What the Customs Union does and does not cover
The EU-Turkey Customs Union, established by Decision No 1/95 of the EU-Turkey Association Council, came into force on 31 December 1995 and created a free trade area for industrial products between the European Union and Turkey. Under the Customs Union, industrial products originating in Turkey circulate freely into the EU without customs duties and without quantitative restrictions. The document that travels with the goods is the ATR Movement Certificate, which confirms the free circulation status for customs purposes.
Removes the tariff barrier on industrial products
Turkish industrial products circulate into the EU free of customs duties, supported by the ATR Movement Certificate. This is the commercial advantage of the Customs Union and it is real and significant.
It does not harmonise all product regulation, it does not grant Turkish products automatic compliance status with future EU regulations, and it does not exempt Turkish manufacturers from complying with the regulatory obligations imposed on non-EU manufacturers under EU product safety law. The Customs Union removes the tariff barrier. It does not remove the regulatory barrier.
The Republic of Türkiye Ministry of Trade’s official guidance on technical regulations is explicit: Türkiye has transposed the horizontal legislation of the EU on CE marking, notified bodies, market surveillance, general product safety and mutual recognition. This confirms that Turkey itself recognises the alignment obligation under the Customs Union. For Turkish exporters the practical consequence is that the same rules apply on both sides of the Kapıkule border. There is no regulatory arbitrage available through the Customs Union.
The medical devices confusion — where the exemption is real, and why it does not extend to GPSR
A specific source of confusion for Turkish exporters researching this question online is the existence of a separate EU-Turkey agreement in the field of medical devices. Under Regulation (EU) 2017/745 (the Medical Device Regulation) and Regulation (EU) 2017/746 (the In Vitro Diagnostic Medical Device Regulation), there is a specific mutual recognition arrangement between the EU and Turkey that exempts Turkish manufacturers of medical devices from the obligation to designate an EU Authorised Representative for their medical device exports to the EU.
This specific exemption applies only to medical devices under the MDR and IVDR, and only to the EU Authorised Representative obligation under those specific regulations. It does not extend to any other regulatory framework, and critically it does not cover the General Product Safety Regulation at all. A Turkish manufacturer of medical devices does not need an EU Authorised Representative for their medical device product line under MDR. The same manufacturer, if they also produce non-medical consumer products, needs the full Article 9 file and the Article 16 EU Responsible Person designation for those non-medical products under Regulation (EU) 2023/988.
A second source of confusion is that some online content about EU Authorised Representative services for Turkish manufacturers pre-dates the GPSR and reflects the situation under the old General Product Safety Directive 2001/95/EC. Under the old directive, certain commercial structures did not trigger the EU Authorised Representative obligation, and some compliance service providers published articles in 2021, 2022 and early 2023 stating that Turkish manufacturers did not need to designate an EU Authorised Representative. Those articles continue to appear in search results, but they are outdated with respect to Regulation (EU) 2023/988 which entered into force on 13 December 2024. Any online source pre-dating 13 December 2024 should not be relied upon for current GPSR compliance decisions.
What this means in practice for a Turkish B2B exporter
Having established that the GPSR does apply to Turkish exporters, the next question is what to do about it. The practical answer turns on one structural question: is your European buyer the importer of record?
For most Turkish exporters serving European B2B buyers under long-term supply agreements — the dominant commercial model in textile, furniture, leather and handicraft trade between Turkey and Europe — the European buyer is the importer of record. The goods are sold on CIF or FOB terms, the commercial invoice is addressed to the buyer, the ATR certificate accompanies the shipment, the buyer’s freight forwarder clears the goods at the EU entry point, and the buyer takes title and distributes to their own retail network. In this structure, the European buyer is the economic operator who places the product on the EU market for the first time, and under Articles 13 and 16 of Regulation (EU) 2023/988 this makes the buyer the importer and therefore, functionally, the EU Responsible Person. A Turkish exporter in this structure does not need to contract a separate EU Responsible Person service from a third party.
What the Turkish exporter does need, irrevocably and without substitute, is the Article 9 internal technical file for each SKU. The buyer, as importer, has parallel obligations under Article 13 (verifying that the manufacturer has produced the file, holding a copy, making it available to authorities on request), but the buyer cannot produce the file on the manufacturer’s behalf because the file depends on information that lives at the Turkish manufacturing unit. That file is what GPSRCheck generates in ten minutes per SKU at €49 one-time.
