Can I modify or rebrand imported products?
Record the proposed changes, check the applicable product rules and establish whether you take on manufacturer responsibilities. Before resale, match the evidence to the finished version, resolve gaps and approve its release. Cambridge China Bridge can help gather factory records and coordinate checks.
Write down the change before approving it
Create a change record comparing the original product with your proposed version. Include branding, materials, components, power supply, software, packaging, instructions and intended use. Attach drawings, photographs and the revised BOM. Ask the factory to identify every difference, including substitutions it regards as equivalent.
State where you will sell: England, Scotland and Wales, Northern Ireland, or elsewhere. This guide focuses on Great Britain. Use the destination and product category to frame the review. The OEM and ODM guide explains the sourcing models; this checklist addresses the decision before releasing a changed version.
Establish your role under the applicable rules
For products covered by the government's UKCA or CE guidance, confirm with the relevant authority whether selling under your own name or trade mark, or modifying a product in a way that affects compliance, means you assume manufacturer responsibilities. Check the specific product regime before applying that conclusion. Rebranding deserves a role review even when the physical product stays unchanged.
Ask a product compliance specialist to record the applicable rules, your resulting role and the reasons for that conclusion. Separate this from the factory's willingness to print your logo. Not every product needs a conformity marking. Our markings and certification guide covers the background.
Assess machinery changes separately
HSE says changes to machinery design, function or safety must be assessed for their extent. For new machinery modified before first use, a substantial change not foreseen or agreed by the manufacturer invalidates the original conformity assessment and marking; the modifier becomes the manufacturer.
HSE also explains that original marking remains valid where modifications were foreseen or agreed and covered by the manufacturer's risk assessment, technical documentation and declaration of conformity. Ask for those records covering your exact change. Treat a sales email saying the change is acceptable as a reason to request supporting documents.
Match the evidence to the finished version
Build a review pack containing the revised specification, risk assessment, component details, test reports, declaration where applicable, label artwork and instructions. Compare report photographs, model identifiers and tested components with the finished sample. Use our test report verification guide for checking the underlying report.
Ask the reviewer to explain which existing evidence remains relevant, which risks the change introduces and which further checks are needed. Request a written testing rationale rather than assuming either that all tests must be repeated or that the original reports cover everything. Record unresolved gaps and who will close them.
Release stock against an approved version
Before resale, have a named buyer representative approve the final sample and evidence pack. Check that production matches the reviewed configuration, labels and instructions. Keep the change record linked to batch records, inspection findings and customer shipments. Our inspection guide explains how to check the actual batch.
Agree that the factory must seek written approval before further substitutions. Reopen the review when the approved specification changes. Give Cambridge China Bridge the original evidence, proposed changes and intended sales destination so its staff in China can request factory records and coordinate checks; keep the buyer's release decision explicit.
Frequently asked questions
Does putting my logo on a product make me the manufacturer?
Confirm with the relevant authority whether marketing under your own name or trade mark means you assume manufacturer responsibilities. Check the specific product regime before approving the branding.
Do I need to repeat every test after a modification?
Ask a competent reviewer to map the changes against existing evidence and explain any further testing needed. The review should identify the finished configuration and give reasons for retaining earlier results.
Can I use the factory's original test report?
Have its scope checked against your revised product, including components, materials and intended use. Keep a written explanation of which results remain relevant and evidence addressing any gaps.
What documents should I get before reselling?
Gather the change record, final specification, risk review, relevant reports, declaration where applicable, labels, instructions and batch inspection evidence. Resolve gaps before the buyer approves release.