Product Safety Rules for UK Craft Sellers

The General Product Safety Regulations 2005 apply across Great Britain to consumer products generally, and they are what sits underneath the specific regimes most craft sellers think about first. CLP tells you how to label a hazardous mixture. The Cosmetics Regulation tells you what a cosmetic needs. GPSR 2005 says the product has to be safe in the first place — and adds two producer duties about information and identification that are easy to miss because they are not label rules in the CLP sense.

If you make candles, wax melts, diffusers or bath products, GPSR is the regime you have almost certainly never read and are nonetheless subject to.

If you heard about "GPSR" from a marketplace notice, you probably mean the EU regulation. Regulation (EU) 2023/988 — also called "GPSR" — applies from 13 December 2024 to products placed on the EU and Northern Ireland market. OPSS states the key duty: "Article 16 of the GPSR sets out that products can only be placed on, or made available to, the NI market if there is a responsible economic operator established in either NI or the EU to fulfil certain compliance tasks." Two things to read carefully there. The role is a responsible economic operator — that is not the cosmetics Responsible Person, which is a different regime and a different duty. And establishment in Northern Ireland or the EU satisfies it, so shipping into NI does not by itself mean you need an EU presence: OPSS notes that the operator can be the manufacturer, an authorised representative, the importer or a fulfilment service provider, and that "there are private sector services available if an EU or NI-based representative is required". This guide covers the GB regime: the General Product Safety Regulations 2005. If you sell into the EU or NI as well as GB, you are subject to both regimes and need to check the EU one separately.

This covers Great Britain. This is not legal advice.

The General Safety Requirement

Regulation 5 is short, and unconditional in its own wording:

"No producer shall place a product on the market unless the product is a safe product."

The following subsections extend the same prohibition to offering, agreeing to place on the market, exposing, possessing for supply, and supplying. There is no de minimis and no hobby carve-out in the wording.

⚠️ "Unconditional" describes the sentence, not its reach. Regulation 3 limits when regulation 5 applies at all. Regulation 3(1): "Each provision of these Regulations applies to a product in so far as there are no specific provisions with the same objective in any relevant enactment governing the safety of the product." And regulation 3(2)(a) is explicit that where another relevant enactment covers a risk, "the definition of 'safe product' and 'dangerous product' in regulation 2 and regulations 5 and 6 shall not apply to such a product in so far as concerns the risks or category of risks covered by the specific provisions of the enactment". So GPSR is residual: it fills the gaps other regimes leave, rather than stacking a second safety duty on top of them.

"Producer" is broader than "manufacturer" — if you make the thing, you are the producer. The territorial extent marker on the regulation is U.K.

Two Producer Duties That Are Not Label Rules

Regulation 7 adds obligations beyond safety itself. Both carry qualifiers, and the qualifiers matter — this is a place where secondary guidance routinely overstates the duty.

Information and warnings. Regulation 7(1):

"Within the limits of his activities, a producer shall provide consumers with the relevant information to enable them—(a) to assess the risks inherent in a product throughout the normal or reasonably foreseeable period of its use, where such risks are not immediately obvious without adequate warnings"

Note the two qualifications: within the limits of his activities, and the duty engages where such risks are not immediately obvious without adequate warnings. This is not a flat rule that every product carries warnings. It is a duty to inform where the risk would otherwise be non-obvious.

Producer and batch identification. Regulation 7(4) requires:

"except where it is not reasonable to do so, an indication by means of the product or its packaging of—(i) the name and address of the producer, and (ii) the product reference or where applicable the batch of products to which it belongs"

Again the qualifier is doing real work — except where it is not reasonable to do so, and where applicable on the batch limb. It is a qualified duty, not an absolute one.

⚠️ Worth stating plainly, because the two get merged: regulation 5's wording carries no qualifier, while the warning duty in regulation 7 is qualified on its face. "Every consumer product must be safe and must carry adequate warnings" collapses two different rules into one and overstates the second. Keep that separate from the question of reach — as above, regulation 3 can switch regulation 5 off entirely for risks another regime already covers.

How This Sits Alongside CLP and Cosmetics

For a maker with a mixed range, these regimes answer different questions — and they do not simply stack. Regulation 3 makes GPSR the residual layer: it applies to the aspects and risks the specific regimes do not cover.

