Selling your frames in Great Britain
We help Japanese frame makers sell to independent opticians and specialist eyewear retailers in Great Britain (England, Scotland and Wales). We can buy and import your frames, introduce them to practices, and act as your UK Responsible Person for MHRA registration.
Buying and import
We buy your frames and arrange collection from your workshop in Japan. Ownership passes to us at collection.
We coordinate export, shipping, customs, duty and import VAT. You invoice one British company, and we guide you through any information or documents required in Japan.
Sales representation
We introduce your frames to optical practices in Great Britain, arrange visits, and handle their orders through The Heritage Exchange.
We choose the range with you, agree prices and trade terms, arrange samples, and introduce your frames to practices that suit them. We manage orders and repeat orders, and answer practices’ questions about materials and construction.
Where it helps, we can ask the maker to agree exclusive models for a practice. Any exclusivity is agreed model by model, in writing.
UK Responsible Person
Spectacle frames are Class I medical devices in Great Britain. This requirement is often new to Japanese makers. A maker based outside the UK must appoint a UK Responsible Person before its frames can be placed on the Great Britain market. You can appoint only one, and the appointment covers all of your devices.
We can act as your UK Responsible Person. Once you appoint us in writing, we register you and your frames with the MHRA, keep your technical documentation and declaration of conformity available for inspection, and act as your contact with the regulator.
The rules have changed several times since 2021. Changes on 16 June 2025 added post-market surveillance requirements. Keeping track of them is part of our job.
What we take on as your UK Responsible Person
Before your frames go on sale
Check that your declaration of conformity and technical documentation have been drawn up, and that the right conformity assessment route was followed
Keep copies of your technical documentation, declaration of conformity and any certificates, with every amendment, available for inspection for as long as the law requires
Register you and each device with the MHRA before any frame is placed on the Great Britain market
Hold the written designation that makes the appointment valid
Tell you exactly how the UKCA mark and our name and address, as your UK Responsible Person, must appear on your packaging or instructions
Keep the registration accurate and file every change: new models, new addresses, new certificates
After they go on sale
Pass complaints and reports of suspected incidents from practices and wearers in Great Britain to you immediately
Check that the post-market surveillance plan and report your frames need are in place and up to date
Where you delegate it to us, report serious incidents and field safety corrective actions to the MHRA within the legal deadlines, and handle post-market surveillance correspondence with the MHRA
Answer MHRA requests for the information and documents needed to show your frames conform
Provide samples or access where we hold them; where we do not, pass the request to you and tell the MHRA what you intend to do
Cooperate with the MHRA on any preventive or corrective action
If a manufacturer acts contrary to its obligations under the medical device regulations, end our legal relationship with it and notify the MHRA and, where applicable, the relevant approved body
Your responsibilities as manufacturer
Appointing us does not transfer your responsibility for the conformity and safety of your frames.
The technical documentation is yours to prepare. We check it and keep it available to the MHRA, but we do not write it. We will tell you what it needs to contain and answer your questions; your existing technical and safety documents are often a starting point.
Design, materials and product safety remain your decisions.
How we start
Before we take on a range or an appointment, we review your frames, prices, minimum orders, lead times, payment terms and product documents. Then we agree the work, who does what, and our fees, in writing.
Send us your export plans and your catalogue.
Lucas Barker, Director
lucas.barker@theheritageexchange.uk
+44 7456 923455
Scope: frames for Great Britain. We take on products and UK Responsible Person appointments only after reviewing the maker’s and products’ documents and agreeing terms in writing.