If you source products from outside the UK and sell them on the UK market, you are legally an importer. That status carries specific obligations that many sellers don’t realise they’ve taken on.
The UK’s product regulations assign responsibilities to different economic operators: manufacturers, importers, distributors, and authorised representatives. When you buy from a Chinese supplier and sell into the UK, you slot into the importer role — even if you’re selling on Amazon, even if you’re a one-person business, and even if you’ve never thought of yourself that way.
What Importers Are Legally Required to Do
Verify compliance before placing products on the market. You must check that the manufacturer has carried out the required conformity assessment, compiled the necessary technical documentation, and correctly applied the required marks (UKCA or CE as applicable).
Ensure documentation is available. You must be able to provide the Declaration of Conformity and technical documentation to market surveillance authorities (Trading Standards) for 10 years after the product was placed on the market.
Affix your own details to the product. Under UK regulations, imported products must carry the importer’s name, registered trade name, or registered trade mark, and the postal address where they can be contacted. This can be on the product, its packaging, or an accompanying document.
Check storage and transport conditions. Importers must ensure that storage or transport conditions during their control don’t jeopardise the product’s compliance with applicable requirements.
Take action on non-compliant products. If you have reason to believe a product you’re selling doesn’t comply, you must take corrective action, inform the relevant authorities if necessary, and keep records.
The Own-Branding Question
If you attach your own brand name or trademark to a product from a supplier — what’s sometimes called private labelling — you step up from importer to manufacturer in the eyes of UK law. This means you take on full manufacturer responsibilities, including being responsible for the conformity assessment and holding the technical file.
This is a significant distinction. Many Amazon sellers who own-brand products from China are unaware that they are legally treated as the manufacturer of those products.
Why This Matters for Amazon Sellers
Amazon’s compliance requests are a reflection of your underlying legal obligations as an importer or manufacturer. The documentation Amazon asks for — Declarations of Conformity, test reports, technical files — is the documentation you’re already legally required to hold. If you can’t satisfy Amazon, you likely also couldn’t satisfy a Trading Standards investigation.
How ComplyHive Can Help
SOS Compliance Call (£175) — A 60-minute session to establish your legal position, identify your specific obligations for your products, and map out what documentation you need.
Amazon Compliance Health Check (£495) — Full audit of your top 10 ASINs against your obligations as importer or manufacturer, with a written report and prioritised action plan.