Ok, some clarifications on the above...
Amazon sellers based in the UK who only want to sell on Amazon.co.uk (inc. Northern Ireland) can be their own RP, provided they know what they are doing. If they don't and something goes wrong, they could be liable
To do this you must have a registered entity (e.g. LTD Co) in the UK and it depends on the products. If you were selling in a high-risk category like food supplements or baby toys, do you really want to be the responsible person?
The RP only takes responsibility for labelling by the way, not the product itself. They will review the label and compare it to the Amazon listing to check they match (and will recommend changes to the listing if they don't) but if you change the product without telling them or lie about it in some way, then the liability is yours.
I am going to get several quotes for this but the company I have been talking to (who was recommended by someone I trust) charges £1000 for year one. Year 2+ prices TBC
It isn't quite this simple as it happens. When a company agrees to be your RP, they are taking responsibility for your product labelling and they aren't going to do that without checking it first, for which there is a charge.
The company I have been talking to assesses this case-by-case and it can be quite complicated. Generally they charge per parent SKU, so if you have a product that comes in 6 sizes and 10 colours (=60 ASINS) they would only need to do one label review. In my case, one of my big products contains some of my smaller products, which I also sell separately - again only one label review is needed. If you are selling lots of completely different items then it could get expensive though as potentially each one would need a review.
In the case of handmade items, you still need to have a label review but it could be done at the ingredient level. So you might make 50 different products but you might only need 1 review to cover everything. Again, looked at case by case.
If you add other products later on, there would be no review needed if they were just variations. But if it was a brand-new range then a new label review would be needed in order to be covered by the RP.
So not quite as simple as paying off a company and forgetting about it. They are taking responsibility for your labelling so they need to have all the information.
Products should already have the manufacturer details on the packaging. I am waiting for confirmation that this is still a requirement or whether the RP info replaces it.
You need to put the RP details on the packaging or include it on an insert. Either solution is fine for products of any size. This does not replace the manufacturer details, which should already be there.
I am also waiting for confirmation that only the RP details need adding? I have heard about extra requirements for batch numbers, model numbers, types, etc? I am guessing this depends on the product (whether it expires for example will play a part)
This isn't needed for general products - only for things like supplements, foods with expiry dates, etc (you guessed it - assessed case by case). However it is recommended as a best practice. If, for example, your customers report a problem with your product, it is useful to be able to trace it back to a batch. This is more difficult when printed on the product packaging (we have thousands of boxes produced at a time and use them as needed for several batches) but easier with inserts. So you may consider talking to your factory and getting them to include a flimsy piece of paper for each batch.
There is also talk of safety/compliance information in the native language. I am waiting for confirmation of which products need this and if there are exemptions.
Again, it depends on the product. Any safety warnings need to be in multiple languages (that really thin flimsy bit of paper that you instantly chuck when buying a toaster). The same for any instructions. Relatively cheap and easy to put in place and once done, you can forget about it.
"Although the GPSR entered into force on 12 June 2023, it will apply from 13 December 2024. The new GPSR does not prevent the sale of products which are in conformity with the GPSD and are placed on the market before 13 December 2024."
For stuff that is already in FBA, Amazon is unlikely to go around opening boxes. In fact the impression I got was that Amazon is box-ticking to keep the EU happy. You will definitely need an RP on your account if you are selling into the EU but will Amazon police inserts and product packaging? Almost certainly not. Should you stick your head in the sand and assume they never will - again, probably not. Yes, adding inserts/altering packaging is a pain and may have a slight cost but you may as well do it and sleep easy.
I'm afraid it sounds like you don't have any choice about having an RP person if selling into the EU and label reviews for anything they will be taking responsibility for, which will put smaller sellers with a very broad range of completely different products out of business.
what if you make your own stuff, say, posters, gel stuff, and arts & crafts? How does that work?
Yes, still need to go through the process. If only selling in the UK/NI you can be your own RP. If selling into the EU, you need to pay someone to do it and they will charge for label reviews, although as I said above, they could do just one review for all the materials you use and this would cover all products.
Still, what’ll happen is that they’ll eventually keep emailing to say you need to add the EU RP to all your listings or they’ll end up deactivated
Nothing is added at the listing level (unless the RP sees something in the label that doesn't match the listing, in which case they will recommend changes in order to comply). It is done at the account level and if you don't have an RP in place by 13th December, you could be deactivated right across Europe until you do (as it was with EPR). Technically you should also have amended your packaging or included inserts but I can't see how Amazon will police this, at least in the short term.
I would be keen to see the 1000eur / year provider and who it is, any info you can share? Then I can atleast worry a little less. I could live with paying that to continue to send my stuff to EU. Assuming it’s a case of providing the info for your items and it’s not overly cumbersome like the generic makeup of a printed poster or a gel resin custom made one-off keyring or something like that, or something mad like the burning fumes and co2 content when it’s on fire etc.
I'm trying to convince them to offer a discount to people I refer over. I deal with lots of companies and can send them a lot of business so hopefully I can coordinate something. I can PM you their details now or you can hold fire until I sort something. I'm a lot more relaxed about this than I was by the way. There is no mad rush - the whole process should be done within 2-3 weeks so you can hang fire for a while.
In the case of A, if the info is on the packaging and we don't need to do anything - how would Amazon know this, would that be because we would not have created the listing?
If you are sending products out to customers in the EU, you will need an RP on your Amazon account. They will asses the products and let you know. Presumably Amazon trusts that RP companies will make sure sellers are doing what they need to do.
With regards to B - who is being defined as a distributor here by the EU? The last I read was quite vague and seemed to suggest anyone other than the brand is basically a distributor in their eyes.
Basically whoever is sending products out to customers. It's a bit like EPR where the seller is the 'producer'. If you are selling on Amazon in the EU you need an EP on your account regardless. They will check each product label/packaging/insert and let you know if you are compliant. If this has been done at the manufacturer/distributor level then you won't need to do anything. If not, your new RP will tell you what needs to be done and, once done, they will be responsible for your labelling/packaging (not the product itself though).
Phew - I hope that helps. Any questions let me know.
