Introduction: The UK Is Not the EU Anymore—But It Is Not as Different as You Think
Since January 2025, the United Kingdom operates its own independent regulatory framework. For importers of adult products, this initially caused widespread confusion: would a CE-marked product still be accepted? Was UKCA mandatory? Did you need to re-certify everything?
The short answers today: CE is still accepted for most product categories. UKCA exists but is not enforced for your product type. And the main practical difference between importing into the UK versus the EU is not certification—it is VAT.
This guide explains what actually applies to adult wellness products entering Great Britain in 2026.
Part 1: CE vs UKCA—The Truth in 2026
The most common question from importers is: “Do I need UKCA marking?”
For adult wellness products: no. CE marking is accepted indefinitely.
Here is what happened. After Brexit, the UK introduced UKCA (UK Conformity Assessed) as a replacement for CE. Multiple deadlines were set, then extended, then extended again. In 2026, the UK government’s published policy is that CE marking continues to be recognized for 21 key product regulations—including those governing electronic devices and consumer products.
What this means for you:
- Products that carry a valid CE mark can be imported into the UK without additional certification
- A separate UKCA mark on the same product is permitted but not required
- The CE Declaration of Conformity you use for the EU is accepted for the UK
The one exception: If your product carries no CE mark—or carries a CE mark that is fraudulent or unverifiable—you need UKCA. But if your product is properly CE-certified for the EU market, you are covered for the UK.
The Practical Recommendation
Given that CE is accepted, the most efficient approach is to ensure your product carries CE, RoHS, and REACH certification—the same documents you use for the EU market. Do not invest in separate UKCA certification for adult products unless and until UK regulations change.
However, you should be aware that the UK is currently overhauling its product safety framework. A government consultation was issued in March 2026. Future changes are possible, but no binding new requirements have been implemented as of mid-2026.
Part 2: UK RoHS and UK REACH
While CE is accepted, the UK operates its own versions of RoHS and REACH—and these are not automatically covered by EU certification.
UK RoHS
The UK’s Restriction of Hazardous Substances regulation mirrors the EU version. The same restricted substances apply. The same testing standards are accepted.
What to ask your manufacturer: “Are your RoHS test reports from an accredited laboratory? Are they valid for the UK market?”
In practice, most EU RoHS test reports from accredited labs are accepted for UK compliance. Confirm with your manufacturer that their reports cover the UK market, or request a UK-specific addendum.
UK REACH
The UK operates an independent chemical regulation framework. Substances registered under EU REACH do not automatically transfer to UK REACH.
What this means for adult products: If your product uses silicone, ABS plastic, or other chemical substances, the manufacturer should confirm UK REACH compliance. For medical-grade silicone from a reputable manufacturer, this is typically a formality—the materials already meet the standards.
What to ask: “Can you provide a UK REACH compliance statement for the materials in this product?”
Part 3: VAT and Customs—The Biggest Practical Difference
The UK’s VAT system is where importing into the UK differs most significantly from the EU.
VAT on All Imports
Unlike the US (which exempts shipments under $800), the UK applies VAT to all imports regardless of value. The standard rate is 20%.
| Scenario | VAT Treatment |
|---|---|
| B2C order under £135 | Seller is responsible for collecting and remitting VAT to HMRC |
| B2C order over £135 | Buyer pays import VAT upon delivery |
| B2B wholesale (any value) | Buyer pays import VAT, reclaimable if they hold a valid UK VAT number |
For B2C Sellers: The £135 Threshold
If you sell direct-to-consumer in the UK and the order value is under £135, you must register for UK VAT, collect 20% VAT at checkout, and remit it to HMRC quarterly. This is mandatory—there is no minimum threshold for non-UK sellers.
If you sell through a marketplace (Amazon UK, eBay UK), the marketplace is typically responsible for VAT collection and remittance.
For B2B Wholesale Buyers
Wholesale buyers pay import VAT at the border. If they hold a valid UK VAT number, they can reclaim this VAT through their regular tax filings. The VAT is therefore a cash flow issue, not a permanent cost.
Part 4: Customs Declaration and HS Code
The UK uses the same HS code system as the EU. The recommended code for adult wellness products:
9019.10.20 — Vibrating massage apparatus
Product description on customs forms: “Electric massager” or “Personal massage device”
The same rule applies as for the US and EU: avoid “sex toy” on customs declarations. The product is legal. The words invite unnecessary scrutiny.
Part 5: The Documentation Checklist
| Document | Status for UK Import |
|---|---|
| CE Declaration of Conformity | Accepted—no separate UKCA needed |
| RoHS test report (EU or UK) | Required—confirm UK applicability |
| REACH compliance statement (UK) | Required—separate from EU REACH |
| UN38.3 battery test report | Required for products with lithium batteries |
| MSDS | Required for products with batteries |
| Commercial Invoice | Required |
| EORI number (buyer’s side) | Required for UK importers—ask your buyer to provide theirs |
Part 6: Northern Ireland
Northern Ireland operates under a different regulatory framework than Great Britain. Under the Windsor Framework, goods entering Northern Ireland from Great Britain are subject to EU customs rules. Goods entering Northern Ireland directly from outside the UK may follow UK or EU rules depending on the product category and declared destination.
For most adult product importers, the practical advice is: if your buyer is in Northern Ireland, confirm which regulatory framework applies to your specific shipment before booking freight.
Conclusion: Easier Than the EU, Harder Than the US
The UK sits between the US and the EU in terms of import complexity for adult products. Certifications are largely covered by existing EU documentation. The main additional requirements are UK-specific RoHS and REACH confirmations—typically simple addendums from your manufacturer.
The VAT system is the most significant operational difference. B2C sellers must register for UK VAT and collect it at checkout. B2B buyers pay VAT at the border and reclaim it. Unlike the US, there is no low-value exemption—every shipment is taxed.
At AmorSerere, we provide UK-compatible compliance documentation with every order bound for Great Britain. If you are sourcing adult wellness products for the UK market, start with a manufacturer who has already done the paperwork.
Related Reading
- Import Regulations: US, EU, UK & Australia (Full Comparison)
- EU Import Guide: CE, RoHS, REACH & WEEE
- US Import Guide: FDA, FCC & Customs Checklist
Last updated: July 10, 2026
