A UK seller can lawfully import genuine Makita from a German distributor and sell it on Amazon UK without asking Makita. The same seller, buying the same tool from a US liquidator, is infringing Makita's trade mark.
Nothing about the product changes. Same box, same serial number, genuine in both cases. What changes is where it was first sold, and that one fact decides whether the brand owner can stop you.
That rule is the least understood and most expensive thing in UK wholesale, and it is where we'll start. The rest of this covers what else changes when stock crosses into Great Britain: marking, plugs, origin, batteries, and who you become in the eyes of the law the moment you import.
Where the goods were first sold decides whether you can sell them
Section 12(1) of the Trade Marks Act 1994 says a registered trade mark is not infringed by use in relation to goods "put on the market in the United Kingdom or the European Economic Area under that trade mark by the proprietor or with his consent." The rights are exhausted. You can resell without permission.
The consequence is a three-line table that decides a lot of purchasing decisions.
- First sold in the UK — rights exhausted, resell freely.
- First sold in the EEA — rights exhausted, resell freely.
- First sold anywhere else — not exhausted, and the brand owner can block the sale.
That third line is the one that catches people. Goods first marketed in the US, the UAE, Turkey or Asia do not exhaust UK rights, so the brand owner can prevent their resale in the UK even though the goods are entirely genuine. Sourcing real Milwaukee from a US liquidator and selling it into the UK is trade mark infringement unless the brand consents. Grey-market US stock is the classic way to lose a shipment and an account at the same time.
Two details worth holding on to. The EEA is the EU plus Iceland, Liechtenstein and Norway — Switzerland is in neither, so Victorinox goods first placed on the Swiss market do not exhaust UK rights. And the regime is asymmetric: goods first sold in the UK are not exhausted in the EEA, so selling UK stock into Europe may need the brand owner's permission, and the brand owner may simply say no.
If you read anywhere that this is still an open question, that source is out of date. The government consulted on changing the regime between June and August 2021, went quiet, and finally answered on 15 May 2025: no change, the UK keeps what it calls the UK+ regime. Its stated reason was that most respondents said the current system works and nobody produced robust quantitative evidence for an alternative.
One residual catch even where rights are exhausted. Section 12(2) preserves the brand owner's objection where there are legitimate reasons to oppose further dealings, "in particular, where the condition of the goods has been changed or impaired after they have been put on the market." Repackaging, relabelling, breaking up multipacks and removing batch codes all put you back inside that exception.
The UKCA deadline everyone worried about is not coming
This one is good news and it is still being written about wrongly.
CE marking is accepted in Great Britain indefinitely, with no end date. It was announced in August 2023 and then actually legislated: the Product Safety and Metrology etc. (Amendment) Regulations 2024 came into force on 1 October 2024 and amended more than twenty assimilated product-safety instruments. UKCA remains valid and available, but for a tools and hardware range it is optional.
The gov.uk sector list, last updated on 22 September 2026, runs to twenty-two sectors with indefinite CE recognition — it was eighteen when announced, with ecodesign and aerosol dispensers added later. Among them: electrical equipment, machinery, personal protective equipment, radio equipment, RoHS, and toys. There is nothing in a normal tools range that still requires UKCA.
Two boundaries. This is Great Britain — England, Scotland and Wales. Northern Ireland follows EU rules and is a separate exercise. And general product safety is a different animal from marking: the General Product Safety Regulations 2005 still apply in Great Britain and treat a UK-based importer as a producer.
The plug is the compliance failure, not the voltage
UK declared supply voltage is 230V, with a tolerance of 10% above and 6% below — so 216.2V to 253V, at 50Hz. EU supply is nominally the same. An EU-spec corded tool will run perfectly well on UK mains.
What it usually will not have is a BS 1363 plug with a BS 1362 fuse, which the Plugs and Sockets etc. (Safety) Regulations 1994 require on domestic appliances. And a conversion plug fitted over a foreign plug needs notified body approval in its own right — a two-pound travel adaptor dropped in the box is not a compliant fix.
We'll be straight about the edge here rather than pretending it's settled: those regulations are framed around domestic use, and whether a trade-grade power tool counts as "designed for domestic use" is genuinely arguable. In practice, a consumer marketplace listing gets treated as domestic supply, and we would not want to be the one running that argument after a complaint.
Separately and less dramatically, the Electrical Equipment (Safety) Regulations 2016 require instructions to be "clear, legible and in easily understandable English." Stock built for the European market often ships with a multi-language booklet where English is missing or machine-translated. That is a breach on its own, and it is the single easiest thing to check before you buy.
You are the importer, and there is a line where you become the manufacturer
If you are a UK business placing goods from outside the UK on the GB market, you are the importer. Buying from a German or Dutch distributor does not make them the importer; it makes them your supplier.
That brings three duties that are near-identical across every sector regulation: put your name or registered trade mark and a postal address on the product; keep the declaration of conformity and the technical documentation for ten years; and investigate complaints of non-conformity. There is an easement running until 31 December 2027 that lets importers of goods from the EEA or Switzerland put contact details on the packaging or accompanying documents instead of on the product itself.
Then there is the line. You are treated as the manufacturer, with all of a manufacturer's obligations, where you place goods on the market under your own name or trade mark, or where you modify goods already on the market in a way that may affect their conformity.
