Comparative Summary of EU GPSR (Regulation (EU) 2023/988) vs UK GPSR (UK SI 2005 No.1803)

This article is provided by BRC Associate Member, UL Solutions.

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Following a proposal from the European Commission (EC), the European Union (EU) replaced the General Product Safety Directive 2001/95/EC with the Regulation on General Product Safety (EU) 2023/988 (EU GPSR), which came into effect on Dec. 13, 2024. The EU GPSR applies directly to all EU member states and Northern Ireland. It aims to modernize product safety rules and address digitalization and distance sales, including sales through online marketplaces.

The United Kingdom (U.K.) has the General Product Safety Regulations 2005, United Kingdom Statutory Instrument 2005 No.1803 (U.K. GPSR), which was implemented under the General Product Safety Directive 2001/95/EC when the U.K. was an EU member state.

The U.K. GPSR is Retained European Union Law (REUL) for Great Britain (England, Scotland and Wales). U.K. GPSR remains largely unchanged since the U.K. left the EU, creating regulatory divergence between the EU (including Northern Ireland) and Great Britain (GB).

Key differences

1. Scope and coverage

EU GPSR: Fully applies to consumer products that are not subject to product-specific safety requirements imposed by Union harmonized legislation, including second-hand, refurbished and recycled goods and those incorporating digital technologies. It also applies to all products where risks are not covered elsewhere, and all products sold online, including via online marketplaces. It identifies specific exempt products, e.g., medicines, food, feed and plants.

U.K. GPSR: Focuses on new consumer products that are not subject to product-specific safety requirements and products where risks are not covered elsewhere. It does not explicitly address online sales or digital product features.

2. Digitalization and online marketplaces

EU GPSR: Introduces new obligations for distance sales and online marketplaces to help prevent unsafe products from reaching consumers. It requires that warnings and safety information be disclosed where necessary and strengthens traceability and safety mechanisms for connected products and those with cybersecurity risks.

Online marketplace providers must fulfil specific product safety obligations. These include establishing a single point of contact for product safety and designing their interface to display accessible product information. Providers must also implement product compliance processes and suspend noncompliant traders. They are also required to register with and use the EU Safety Gate portal. Additionally, they must remove dangerous products from orders flagged by authorities within two working days.

U.K. GPSR: No specific provisions for online marketplaces or digital product safety. It relies on general safety principles without addressing modern e-commerce challenges.

3. Roles in the supply chain: Risk assessment and traceability of products

EU GPSR: Defines several new stakeholder roles, including economic operator, manufacturer, authorized representative, importer, fulfilment service provider and provider of an online marketplace. It mandates that non-EU manufacturers appoint a responsible person within the EU for compliance. The manufacturer or the person responsible must maintain technical documentation, including a documented risk assessment, and list all applicable standards or other elements applied to meet the general safety requirements. It also outlines specific rules for traceability and compliance tracking.

U.K. GPSR: Relies on producer responsibilities as defined in the 2005 regulation to place safe products on the market. It encourages safety assessments but lacks a mandatory documented risk assessment. It requires batch reference on labeling but does not mandate other traceability provisions.

4. Labeling requirements

EU GPSR: Expands labeling to include multiple economic operators name and address details (manufacturer, importer (if applicable) and responsible person (if not already shown)), including their electronic address (any electronic address that that allows for direct communication, such as an email address, or a website that allows for direct communication, e.g., by contact template) in addition to batch code, instructions and safety information (as required). Requires mandatory digital warning or safety information (where necessary) for all products made available by means of distance sales, including online marketplaces.

U.K. GPSR: Requires basic labeling for the producer (name and address), batch code and safety warnings, but lacks digital traceability elements.

5. Product recalls and consumer remedies

EU GPSR: Strengthens recall procedures and mandatory consumer remedies, which must include at least two of the three options of repair, replacement or refund. Requires timely and cost-free options for consumers.

U.K. GPSR: Provides general recall guidance but does not mandate specific remedies or consumer rights in recall scenarios.

6. Market surveillance

EU GPSR: Integrates with EU Regulation 2019/1020 for enhanced market surveillance. It uses the Safety Gate system for rapid alerts on dangerous products.

U.K. GPSR: Surveillance is managed by U.K. authorities with no equivalent EU-wide alert system.

7. Strategic implications for businesses

EU GPSR: Businesses must adapt to stricter compliance, especially for online and tech-enabled products. Non-EU manufacturers need to designate EU-based responsible persons. Enhanced documentation and proactive safety measures are essential.

U.K. GPSR: It remains simpler but fails to address modern product safety challenges. U.K. businesses exporting to the EU must comply with both regimes, increasing regulatory burden.

Following the enactment of the Product Regulation and Metrology Act 2025 on July 21, 2025, it is anticipated that the U.K. will revise its legal framework covering general product safety in time, although this Act does not immediately replace or overhaul the U.K. GPSR.

Conclusion

The EU GPSR represents a significant modernization of product safety law, aligning with digital commerce and consumer protection trends. In contrast, the U.K. GPSR currently stems from a pre-digital framework. Businesses operating across both the EU and U.K. must navigate these differences carefully to enable full compliance.

Let’s navigate this fragmented regulatory framework together

At UL Solutions, we help manufacturers and online and offline retailers meet the requirements of the EU GPSR and the U.K. GPSR. With deep expertise in consumer product regulations and a global network of experts and laboratories, we provide practical support tailored to your compliance needs. Our services include product labeling reviews, technical documentation evaluation, risk analysis assessments and educational seminars covering all aspects of GPSR due diligence. We also offer training to help you evaluate products before they enter the global marketplace.