Great Britain Producer Traceability Marking: Who Counts as a Producer


The General Product Safety Regulations 2005 as explained by GOV.UK and the Business Companion guide.

Short answer: GOV.UK says producers should allow traceability by showing, where reasonable, the producer name and address and the product reference or batch on the product or its packaging. Producers include manufacturers, anyone putting their name or trade mark on the product, and importers. The Business Companion guide adds the producer must have an address in Great Britain.

Not legal, customs or tax advice. General information from public pages; confirm with the authority, your customs broker or a lawyer.

Who is a producer

SituationWho is the producer
Manufacturer established in the UKThat manufacturer
Someone presenting themselves as manufacturer by putting their name or trade mark on the productThat person (the own-brander)
Manufacturer outside the UK with a UK representativeThe representative
Manufacturer outside the UK, no UK representativeThe person established in the UK that places the product from outside the UK on the market
ImportersListed as producers

What to mark

ItemWhat the guidance says
Producer name and addressOn the product or its packaging, where reasonable; the address must be in Great Britain
Product reference or batchOn the product or its packaging, where reasonable and where applicable
Main dutyTo supply a safe product
Importer concessionWhile marking individual items is unreasonable in new arrangements, an importer may use the address on shipping documents, the GB customer invoice or the outer shipper label plus a website, but only for a limited time and not after 31 December 2027; marking each item before then is encouraged

Checks before a UK order ships

  • [ ] Decide who the producer is and write that into the contract [1]
  • [ ] Print the producer name and a Great Britain address on product or carton [2]
  • [ ] Add a product reference or batch code [1]
  • [ ] If relying on the importer concession, note its end date of 31 December 2027 [1]
  • [ ] Confirm product-specific rules separately; this guidance covers general consumer goods (general practice)

Questions answered

Who is a producer under the guidance?

GOV.UK lists UK-established manufacturers, anyone presenting themselves as the manufacturer by putting their name or trade mark on the product, importers, and certain others. Business Companion calls manufacturers, own-branders and importers producers.

Must the address be in Great Britain?

Business Companion says the producer must have an address in Great Britain and records that this was clarified in a page update.

Until when can an importer use shipping documents instead of marking each item?

GOV.UK says those alternatives are time limited and may not be used after 31 December 2027.

Further reading

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General information, not legal, customs or tax advice. Your written quote and contract govern. Examples use invented numbers unless stated otherwise.