For Turkish exporters who instead sell B2C directly to European consumers — own Shopify store, Amazon EU Seller Central, Etsy direct export — a separate EU Responsible Person designation is required under Article 16. Dedicated providers (EaseCert, Euverify, Lovat Compliance, EU Compliance Partner, gpsrcompliant.eu) at annual fees typically in the €150–500 range serve this segment. The Article 9 file remains the manufacturer’s own obligation regardless, and GPSRCheck generates it for the self-service route at €49 per SKU.
What the 6-page PDF actually contains, for a Turkish or Egyptian exporter serving European buyers
Product identification and economic operator data
The model number or SKU identifier your buyer uses in the PO, the brand name under which the product is placed on the EU market, your manufacturing unit as manufacturer of record with full postal address in Turkey or Egypt, and the slot for the EU Responsible Person contact — which may be the European buyer acting as importer of record, or a dedicated EU Responsible Person provider.
Product description and intended use
Full composition inventory (wood species for furniture, fibre blend for textiles, leather type and tanning method, fittings, hardware, fabrics, finishes, adhesives), intended use and target consumer, declared age range where relevant, conditions of use and care instructions.
Internal risk analysis under Article 9
Hazard identification across the categories relevant to your vertical. For furniture: structural stability, tipping risk, sharp edges, pinch points, chemical emissions from panels and finishes, entrapment risks, joint strength. For textiles: chemical composition under REACH (azo dyes, nickel release, phthalates, flame retardants), mechanical hazards, flammability, colourfastness. For leather goods: chromium VI, azo dyes, heavy metals, sharp trims, attachment point strength. Severity-by-likelihood scoring, mitigation measures, residual risk statement.
EU Declaration of Conformity
Referencing Regulation (EU) 2023/988 Article 9 and ready for electronic signature by the manufacturer or authorised signatory. The document the European buyer’s legal counsel needs to close the compliance file and issue the PO.
Printable product label — two copies per A4 sheet
Manufacturer name and postal address, EU Responsible Person contact, product identifier, warnings where applicable, traceability batch code. Ready to be printed at your facility, attached to the product, sewn into a care label for textiles, or affixed to the master carton for furniture.
The document your European buyer is asking about
When a European buyer’s legal department or quality and compliance team sends you a formal email asking for “GPSR documentation per Regulation (EU) 2023/988” they are asking for a structured internal risk analysis under Article 9, the EU Declaration of Conformity that references it, and confirmation of an EU Responsible Person designation under Article 16. The internal risk analysis is the substance of the file — not a test report from an accredited laboratory, not an OEKO-TEX certificate, not a BSCI audit, not an ISO 9001 statement, not an ATR certificate, not a certificate of origin from your chamber of commerce. These adjacent documents are already in your buyer’s tech pack and they do not replace the Article 9 file under the Regulation.
Under Article 2 of Regulation (EU) 2023/988, for products covered by Union harmonisation legislation (Low Voltage Directive 2014/35/EU, EMC 2014/30/EU, RED 2014/53/EU, Toy Safety Directive 2009/48/EC, Cosmetics Regulation (EC) 1223/2009, Medical Device Regulation 2017/745, Machinery Regulation 2023/1230 and similar) the GPSR Chapter II does not apply to the risks covered by that harmonisation legislation. For non-harmonised consumer products — furniture without electrical components, textiles without PPE function, leather goods, fashion accessories, home decoration, ceramics, non-electric homeware, stationery — the Article 9 file is the primary compliance document.
GPSRCheck generates that file. What it does not generate — and what no compliance tool generates legitimately — is a “GPSR certification”, because the Regulation does not establish a certification scheme. Any vendor selling you a “GPSR certificate” is using marketing terminology that does not match the text of the Regulation. What exists under the Regulation is the technical file, the EU Declaration of Conformity, and the Responsible Person designation. That is the package your European buyer is asking for.
The two compliance layers and why most Turkish and Egyptian B2B exporters do not need a separate Responsible Person contract
Regulation (EU) 2023/988 imposes two distinct documentary obligations on a non-EU manufacturer placing consumer products on the EU market.
The technical file
The risk analysis, the EU Declaration of Conformity and the printable label — the manufacturer’s own responsibility to produce and keep for ten years (Article 9(4)). For a Turkish or Egyptian B2B exporter, this is the €49 GPSRCheck file. GPSRCheck produces it in ten minutes per SKU. One license per SKU, no subscription: the PDF is permanent, and the license lets you regenerate the file up to 10 times within 30 days from first activation to correct details.
