The difference between the old GPSD and the new GPSR that broke your listing
Before 13 December 2024, the EU ran consumer product safety under Directive 2001/95/EC, commonly called the GPSD. It was a directive — meaning each member state transposed it into national law with its own flavor, its own deadlines and its own documentation expectations. Many Chinese sellers and Amazon EU catalogs operated for years under GPSD without a single documentation request.
On 13 December 2024, Regulation (EU) 2023/988 — the GPSR — replaced the GPSD entirely. Three structural changes made it much tougher:
Regulation instead of directive
The GPSR is directly applicable in all 27 EU member states without transposition. One text, one set of obligations, zero national variation. The wiggle room from 27 different national implementations is gone.
Article 9 formalised the risk analysis
Under GPSD, risk assessment was a general duty without a prescribed format. Under GPSR Article 9, it is a specific document with a specific structure — severity × probability matrix, hazard identification, mitigation measures — that must be produced on request.
Article 16 created the EU Responsible Person requirement
Non-EU manufacturers must now appoint an EU-established economic operator as their regulatory contact. This is the requirement Amazon started enforcing on 1 April 2024, eight months before GPSR technically entered into force.
Your listing was probably blocked because your old GPSD-era documentation does not satisfy the new Article 9 structure, or because you have not yet appointed an EU Responsible Person, or both.
How the Amazon listing reinstatement sequence actually runs
Identify the specific flag
Go to Performance → Account Health → Regulatory Compliance. The flagged ASIN will show the exact reason code. Note whether the flag is about the Article 9 file, the Responsible Person, manufacturer identification, or the traceability label.
Produce the missing document
If the flag is about the technical file (most common), generate the Article 9 file with GPSRCheck. If the flag is about the Responsible Person, contract an EU Responsible Person service separately (€150–€300/year).
Upload through the correct interface
Regulatory Compliance tab → Submit compliance information button → upload the PDF. Do not email the document to Seller Support; they do not process compliance uploads via email.
Wait for automated review
Typical review turnaround is 24–72 hours. During this period the listing remains inactive.
Reinstatement or rejection
If accepted, the ASIN returns to active. If rejected, the rejection reason will indicate what is still missing — typically a format issue with the uploaded document. Correct and re-upload.
What’s in the 6-page PDF GPSRCheck generates
Cover page
Product identification, manufacturer data, unique file reference and generation date.
Product description
Materials, intended users, foreseeable misuse, and life cycle information.
Internal risk analysis under Article 9
Severity × probability matrix, hazard identification and mitigation measures across physical, mechanical, chemical, thermal, electrical, radiation and flammability categories.
EU Declaration of Conformity
In harmonised format, ready to sign, citing Regulation (EU) 2023/988 Article 9.
Printable product label — 2 copies
All mandatory GPSR data: manufacturer identification, traceability identifier, safety warnings. Ready to cut and affix. 10-year document retention statement included.
Generated from your own input, in your own browser. No data leaves your device.
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 what 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 — typically €150 to €300 per year. You can combine our technical file with any Responsible Person provider. The PDF you download is yours to keep and is not tied to any Responsible Person contract.
We decouple the two on purpose: you own the document, you pick the Responsible Person separately. 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.
Regulation (EU) 2023/988 replaced GPSD 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.
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.
Products flagged as non-compliant are listed publicly, by brand and model. Inclusion is permanent and searchable — 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 |
High-volume catalogues and special pricing
For high-volume catalogues and commercial enquiries, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
My listing was active for two years and suddenly got blocked. What changed?
Can I get the listing back by just appealing the block without submitting new documentation?
My product has CE marking. Why is the listing blocked under a different regulation?
The block references ‘Regulation 2023/988.’ Is that the same as GPSR?
I have four blocked listings across Amazon DE, FR, IT and ES for the same underlying product. Do I need four files?
How fast can I get my catalog back online if I start today?
⚠️ 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.