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Black Friday & Cyber Monday Compliance Checklist: Selling Safely in the EU & UK
Black Friday and Cyber Monday are the biggest shopping days of the year across Europe and the UK. For most sellers, they bring a welcome boost in traffic and sales, but they also come with extra scrutiny.
With flash deals, product launches, and busy fulfilment centres, it’s easy to lose sight of one thing that never takes a break: compliance.
Both the EU’s General Product Safety Regulation (GPSR – Regulation (EU) 2023/988) and the UK’s General Product Safety Regulations 2005 put clear responsibility on sellers, importers, and online marketplaces to make sure every product is safe, traceable, and properly documented.
Whether you’re selling within the EU or UK, or shipping from abroad, this checklist will help you confirm that your products, packaging, and data practices are all in order before the first sale goes live.
1. Make Sure Your Products Are in Scope
The GPSR and the UK’s equivalent safety laws apply to almost all non-food consumer products, including:
- Electronics such as chargers, headphones, and small appliances
- Toys and baby products
- Cosmetics and personal care items
- Clothing and accessories
- Homeware and decorative goods
If you sell any of these during Black Friday or Cyber Monday, your products are covered by product safety and consumer protection laws.
In addition to the GPSR, some products must also meet specific directives or standards, such as:
- Low Voltage Directive (LVD) or EMC Directive for most electrical and electronic goods
- Toy Safety Directive (2009/48/EC) for children’s toys and accessories
- Cosmetics Regulation (EC) 1223/2009 for beauty and personal care products
- Textile Labelling Regulation (EU) 1007/2011 for clothing and fabrics
- REACH and CLP Regulations for any product containing chemicals, coatings, or dyes
Quick note: Article 2 of the GPSR defines its scope broadly as any product intended for, or reasonably expected to be used by, consumers. The UK’s rules follow the same principle and reference harmonised standards under UK law.
2. Appoint a Responsible Person
If your business is based outside the EU or UK, you’ll need a local contact who can take regulatory responsibility for your products.
Depending on what you sell, this role may be called a Responsible Person (RP) or an Authorised Representative (AR).
Under the GPSR, the Responsible Person ensures your products meet all safety and documentation requirements and serves as the official contact for authorities.
For products covered by specific laws, such as the Medical Devices Regulation (MDR), the Cosmetics Regulation (EC) 1223/2009, or the Toy Safety Directive, the Authorised Representative or Responsible Person has similar responsibilities tailored to that product type.
Your RP or AR should be able to:
- Provide safety and compliance documentation when requested
- Communicate with market surveillance authorities
- Support traceability and manage recalls
Tip: Online marketplaces such as Amazon, eBay, and Zalando often require proof of an EU or UK Responsible Person or Authorised Representative before you can list certain products.
3. Keep Your Technical Documentation Up to Date
Before you start selling, make sure your technical file is complete and ready for inspection. It should include:
- A product risk assessment, including any foreseeable misuse
- Testing results and certifications
- Details of materials and components
- Batch numbers and supplier records
Keep all documentation for at least 10 years, as authorities can request it at any time, especially during busy sales periods when consumer complaints are more common.
Discover our ready-to-use product compliance templates, including risk assessment and technical file templates, to help you stay organised and meet GPSR and UK safety requirements efficiently.
4. Double-Check Labels and Packaging
Labelling mistakes are one of the most common causes of compliance problems. To stay compliant, make sure every item clearly shows:
- The manufacturer’s and Responsible Person’s name and address (EU or UK)
- Product identification, such as a model or batch number
- Any warnings or age restrictions in the consumer’s language
Your online listings should match exactly what appears on your product and packaging. Even small inconsistencies can lead to marketplace removals or regulatory action.
5. Review Online Listings and E-Commerce Setups
Product safety rules apply just as much online as they do in physical stores. Review your website and marketplace listings to make sure that:
- Product photos and descriptions match what customers actually receive
- Safety warnings are clearly visible before purchase
- Your Responsible Person’s contact details are included
- Every order can be traced back to a specific batch or supplier
If you use fulfilment centres or dropshippers, confirm that they follow your safety and recall procedures. Regulators now hold everyone in the supply chain accountable.
