Same product, different rules
A UK business selling into Ireland today is a non-EU business. That's the part a lot of companies still haven't fully absorbed. The product on the shelf in Manchester is the same one going into a warehouse in Dublin, but the paperwork behind it, the marks on it and the people named on the label all have to answer to EU law.
Ireland is usually the first EU market UK sellers try. Same language, short shipping lanes, customers who already know the brand. It's also where the gaps show up first: at customs, on Amazon and eBay when a listing gets suppressed, or when the Competition and Consumer Protection Commission (CCPC) asks who is responsible for a product.
I've spent 21 years in manufacturing, 12 of them in quality and compliance, most recently managing CE and product compliance for an Irish manufacturer selling across Europe. With Ninety8 Compliance, I'm now working with UK businesses that want to sell into Ireland and the EU without finding out the hard way what's missing.
Five things your product needs before it ships
- CE marking, not UKCA. UKCA is not recognised anywhere in the EU. If your product falls under EU product legislation (electrical, radio, toys, machinery and so on), it needs CE marking and the testing to support it. Great Britain now accepts CE marking indefinitely for most product types, including toys, machinery, radio equipment and PPE, so building to CE usually gives you one product for both markets.
- An EU Declaration of Conformity. Your UK Declaration doesn't carry across. You need an EU version that lists the EU directives and regulations, the harmonised standards you applied, and who signed it. It's a short document, but it's the first thing an authority or marketplace asks for.
- Someone established in the EU. For most consumer products, there has to be an economic operator based in the EU: a manufacturer, an importer, an authorised representative or a fulfilment service provider. Their name and contact details go on the product, its packaging or the accompanying documents. A UK address on its own doesn't meet the requirement.
- GPSR labelling and online listings. Since 13 December 2024, the General Product Safety Regulation applies to almost every consumer product. Each product needs a type or batch number, manufacturer details and the EU responsible person's details. If you sell online, the same information has to appear on the listing, along with warnings and safety information in the language of the country you're selling into.
- Packaging and producer registration. The EU Packaging and Packaging Waste Regulation has applied since 12 August 2026, bringing new requirements on packaging materials and the documents behind them. Separately, Ireland has producer responsibility schemes. Electrical products and batteries must be registered with Producer Register Ltd, and if you sell them direct to Irish customers from the UK, you must appoint an authorised representative in Ireland to do it. Packaging producers usually meet their obligations by joining Repak.
A note on Northern Ireland
Under the Windsor Framework, EU product rules still apply in Northern Ireland. That means CE marking, the EU Declaration of Conformity and GPSR all apply to goods placed on the NI market, even when they ship from Great Britain. If you already sell into Belfast, you may be closer to EU-ready than you think. If you've been relying on UKCA alone, NI is a gap today, not a future one.
The mistakes that come up again and again
- Shipping with UKCA only. It's the most common one, and it stops goods at the first check.
- A Declaration of Conformity that names the wrong laws. UK regulations referenced instead of EU ones, or standards that have since been superseded.
- No EU address on the product. The UK head office is on the label, but nobody in the EU is.
- Marketplace listings missing GPSR details. Amazon and eBay now check, and incomplete listings get blocked.
- Forgetting packaging and producer registration. It's not about the product's safety, so it gets overlooked until a letter arrives.
- Assuming the distributor has it covered. Sometimes they do. Often they assume you do.
Where to start
You don't need to rebuild your compliance from scratch. In most cases the testing is already done and the product is fine. What's missing is the EU paperwork, the right names on the label and a few registrations.
I've put the essentials into a free five-page guide, Selling from the UK into Ireland and the EU. It covers the five essentials, who's who in the EU supply chain, a document checklist and the common mistakes. You can download it here.
If you'd rather talk it through, I'm happy to look at what you already have and tell you plainly what's missing. Book a 30-minute call.