The EU Responsible Person
For Turkish and Egyptian exporters selling B2B to a European buyer who is the importer of record, the buyer is already the Responsible Person by operation of law under Articles 13 and 16 — no separate contract needed. For direct B2C export (Amazon EU, Shopify, Etsy), a separate EU AR is required: EaseCert, Euverify, Lovat Compliance, EU Compliance Partner or gpsrcompliant.eu at €150–500 per year.
GPSRCheck deliberately does not bundle the Responsible Person service into its €49 fee, because many Turkish and Egyptian exporters in B2B structures do not need a separate Responsible Person at all. Unbundling keeps the price at €49, keeps the tool focused on the document only the manufacturer can produce, and lets you choose the Responsible Person arrangement that fits the commercial structure of each buyer relationship.
Enforcement reality for Turkish and Egyptian exporters shipping consumer products to Europe
Amazon started suspending EU listings of non-EU sellers without a designated EU Responsible Person eight months before the GPSR’s official entry into force. Non-Amazon channels followed through 2025: European B2B buyers updated their PO templates to require the Article 9 technical file as a condition of PO issuance.
The regulation entered into force across all 27 EU Member States and the EEA. EU customs at Kapıkule at the Trakya border, Piraeus, Thessaloniki, Rotterdam and Hamburg intensified documentary inspection on non-EU consignments of consumer products from Turkey and Egypt.
Market surveillance authorities have the power to require the technical file within a short deadline of typically ten working days. Failure to produce the file can result in withdrawal from the market and inclusion in the Safety Gate public database.
The European Commission’s official FAQ on the GPSR, published in December 2024, is explicit that exceptions cannot be made on the basis of business size. A Turkish furniture manufacturer with a hundred-worker unit in İnegöl carries the same documentary obligations as a multinational manufacturer with EU subsidiaries.
For Turkish and Egyptian exporters with B2B buyer relationships, the most common enforcement pathway is commercial: the European buyer’s legal department updates the supplier qualification process and adds the Article 9 file to the list of documents required for continued supplier status. Suppliers who produce the file continue receiving POs. Suppliers who cannot get suspended from the vendor list and replaced. For a Turkish furniture exporter whose largest client represents 20–30% of annual turnover, a suspended vendor status is an existential event. The €49 file restores the relationship.
Consultancy, subscription platforms, bundled enterprise services and GPSRCheck
| Traditional consultancy (local) | Annual subscription platforms | Bundled enterprise (EaseCert) | GPSRCheck | |
|---|---|---|---|---|
| Indicative price | €250–800 per product | €199–500 per year | €400 standard / €500 furniture, one-time | €49 per SKU, one-time |
| EU Responsible Person | No | Yes, bundled | Yes, bundled | No — contract separately if needed |
| Time to deliver | 3–8 weeks | 24–48 h after onboarding | 3–5 business days | 10 minutes |
| Data handling | Sent to consultant | Cloud storage on vendor servers | Cloud storage on vendor servers | 100% browser-side |
| Per-SKU cost at 30 SKUs | €7,500–€24,000 | €199–500 + tier surcharges | €12,000–€15,000 | €1,470 (30 × €49) |
Competitor prices verified from their public pricing pages as of April 2026. For high-volume catalogues and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.
High-volume seasonal catalogues and special pricing
For seasonal catalogues and commercial enquiries, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
If Turkey has transposed EU product safety legislation into national law, why does the GPSR apply separately — shouldn’t our Turkish domestic compliance be enough?
Our ATR certificate has always been accepted at EU customs. Is the GPSR going to affect the ATR or replace it?
Is there any talk of a specific EU-Turkey mutual recognition agreement for GPSR like the one for medical devices?
I found a 2022 article from an EU AR service provider saying Turkish manufacturers do not need an EU Authorised Representative. Was that article wrong?
We ship to both the EU and to Turkey’s own domestic market. Does the Article 9 file cover both, or do we need separate files?
How do we know for certain that the Turkish Ministry of Trade position I read about is still current?
⚠️ Important notice: GPSRCheck generates the Article 9 technical file for non-harmonised consumer products only. Products under Union harmonisation legislation (Toy Safety Directive for children under 14, Low Voltage/EMC/RED for electrical equipment, MDR for medical devices, Machinery Regulation, PPE Regulation) require different documentation. GPSRCheck does not provide the EU Responsible Person service under Article 16.