the first time a warehouse picks from the wrong pallet.
Online listings count too
If you sell into Northern Ireland through your own website or a marketplace, the compliance information needs to be visible on the listing before purchase, not just on the box. Marketplaces enforce this themselves: Amazon, Etsy and others check the Responsible Person field and suppress listings where it is empty.
CE and UKCA: the part that is about to get more confusing
Alongside GPSR sits the conformity marking question, and here the two markets are actively diverging.
|
Great Britain |
Northern Ireland |
|
|
Product safety regime |
UK rules, EU GPSR does not apply |
EU rules, EU GPSR applies |
|
Responsible Person |
Not required under EU GPSR |
Required, in EU or NI |
|
Conformity marking |
UKCA, with CE accepted until 31 December 2027 |
CE marking, fully valid, UKCA not required |
|
From 1 January 2028 |
UKCA mandatory |
CE unchanged |
Read that bottom row carefully. From January 2028 a product sold in Great Britain needs UKCA marking, while the same product sold in Belfast needs CE marking. Businesses selling into both will be carrying two markings, or dual-marking, from that point on.
That is eighteen months away, which sounds comfortable until you remember that packaging artwork, moulds and product tooling have lead times measured in months. If you are redesigning packaging this year for any reason, factor it in now rather than reprinting in 2027.
What we see going wrong
Four patterns come up repeatedly with British clients.
Assuming domestic sales are exempt. The most common one. Northern Ireland feels like home turf, so the EU rules do not come to mind until a marketplace listing is suppressed or a retailer asks for the Responsible Person details.
Appointing a Responsible Person in Great Britain. It has to be in the EU or Northern Ireland. A UK compliance consultancy based in London does not satisfy the requirement, however competent they are.
Treating it as a customs question. Your freight forwarder handles the movement of goods. Product compliance is a separate track, and forwarders generally will not take it on.
Waiting for clarity that is not coming. The Windsor Framework is settled arrangement, not a temporary measure. The divergence between GB and NI product rules is the design, not a transitional glitch.
What to do, in order
- Confirm whether you actually sell into Northern Ireland. Check your order data rather than your assumptions. Plenty of businesses discover a steady trickle of Belfast postcodes they had never separated out.
- Appoint a Responsible Person in the EU or Northern Ireland. An EU-based appointment covers Northern Ireland, the Republic of Ireland and the rest of the EU in one go.
- Update your labelling. Dual-label so one stock pool serves both markets. A sticker is an accepted interim measure while the next print run is prepared.
- Update your online listings. Add the Responsible Person details wherever compliance information is requested, including marketplace fields.
- Check your technical documentation. GPSR requires it to exist and to be producible on request. If your supplier has never been asked for test reports, now is the moment.
- Plan for UKCA before 2028. Not urgent this quarter, but it belongs in your next artwork and tooling cycle.
Is it worth it for a small volume?
This question comes up honestly and deserves an honest answer. If Northern Ireland is a handful of orders a year, some businesses do choose to stop shipping there. That is a legitimate commercial decision.
But the arithmetic usually favours compliance. An EU Authorised Representative appointment costs a few hundred pounds a year and covers unlimited products. The same appointment opens the Republic of Ireland and the rest of the EU, which is a market of 450 million people rather than 1.9 million. Most clients who came to us for Northern Ireland ended up using the appointment for far more than that.
Conclusion
Northern Ireland follows EU product safety rules, and that makes a British seller a third-country seller in part of its own domestic market. GPSR applies, a Responsible Person established in the EU or Northern Ireland is required, and their details need to be on the product and on your listings.
The good news is that this is administrative rather than technical. There is no product redesign, no new testing, no fundamental change to what you sell. It is an appointment, a label update, and a documentation check. Most of our British clients are set up within a week.
Selling into Northern Ireland from Great Britain?
We act as EU Authorised Representative from 150 EUR per year, covering unlimited products, Northern Ireland, the Republic of Ireland and all 27 EU member states under one mandate.
Order the service, or book a free 30-minute call and we will tell you whether you actually need it. Sometimes the answer is no, and we will say so.
Sources
- European Union. Regulation (EU) 2023/988 regarding General Product Safety (GPSR). EUR-Lex.
- Northern Ireland Assembly. Windsor Framework timeline. niassembly.gov.uk
- UK Government. UKCA marking guidance. gov.uk
- Europese Commission. Product safety and compliance. commission.europa.eu
