If you’re exporting products from the UK, there’s a good chance you’ll need a Certificate of Free Sale (CFS). But here’s what catches many exporters off guard – the application process, issuing authority, and requirements differ depending on your industry.
This guide breaks down how to obtain a Certificate of Free Sale in the UK for each major product category, which government body issues it, and when you’ll need your CFS Notarized or Apostilled for international use.
What Is a Certificate of Free Sale?
A Certificate of Free Sale is an official document confirming that your products comply with relevant UK regulations and are legally sold on the open market without restriction. It’s essentially a government-backed assurance to foreign regulators that your goods meet domestic standards.
Many countries require a CFS before allowing imported goods to enter their market – particularly when the importing country lacks its own regulatory framework for the product type in question.
A CFS is not part of the UK’s standard export procedures, but it may be needed to access specific overseas markets. It’s free to apply for in most categories, and the certificates typically do not expire unless the destination country specifies a time limit.
Which UK Authority Issues Your CFS?
This is where it gets industry-specific. There is no single issuing body in the UK – the authority depends on what you’re exporting.
- Medical devices and IVDs: Medicines and Healthcare Products Regulatory Agency (MHRA). CFS can only be ordered for devices registered through the MHRA’s Device Online Registration System (DORS). Only UK-based manufacturers, UK Responsible Persons, or Northern Ireland-based Authorised Representatives can apply. MHRA certificates are issued as PDFs with an electronic signature.
- Food, drinks and supplements: Rural Payments Agency (RPA). Applications are submitted through the RPA’s online service. Allow 10 working days for processing. It’s free to apply.
- Cosmetics: Department for Business and Trade (DBT). DBT issues CFS for cosmetic products. Note that following the UK’s accession to the CPTPP, some countries no longer require a CFS for cosmetics – check the latest DBT guidance.
- Pesticides and biocidal products: Health and Safety Executive (HSE). HSE or DBT can issue a CFS depending on the product’s regulatory status. For products intended solely for export (not sold in the UK), HSE may issue an export statement rather than a CFS.
- Veterinary medicines and animal products: Department for Environment, Food and Rural Affairs (Defra).
- Pharmaceuticals: Department of Health and Social Care.
- Other products: If your products don’t fall into the categories above, contact DBT at ilb.enquiries@businessandtrade.gov.uk with details of your products and applicable safety legislation. DBT will advise whether they can issue a CFS.
How to Apply for a Certificate of Free Sale
While the exact process varies by issuing authority, the general steps are:
- Check if you need a CFS. Verify with your importer or the destination country’s regulatory body whether a Certificate of Free Sale is required. Not all countries demand one, and some accept alternative documentation.
- Ensure your products are registered. For medical devices, this means registration through MHRA’s DORS. For food and drink products, you’ll need to provide details of the product and the destination country through the RPA’s online system.
- Apply through the relevant authority. Most applications are now submitted online. You’ll typically need to provide a contact name, email and phone number, the destination country, product names, and any additional information required by the importing country (such as a trader declaration or schedule of analysis).
- Receive your CFS. Processing times vary – RPA aims for 10 working days, while MHRA timelines depend on volume. Most CFS documents are now issued digitally as PDF files.
When Does a CFS Need to Be Notarized or Apostilled?
Here’s the critical step many exporters miss. A Certificate of Free Sale on its own is often not enough for the importing country’s regulatory authority. Depending on the destination, you may need:
- Notarization – a Notary Public verifies the authenticity of the CFS. For MHRA-issued certificates (which are digital PDFs), the FCDO will not Apostille the PDF directly. You first need a Notary to verify the certificate’s authenticity with MHRA and issue a notarial certificate.
- Apostille – for countries that are members of the Hague Apostille Convention, the Apostille authenticates the Notary’s signature and seal. In the UK, the FCDO Legalisation Office issues Apostilles.
- Embassy legalisation – for countries outside the Hague Convention (such as China and Vietnam), the CFS may require further legalisation at the relevant embassy or consulate after the Apostille step.
If you need your Certificate of Free Sale Notarized or Apostilled, NotaryPublic24 handles the entire process online – from Notarization through to Apostille – so you can focus on your export business.
Frequently Asked Questions
How much does a Certificate of Free Sale cost in the UK?
Most CFS applications in the UK are free. However, Notarization and Apostille services carry separate fees if the destination country requires them.
Does a Certificate of Free Sale expire?
Generally no – UK-issued CFS documents do not have an expiry date unless the importing country specifies a time limit. For MHRA medical device certificates, the validity is linked to the assessment document expiry date plus 365 days.
Can I get a CFS for products only intended for export?
If the product is not sold on the UK market, it may not qualify for a standard CFS. HSE, for example, issues an “export statement” rather than a CFS for biocidal products that are export-only. Contact the relevant authority for your product type.
Is a CFS the same as a Certificate of Manufacture?
No. A Certificate of Manufacture (CoM) applies specifically to products manufactured for export-only markets. For example, DBT issues CoMs for pesticides intended solely for export. If your product is on free sale in the UK, you need a CFS, not a CoM.
Do I need a separate CFS for each country?
This depends on the issuing authority and the importing country’s requirements. Some countries require their name to appear on the CFS, which means a separate certificate per destination. Others accept a generic CFS with no country identified.
Summary
Getting a Certificate of Free Sale in the UK depends entirely on what you’re exporting. Medical devices go through MHRA, food and drink through RPA, cosmetics through DBT, and so on. The application is usually free and digital, but the step most exporters underestimate is the legalisation chain: Notarization → Apostille → (embassy legalisation if needed).
If your CFS needs to be authenticated for international use, NotaryPublic24’s online Notarization and Apostille services can handle it from start to finish.