	What it governs	Applies to
GPSR 2005	The product must be safe; qualified duties on information and producer/batch identification	Consumer products generally — but only for risks no specific regime already covers (reg 3)
GB CLP	Hazard classification and the hazard label, where the mixture classifies as hazardous	Chemical mixtures — candles, wax melts, diffusers, room sprays
Cosmetics Regulation	Safety assessment, Responsible Person, notification, cosmetic labelling	Products applied to the body — soap, balms, bath bombs

What that means concretely. The Cosmetics Regulation carries its own general safety duty. Article 3: "A cosmetic product made available on the market shall be safe for human health when used under normal or reasonably foreseeable conditions of use". So for a soap or a bath bomb, that duty is the one doing the work, and regulation 5 is switched off for the risks it covers. A soap maker is not meeting two separate general safety requirements; she is meeting the cosmetics one. Where GPSR still bites on a cosmetic is the ground the Cosmetics Regulation does not occupy — for example the producer and batch identification duties in regulation 7, which survive because regulation 3(2)(b) disapplies only what is covered elsewhere.

The practical consequence is that clearing your CLP label does not discharge GPSR. A correctly classified and labelled candle that is nonetheless unsafe — an unstable container, a wick that tunnels and cracks the glass — fails regulation 5 regardless of how good the hazard label is.

What This Means in Practice

The producer-identification duty in regulation 7(4) is the one with the clearest day-to-day consequence. Being able to point at a product and say which batch it came from is what makes a proportionate response possible if something goes wrong. Without it, a single complaint about one candle becomes a question about every candle you have ever sold.

That is the same argument the cosmetics side makes through the Product Information File and batch codes, arrived at from a different direction. Our guides to cosmetic batch codes and the Product Information File cover the cosmetics version.

For candles specifically, product safety also brings in the voluntary standards on warning labels and fire safety, which sit alongside rather than inside GPSR — see candle warning labels.

Current Status

The General Product Safety Regulations 2005 remain in force, and the legislation.gov.uk entry for the instrument records no known outstanding effects.

UK product-safety law is an area under active reform, so this is worth re-checking against legislation.gov.uk rather than assuming it holds indefinitely.

Northern Ireland

This guide covers Great Britain. Northern Ireland follows EU product safety rules, which have diverged from the GB position. If you ship to Northern Ireland or into the EU, check that side separately rather than assuming the GB answer carries across — the same caution applies here as it does to CLP in NI.

Common Questions

Does GPSR apply to handmade products?

Yes. The regulations apply to producers placing consumer products on the market, with no exemption for handmade, small-batch or hobby production.

Do I need to put my address on every product?

Regulation 7(4) requires an indication of the producer's name and address on the product or its packaging, except where it is not reasonable to do so. Treat it as the default and the exception as something you would need a reason for.

If my candle has a CLP label, am I covered?

No. CLP addresses hazard classification and labelling. GPSR's general safety requirement is a separate duty about the product being safe, and a compliant label does not answer it.

Does GPSR require batch codes?

Regulation 7(4) refers to the product reference or, where applicable, the batch — and is qualified by "except where it is not reasonable to do so". It is a qualified duty rather than an absolute batch-code requirement. Note this differs from the cosmetics position, where a batch identifier is a required label element.

Who enforces it?

Product safety enforcement sits with local Trading Standards. Note that GB CLP enforcement is split differently depending on route to market, so the two regimes do not necessarily bring the same enforcing authority.

Related Guides

• Laws on selling homemade crafts in the UK: what you must know
• Legal requirements for selling homemade candles and wax melts in the UK
• CLP labels: the complete UK guide for craft sellers
• Candle warning labels: what UK makers must include

CraftCert covers the CLP side — classification from your formulation, the hazard label, and batch records that tie a product back to what it was made from. It does not assess whether a product is safe under the general safety requirement; that is a product-design question. Our scope page sets out the boundary.

Sources

• legislation.gov.uk — General Product Safety Regulations 2005, regulation 3 (application — GPSR is residual to other relevant enactments)
• legislation.gov.uk — General Product Safety Regulations 2005, regulation 5 (general safety requirement)
• legislation.gov.uk — Cosmetics Regulation (EC) No 1223/2009, Article 3 (safety)
• legislation.gov.uk — General Product Safety Regulations 2005, regulation 7 (other obligations of producers)
• legislation.gov.uk — General Product Safety Regulations 2005 (contents and current status)
• legislation.gov.uk — GB CLP, Article 4 (general obligations)
• GOV.UK / OPSS — EU Regulation 2023/988 on general product safety: detailed guidance (the NI position and the responsible economic operator)