The EU has been working on GPSR since 2020 and it was approved by the European Parliament in May 2023.

It updates existing rules to reflect the growth of online commerce and aims to give better protections for consumers.

That include the need to have a “responsible person”, which is effectively a compliance agent, inside the EU or Northern Ireland.

That is a particular challenge for small businesses in Great Britain who are selling direct to consumers, therefore they have no physical presence in the EU or Northern Ireland.

The Federation of Small Businesses (FSB) is calling on the government to give better export support to firms.

Tina McKenzie, policy chair at the FSB, said: “GPSR will be a real barrier to international trade for some of our small firms looking to export to EU member states, but also move goods to Northern Ireland.

“While the UK government’s newly published guidance is helpful, small firms are still faced with the complexity and associated costs around it.

“Governments from both sides should look at removing unnecessary trade barriers, not least those arising from the product safety rules, for small businesses in the UK-EU Trade and Cooperative Agreement review in 2026.”

It is understood the government expects GPSR to have a limited impact on the UK internal market as it largely formalises the reality of how many businesses are already operating.