Private-label kitting is how people cross it without noticing. Take four brand-name tools, box them as your own set, and you have taken on the technical file, the conformity assessment and the declaration of conformity for products you did not make. The same act also revives the trade mark objection under section 12(2). One decision, two liabilities, and neither of them shows up until something goes wrong.
Where the invoice came from is not where the goods came from
The EU–UK Trade and Cooperation Agreement is zero-tariff only for goods that meet its rules of origin. Goods that fail the origin test pay the full MFN rate, exactly as if no agreement existed.
Non-originating means manufactured outside the UK and EU. Sitting in a Rotterdam warehouse confers nothing. Neither does affixing labels, simple painting and polishing, or simple assembly needing "neither special skills nor machines, apparatus or equipment especially produced or installed" — the agreement calls that insufficient production, and repacking or kitting in the EU does not create EU origin.
So the practical read on a mixed brand list: Knipex, Opinel, LEKI and Petzl are plausibly EU-originating. Milwaukee, Makita and Stanley are substantially manufactured outside the EU and will typically be non-originating however European the invoice looks. Victorinox is Swiss, which is a separate agreement rather than the TCA. Thule manufactures in several countries and needs checking per SKU.
There are two ways to claim preference: a statement on origin from the exporter, which can cover a single shipment or multiple identical shipments over up to twelve months, or importer's knowledge, where you hold the evidence yourself. Keep those records four years — a different clock from the ten-year product-safety one, and worth not conflating.
On the duty itself: MFN rates on most hand and power tools are low, often between nothing and a couple of percent. But they are set per commodity code, and we are not going to publish a number that might be wrong for your SKU. Check yours on the UK Integrated Online Tariff.
Batteries, if you plan to fly them
Lithium cells and batteries have to meet the testing standard in the UN Manual of Tests and Criteria, sub-section 38.3, and be packed, marked, labelled and documented to the ICAO Technical Instructions. The UK applies those rules rather than running its own.
The change worth knowing, because anything written before this year gets it wrong: from 1 January 2026 the 30% state-of-charge cap extends to batteries packed with the equipment they power. It previously applied only to batteries shipped on their own.
Bare battery packs are cargo aircraft only — the CAA's wording is that transporting lithium batteries on their own is forbidden in the hold of a passenger aircraft. Batteries packed with equipment can travel on passenger aircraft, limited to five kilograms of batteries per package. Make UN38.3 test summaries a condition of purchase rather than something you chase after the freight is booked.
PPE, if the range runs that way
Assimilated Regulation 2016/425 governs, and CE marking is recognised indefinitely here too. Category III covers risks that may cause very serious consequences such as death or irreversible damage to health, and item (g) on that list is falling from a height — with no height threshold at all. Harnesses, lanyards, connectors, work-at-height helmets and chainsaw cut-protection trousers are Category III at any height.
If you see a source claiming the threshold is falls above six metres, it is wrong. That number does not appear in the regulation.
Category III also means ongoing surveillance rather than a certificate in a drawer: type-examination plus either supervised product checks at random intervals or production quality assurance. A harness with a 2019 certificate and no evidence of continuing surveillance is worth a direct question.
A distributor's own duties are narrower but real: verify the marking, verify the required instructions and information are present in English, and don't break the storage and transport chain. PPE instructions carry inspection intervals and service life, so supplying without them is its own breach rather than an administrative slip.
What we won't tell you about Amazon UK
Amazon publishes an invoice standard, and it is worth meeting whether or not you ever submit one: issued within the last 365 days, quantities consistent with sales volumes, product identifiers, supplier contact details, an authentic PDF or image rather than an editable file, and a completed transaction rather than a quote or pro forma. Pricing may be redacted; the rest may not.
Beyond that, be careful what you read. The widely repeated "minimum ten units" rule does not appear in Amazon's own guidance, which says only that quantities must match sales volumes. And we found no authoritative statement that Amazon UK's invoice standard differs from Amazon US — the same policy serves both marketplaces. The genuine UK-specific differences are in VAT and in which brands happen to be gated, not in what an invoice has to look like.
On gating: which brands are restricted changes constantly and is account-specific. Anyone publishing a list is guessing, and a list is exactly the kind of thing that makes a supplier look knowledgeable and turns out to be worthless.
One thing we did not research, and you should
Knives. Selling Opinel or Victorinox into the UK engages a separate regime — age verification on remote sales, restrictions on delivery, and prohibitions on certain blade types — and Amazon and eBay enforce their own rules on top of the law. We have not done that work and are not going to improvise it here. If knives are in your plan, get advice specific to them.
How we handle this
We issue accurate commercial paperwork for goods we actually sold you, in the shape a marketplace expects, and we will tell you what we know about a SKU's origin and its marking before you buy rather than after. Where we don't know, we say so, which is why several sections above end in "check this yourself" instead of a confident answer.
What we will not do is suggest that a document decides a marketplace's mind, or let anyone infer that because a tool is genuine it is therefore sellable in their market. Genuine and compliant are two separate tests, and the importer's obligations are yours whoever you buy from. The least a supplier can do is not leave you guessing about what you are importing.