What “documentation required” means in the Amazon email
Amazon’s GPSR compliance workflow has three layers. The first is the manufacturer information field: name, address, email. The second is the EU Responsible Person field. The third is the product documentation upload — this is the one most FBA sellers miss. Amazon does not auto-generate this for you, does not provide a template, and does not accept the factory’s internal QC report as a substitute. What they expect is a GPSR-compliant technical file: Article 9 risk analysis, product description, EU Declaration of Conformity and traceability data, all in a single document per SKU.
When the dashboard shows “documentation required”, it is the third layer that is empty. The first two are text fields you fill in Seller Central. The third is an upload slot that needs an actual file.
Private label, resale, or bundle: the documentation obligation is not the same
You are the manufacturer — full Article 9 obligation
Article 3 of the GPSR makes you the manufacturer when you market a product under your own name or trademark. The full Article 9 technical file sits with you. GPSRCheck generates it.
You are a distributor — verification duty, not creation duty
The documentation obligation belongs to the original brand owner. Your job is to verify that the brand owner has provided a valid file. If the brand owner cannot produce one, you cannot legally place the product on the EU market.
You are the manufacturer of the combined product
The GPSR considers bundling into a new marketed unit to create new risk scenarios requiring fresh assessment. A full technical file is owed for the bundle.
Same treatment as private label — new file required
The rebranding makes you the manufacturer under the GPSR. A new technical file is required in your brand name.
The cost of delay when Amazon is the one asking
Amazon’s compliance queue does not wait for your consultant’s availability. The initial email comes with a deadline — typically 14 to 30 days. If the deadline passes without documentation uploaded, Seller Central moves the ASIN to “suspended pending compliance” status. The listing is invisible to buyers, inventory accrues storage fees, and your organic ranking decays every day the listing stays dark. Ranking recovery after reinstatement typically takes two to six weeks to return to pre-suspension levels, if it recovers at all.
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
Amazon sent me the email but my listings are still active. Do I have time?
Can I upload the same PDF for multiple ASINs that are variants of the same base product?
My products are CE-marked. Do I still need a GPSR file?
Does GPSRCheck generate the file for Amazon, or for market surveillance authorities, or both?
Where does the data I enter in the generator go?
What if Amazon rejects the file after I upload it?
⚠️ 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.