The European Commission’s position, in its own words
In December 2024, the European Commission published an official FAQ on the GPSR to address the most frequent questions from businesses, particularly small businesses. One question asked whether sole traders and micro-enterprises were exempt from the technical file obligation under Article 9. The Commission’s answer was unambiguous: the regulation does not contain size-based exemptions, and exceptions cannot be made on the basis of business size.
The reasoning stated in the FAQ is that a consumer’s right to a safe product cannot depend on who sold it — a faulty product purchased from a sole trader causes the same harm as a faulty product purchased from a corporation, and the regulatory framework must treat both identically to protect the consumer.
This is a deliberate policy position, not an oversight in drafting. The legislators who shaped the GPSR during its drafting process in 2021 and 2022 were aware that the regulation would capture sole traders. The choice was made explicitly in favour of consumer protection over compliance proportionality, on the reasoning that proportionality could be addressed through the cost of compliance tools (which is why one-time self-service tools like GPSRCheck have become viable in the post-regulation market) rather than through exemption from the obligation itself.
Three counterarguments that keep surfacing and why they fail
“The regulation is aimed at manufacturers, and I am just a trader.”
Article 3 of the GPSR defines “manufacturer” broadly. Any natural or legal person who markets a product under their own name or trademark is a manufacturer under the regulation, even if the physical production happens elsewhere. A sole trader selling handmade candles under their own brand is a manufacturer for GPSR purposes.
“EU law has thresholds for small businesses elsewhere, surely the GPSR has one too.”
Some EU regulations do contain SME-specific provisions (the GDPR has lighter record-keeping for organisations under 250 employees; the EU AI Act has carve-outs for research). The GPSR does not. When the European Commission drafted the GPSR, the choice was made to not include a size threshold, and that choice was confirmed in the December 2024 FAQ. Looking for a threshold that does not exist is not a compliance strategy.
“Enforcement against a one-person operation is not realistic.”
EU market surveillance authorities do receive consumer complaints about products from small sellers, and they do issue formal documentation requests to sole traders. Beyond authorities, Amazon, Etsy, eBay and other marketplaces enforce GPSR compliance on their own seller bases to protect themselves from Article 22 liability, and their enforcement is automated and does not care whether the seller is a sole trader or a corporation.
How GPSRCheck makes compliance proportionate for sole traders and the self-employed
€49 per product
The PDF you download is permanent. The license lets you regenerate the file up to 10 times within 30 days from first activation. No annual subscription that eats the margin of a small line.
Generator runs in the browser
10 minutes per product, downloadable PDF. No human interaction required unless something goes wrong. No sales call, no account manager.
100% runs in your browser
The sole trader’s product data — formulations, dimensions, sourcing notes — never touches our servers. Important for brands that are protective of their product-specific knowledge.
Standard PDF you own
Send to retailers, upload to marketplaces, store in Google Drive, hand to an authority through a Responsible Person. Does not evaporate if a subscription lapses.
10+ products? Special pricing
For high-volume product lines and commercial enquiries, visit solidwaretools.com or email hello@solidwaretools.com.
Free diagnostic included
If you are not sure whether your product category requires a GPSR file, the free diagnostic at the secondary CTA runs through the question in 2 minutes.
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 |
20 products in your line? One file at a time is not a plan.
Need GPSR technical files at volume? For high-volume product lines and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
I am registered as self-employed in Spain as an autónomo. Does the GPSR treat me the same as a UK sole trader or a French auto-entrepreneur?
My entire turnover is under €20,000 per year. Is there any threshold I can point to?
I sell products I design but do not physically make — a factory in Portugal produces them for me. Am I still the manufacturer?
Can I comply without contracting an EU Responsible Person?
My products are small, low-risk, clearly labelled, and have never had a safety complaint. Is the risk analysis really necessary?
What is the fastest path from zero to compliant for a sole trader with 12 products?
⚠️ 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.