The principles of repackaging vs. manufacturing become clearer when applied to specific sectors.

Toys and Children’s Products

Toys fall under some of the strictest rules in the EU and UK, with the Toy Safety Directive (2009/48/EC) and the UK Toys (Safety) Regulations 2011 setting detailed requirements. But the GPSR still applies as a safety net, especially for risks that aren’t fully addressed, like cybersecurity in connected toys.

Where things get tricky is private labelling. Many importers buy generic toys and sell them under their own name. Under Article 13(1) GPSR, this automatically makes them the manufacturer, with full responsibilities for conformity assessments, technical files, and CE/UKCA marking.

• If you only re-box or add multilingual warnings, you stay a distributor.
  
  
• If you put your own logo on the toy, you become the manufacturer.
  
  
• If you alter the toy, for example by adding sound modules, magnets, or new detachable parts, this counts as a substantial modification. You then assume full manufacturer duties for the “new” toy because risks such as choking or ingestion are introduced.
  
  

Electronics and Electrical Goods

Most electronics are already regulated under harmonised laws like the Low Voltage, EMC, or Radio Equipment Directives. However, GPSR still applies to any risks these do not cover.

Repackaging on its own, such as changing the retail box design, doesn’t make you a manufacturer, but you must ensure importer and traceability details are correct and visible. Rebranding, however, does: if you sell a charger under your own name, you need to hold the technical documentation, issue the Declaration of Conformity, and take responsibility for CE/UKCA marking.

Even bundling can trigger new obligations. If you package a device with a different charger than the original design anticipated, you’ve changed its safety profile and created a new product under the law.

Cosmetics and Personal Care

Cosmetics are governed by Regulation (EC) No 1223/2009 in the EU and a near-identical UK regime. Here, too, the GPSR applies as a backdrop for general safety.

Adding translations of ingredients or instructions doesn’t change your role, you remain a distributor. But as soon as you rebrand, you must also become the Responsible Person (RP) under cosmetics law, either directly or by appointing a third party. This carries obligations for CPNP/SCPN notification, maintaining the Product Information File, and ensuring the Cosmetic Product Safety Report (CPSR) is in place. 

Even packaging changes can count as substantial modifications if they affect safety. For example, a new container material that interacts with the formulation, causing instability or leaching. At that point, you are no longer simply repackaging but placing a new product on the market.

Household Goods

Many household goods, from furniture and cookware to DIY tools, fall directly under the GPSR because no harmonised legislation applies. This makes the GPSR the primary rulebook.

Here the same principle applies: re-boxing or adding sleeves keeps you a distributor, but rebranding shifts you into the manufacturer category. That means you must perform a documented risk assessment (for example, checking the stability of furniture under EN 581 or verifying the strength of cookware handles under EN 12983).

Changes that affect safety count as substantial modifications. Removing anti-tip devices from a piece of furniture, altering the handle of a DIY tool, or changing the coating on cookware can all alter mechanical or chemical safety, creating new risks and manufacturer obligations.