6. Don’t Overlook Data Protection and GDPR Representatives
Black Friday and Cyber Monday bring a major surge in personal data — from customer names and addresses to payment details and browsing activity.
If your company is based outside the EU or UK but sells to customers in those markets, you’re still responsible for protecting that data.
Under Article 27 of the EU GDPR and UK GDPR, you must appoint an EU and/or UK GDPR Representative.
The Representative:
- Acts as your official contact for customers and regulators
- Maintains your Records of Processing Activities (RoPA)
- Helps ensure your privacy and cookie policies meet local requirements
If you collect EU or UK customer data through platforms like Shopify, WooCommerce, Meta, or Google Ads, appointing a GDPR Representative is essential for staying compliant and maintaining trust.
7. Be Ready for Recalls and Inspections
Regulators across the EU and UK often carry out test purchases during busy shopping periods. If a product doesn’t meet safety standards, they can issue recall orders. That includes sellers based outside the region.
Make sure you can:
- Identify affected batches quickly
- Notify customers and distributors without delay
- Provide corrective action reports to authorities
Keep an eye on the the EU Safety Gate (https://ec.europa.eu/safety-gate) and the UK’s OPSS product recalls list to stay informed about similar products that have been flagged.
8. Register for Environmental and Packaging Schemes
Beyond product safety, both the EU and UK enforce Extended Producer Responsibility (EPR) rules for packaging waste.
If you sell or ship products to markets such as France, Germany, or the UK, you’ll likely need to register with national packaging schemes and report the types and amounts of materials you use.
Failing to register can lead to fines, blocked listings, or even sales bans. Marketplaces are also increasingly requiring sellers to provide valid EPR registration numbers before allowing new listings.
9. Test and Verify Product Safety
Testing isn’t just good practice. It’s your proof of compliance. Depending on your product, you may need to conduct:
- Electrical safety tests (EN 60335, EN 60950)
- Toy safety tests (EN 71 series)
- Chemical safety checks (REACH and CLP)
- Flammability tests (for textiles or furniture)
Keep all test reports on file and ready to share with your Responsible Person or with authorities if requested.
10. Plan Beyond the Sales Weekend
After Black Friday comes Cyber Monday, followed by the busy holiday season. Use this period to review and strengthen your compliance processes:
- Review feedback and product returns for any safety trends
- Record all complaints and how they were resolved
- Audit your suppliers and renew testing where necessary
- Schedule a full compliance review before next year’s sales season
A Quick Note for UK Sellers
If you sell to UK consumers, the rules are similar but not exactly the same.
While the EU’s GPSR took effect in 2024–2025, the UK still follows the General Product Safety Regulations 2005, which include many of the same requirements such as safety assessments, documentation, and traceability.
If your business is based outside the UK but sells to UK customers or processes their data, you’ll also need a UK GDPR Representative in addition to your EU one. This helps ensure that regulators and consumers can reach you easily and that your listings stay active on platforms like Amazon UK or eBay.
Euverify supports both regions, offering EU and UK Responsible Person and GDPR Representative services to help brands sell confidently across borders.
Final Takeaway
Black Friday and Cyber Monday aren’t just about driving sales. They’re also a test of how prepared your business is for today’s tougher compliance standards.
Under the EU GPSR and UK safety laws, every product you sell must be safe, traceable, and properly documented. And under the EU and UK GDPR, all customer data must be handled lawfully and transparently.
For cross-border sellers, it really comes down to two key requirements:
- An Authorised Representative or Responsible Person to manage product safety and documentation
- A GDPR Representative to oversee data protection compliance
Together, these steps protect your customers, strengthen your reputation, and help your business run smoothly during the busiest shopping season of the year.
Euverify makes EU and UK compliance simple for global sellers. We handle everything from GPSR documentation and packaging registration to GDPR representation.
This season, make compliance part of your brand promise.
Practical Guide to Clothing, Apparels, and Textile Compliance in the UK & EU
A helpful guide that provides a comprehensive overview of compliance for Clothing, Apparels, and Textiles.
Technical Files Checklist & Risk Assessment Template
For Clothing, Apparels, and Textiles
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Appoint Your EU Representative & Ensure Compliance for Your Clothing, Apparels, and Textile
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