Why private label ASINs get hit first
Under Article 3 of Regulation (EU) 2023/988, the GPSR considers a private label brand owner to be the manufacturer of the product whenever they place it on the EU market under their own name or trademark. This is true even if the physical manufacturing happens in Yiwu, Shenzhen, Dongguan, Ho Chi Minh City or Guadalajara. The logic is legal, not logistical: the brand on the box is the entity that owes the documentation.
The technical file cannot be outsourced to the factory — the factory is not the manufacturer under the GPSR, the founder is. The factory’s internal QC reports do not substitute for the Article 9 internal risk analysis. Even when the agent in China offers to “prepare the file for $180”, what they typically deliver is a repackaged set of test reports from a Chinese lab, which is not what Amazon Seller Central asks for and not what an EU market surveillance authority would accept.
What Amazon Seller Central actually wants in the GPSR compliance field
The Seller Central compliance interface for GPSR has three upload slots: manufacturer information (name, address, email), EU Responsible Person contact details, and the product documentation itself. Amazon does not publish a strict format requirement, but the documentation has to satisfy Article 9 of the GPSR: a documented internal risk analysis, a product description with intended use and foreseeable misuse, a list of applicable EU standards, and an EU Declaration of Conformity signed by the manufacturer or authorised representative.
GPSRCheck generates all four components in a single 6-page PDF structured in the exact order that a market surveillance authority expects. You upload the PDF to the compliance field in Seller Central and the listing reactivation queue typically processes the restoration within 24 to 72 hours.
What’s in the 6-page PDF
Product identification and traceability
Manufacturer name and address, EU Responsible Person placeholder, SKU, batch reference, product category.
Product description, intended use and foreseeable misuse scenarios
How the product is designed to be used, and what a reasonable user might do with it outside that scope.
Article 9 internal risk analysis
Hazard identification, likelihood and severity assessment, mitigation measures, residual risk statement.
EU Declaration of Conformity
Signed template referencing Regulation (EU) 2023/988 and any additional applicable directives (LVD, EMC, RoHS, toy safety, etc. as applicable).
Printable product label
Traceability block and EU Responsible Person placeholder, ready to print at 45×25 mm or scale up.
Every page is generated locally in your browser. Nothing is uploaded to our servers. The file is yours the moment you close the tab.
The technical file and the EU Responsible Person: two separate things
The GPSR has two distinct compliance layers for non-EU sellers, and vendors in this market often bundle them into one expensive annual contract. They don’t have to be bundled.
The technical file
The documented internal risk analysis, the EU Declaration of Conformity, the product label with traceability data. This is the document Amazon Seller Central asks you to upload. GPSRCheck generates it in 10 minutes for €49 per SKU. One license per SKU. The PDF you download is yours permanently and does not expire. The license lets you regenerate the file up to 10 times within 30 days from first activation to correct details.
The EU Responsible Person
Every non-EU manufacturer must appoint an EU-established economic operator as regulatory contact — a service, not a document. Typical pricing €150 to €300 per year. You can pick any provider and combine it with your GPSRCheck files. The PDF you download is yours to keep and is not tied to any Responsible Person contract.
The industry standard is to bundle both layers into a single annual subscription of €199 to €2,000, which means you cannot leave the vendor without losing access to your own documentation. We decouple the two on purpose: you own the document, you pick the Responsible Person separately, and if you ever change provider, your files travel with you.
Enforcement reality — the timeline that built this market
Amazon started suspending EU listings without a valid EU Responsible Person — eight months before the GPSR’s official entry into force. Amazon moved ahead of the regulator.
Regulation (EU) 2023/988 entered into force across all 27 EU member states plus Northern Ireland. Every non-food consumer product placed on the EU market must have a documented Article 9 internal risk analysis and an EU Responsible Person under Article 16.
When a market surveillance authority in any EU member state issues a reasoned request for the technical file, the economic operator has ten days to provide it. Missing this window is treated as a presumption of non-compliance and triggers listing removal, cargo detention or sales ban.
Member states are implementing national penalty regimes. Germany additionally imposes criminal penalties of up to one year of imprisonment. France allows proportional fines up to 10% of annual turnover. Italy, Spain, Netherlands and Poland have enacted comparable ranges.
Products flagged as non-compliant are listed publicly, by brand and model. Inclusion is permanent and searchable — the reputational damage outlasts any fine.
Customs may detain shipments without valid GPSR documentation, accruing daily storage costs until documentation is produced or the shipment is returned.
Why GPSRCheck rather than a consultancy or an annual subscription?
| Consultancy | Annual subscription platform | GPSRCheck | |
|---|---|---|---|
| Price | €400–2,000 per product | €199–600 per year | €49 per product |
| Time to delivery | 3–15 business days | 48h onboarding + setup | 10 minutes |
| Billing model | Quote-based invoice | Annual recurring | One payment per SKU · Permanent PDF · 30-day edit window |
| EU Responsible Person | Included in package | Included in package | Separate (pick any provider) |
| Legal basis | Art. 9 Reg. (EU) 2023/988 | Art. 9 Reg. (EU) 2023/988 | Art. 9 Reg. (EU) 2023/988 |
| Data handling | Sent to consultancy | Stored on vendor servers | 100% in your browser |
| Portability | File belongs to consultancy | File tied to subscription | File is yours, travel-ready |
40 SKUs in your Amazon EU catalog? One file at a time is not a plan.
Need GPSR technical files at volume? For high-volume catalogues and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
My agent in China offered to prepare the GPSR file for $180 per SKU. Is that the same thing?
Does my existing CE marking on the product cover the GPSR requirement?
How does the PDF from GPSRCheck map to the Seller Central compliance fields?
My brand has 60 ASINs suspended simultaneously. Do I really need 60 separate files?
Does GPSRCheck include the EU Responsible Person service?
If my ASIN is already suspended, how fast can I get the listing back online?
⚠️ Important notice: GPSRCheck is a self-assessment documentation tool, not legal advice and not a product testing service. The Article 9 technical file is generated from your input data. GPSRCheck does not provide the EU Responsible Person service.