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Artifact GuideUKSupply Chain Roles Manufacturer Importer Distributor

UK PSTI Manufacturer, Importer and Distributor Roles

Distinguish , , , and authorised-representative duties per product and supply route, including rebranding, imports, statement checks, stop-supply decisions, and compliance failures.

The guide separates binding duties from OPSS guidance, ETSI good practice, internal controls, and the limited deemed-compliance routes introduced in 2025.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections9 primary sources
Overview

Classify roles for each product and supply route. A company can be a for one product and a for a rebranded version of another. The role determines pre-supply checks, retention, investigation, stop-supply, remediation, notification, and record duties. An authorised representative can perform agreed manufacturer duties, but the appointment does not remove the manufacturer's liability.

Section 1

How to classify each role

A either makes a product or has it designed or made, and markets that product under its name or trade mark. A person that markets another person's product under its own name or trade mark is also a manufacturer. An brings the product into the United Kingdom from outside the United Kingdom and is not the manufacturer. A makes the product available in the United Kingdom and is neither manufacturer nor importer.

Apply the definitions to the legal entity, product branding, shipment, and transaction. Record the overseas separately from the UK . Installation under a works contract can fall outside the definition in the narrow circumstance described in section 7, so capture the contract and whether identical products are otherwise made available to consumers.

  • evidence: design or manufacturing control, brand or trade mark, product type and batch, first supply, and any authorised-representative agreement.
  • evidence: named overseas supplier, import records, UK entry, product and batch, importer identity, and confirmation that the importer is not the .
  • evidence: purchase and resale route, UK availability, product and batch, upstream and , and confirmation that the distributor is neither.
  • Reassess after private labelling, marketplace fulfilment changes, direct-to-consumer imports, group-company transfers, acquisitions, or contract-manufacturing changes.
Section 2

Manufacturer duties

When the statutory conditions apply, the must meet the applicable security requirements, provide the statement under the ordinary route or satisfy the current deemed-compliance conditions, investigate suspected failures, take required action, and keep the prescribed records. Where more than one person is a manufacturer, regulation 5 requires each manufacturer to meet or be deemed to meet the relevant security requirements.

  • Before supply: approve scope, Schedule 1 controls, public vulnerability and support information, statement route, product matching, and release evidence.
  • After a suspected failure: investigate, stop supply when required, remedy the failure, communicate with affected economic operators or customers as required, assess OPSS notification, and retain the investigation record.
  • Authorised representative: record the written agreement and exact duties accepted. Section 13 also gives the representative a direct duty to act on a 's compliance failure within its statutory conditions.
Section 3

Importer and distributor duties

Importers and distributors have direct duties; a supplier contract does not transfer them away. The current Schedule 1 technical requirements apply to manufacturers, while importers and distributors must perform their own statement checks and must not supply when the Act's knowledge-or-belief conditions for a compliance failure are met. Under the ordinary route, the also retains the statement for the longer of 10 years from issue or the defined support period. The has no equivalent statement-retention rule in regulations 8 and 9, but it still needs evidence of its pre-supply check and other records required by the Act.

From 4 December 2025, and checks must reflect the Schedule 2A label route when it is relied on. Verify the exact product, scheme, current label, and expiry rather than accepting a generic claim.

  • : verify the , product scope, applicable security requirements, ordinary statement or label route, accompaniment, and retention setup before supply.
  • : verify product scope and the ordinary statement or label route before supply; preserve the check against the actual stock.
  • : investigate suspected failures and retain investigation records for the statutory period. Both: apply stop-supply and remedial duties, contact upstream actors, and assess required notifications.
  • Marketplace, fulfilment, and dropship models need a transaction-level decision about who imports and who makes the product available.
Section 4

Handoff record for each supply route

Create a role matrix for the actual product and route. The matrix should identify each legal entity, its role, the duty trigger, the evidence it receives or creates, the stop-supply authority, and the compliance-failure contact. Update it when the route changes.

  • Record product type, batch, release, , authorised representative, origin country, , , sales channel, and first UK supply date.
  • Attach the statement or Schedule 2A evidence, security-control evidence index, public information URLs, retention owner, and review triggers.
  • Name who can stop orders, quarantine stock, contact customers, notify OPSS, and preserve the investigation record.
  • Do not approve a route with an unnamed , ambiguous rebrander, missing statement check, or unverified label.
Recommended next step

Assign the duties for each supply route

Map the manufacturer, importer, distributor, and representative to their pre-supply checks, stop-supply authority, notifications, and records.

Assessment workflow
Open Assessment Autopilot for UK PSTI Product Security

Create a role matrix for the legal entities in the product supply chain.

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Research workflow
Review UK PSTI Product Security source evidence

Use Research Copilot to answer follow-up questions with cited source material.

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Talk to Sorena
Talk through UK PSTI Product Security implementation

Review scope, evidence, owners, and the next compliance actions with Sorena.

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Primary sources

References and citations

PSTI Security Requirements Regulations 2023
legislation.gov.uk2 citations
Referenced sections
  • Security requirements, multiple-manufacturer rule, statements, label routes, and retention.
  • Security requirements, multiple-manufacturer rule, statement fields, and retention.

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