What the EU Authorised Representative does, and what they structurally cannot do for you
The EU Authorised Representative under Article 16 of Regulation (EU) 2023/988 is a natural or legal person established in the European Union who the manufacturer designates in writing as the contact point for market surveillance authorities. Their core obligations include maintaining the EU Declaration of Conformity available for the duration required by the Regulation, making the technical file available to authorities on request, cooperating with authorities on corrective actions, informing the manufacturer when safety issues are identified, and in some cases intervening in product withdrawals or recalls.
The key phrase in that list is “making the technical file available” — the AR’s role is to hold the file and hand it over when asked, not to produce it. The file has to exist before the AR can do their job. A Responsible Person without a file is a contact box with nothing to hand over, and that is a failure mode both the Responsible Person service and the manufacturer want to avoid. This is structurally important for the price architecture of the compliance package: most EU AR providers price their service on an annual basis (€150–500 per year typical) and the service scope is defined around what the AR can legally deliver: registration, holding documents, fielding authority correspondence, coordinating recalls. What the AR cannot deliver is the underlying risk analysis of your product, because the evidence and the process knowledge that feed the risk analysis live at your manufacturing unit in India. GPSRCheck fills exactly that gap at €49 per SKU one-time.
Choosing an EU Authorised Representative for an Indian manufacturer — what to look for, what each tier offers
ecinternational.co.in, Veteran Group India and similar
Operate with an EU legal partner and serve as the entry-level AR service for Indian manufacturers. Accessible in Indian Standard Time and in local languages. Historically many specialised in medical devices (MDR/IVDR) and are extending to GPSR. Price points and bundling vary; request a quote.
Advena, I3CGlobal, CMS MedTech and similar
Operate from the EU with specialist expertise in specific regulatory frameworks. Typically price range €300–800 per year depending on complexity. Historically medical device-focused, extending to GPSR.
EaseCert, Euverify, Lovat Compliance, EU Compliance Partner, gpsrcompliant.eu
Target primarily non-EU e-commerce sellers on Amazon, Shopify and Etsy but also serve B2B exporters looking for a standalone AR service. Price range €150–800 per year for standalone AR or €400–500 one-time for GPSR+AR bundles. The structural fit for most Indian textile, leather and handicraft exporters who need a separate AR at all.
UL Solutions, TÜV, Bureau Veritas, SGS, Intertek
The correct choice for Indian manufacturers with very large portfolios, complex products under multiple harmonisation frameworks, or specific testing needs that the consultancy can bundle. Price points are enterprise level (€2,000–10,000+ per engagement).
The combined compliance stack: GPSRCheck + an external EU AR, total cost for a 20-SKU catalogue
| Scenario | GPSRCheck files | EU AR cost | Year 1 total | Year 2+ |
|---|---|---|---|---|
| B2B to importer-of-record buyer (no separate AR needed) | 20 × €49 = €980 | €0 (buyer is AR) | €980 | €0 |
| B2C direct (own Shopify, Amazon EU, Etsy) — separate AR required | 20 × €49 = €980 | €150–500/year | €1,130–1,480 | €150–500/year |
| Bundled provider (EaseCert, €400/product, AR included) | 20 × €400 = €8,000 | €8,000 | €0 | |
The difference (€8,000 vs €1,130–1,480) reflects the unbundling choice: GPSRCheck charges for the file only, the external AR charges for the AR only, and together they cost a fraction of a provider that bundles both into a single per-product fee. The quality of the underlying Article 9 file is the same — it is the same regulation, the same risk analysis structure, the same documentary output. What differs is structural pricing, not substance.
What the 6-page PDF actually contains, for an Indian exporter serving European buyers
Product identification and economic operator data
The style number, SKU identifier or tech pack reference 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, and the slot for the EU Responsible Person contact — which may be the European importer acting as importer of record, or a dedicated EU Responsible Person provider.
Product description and intended use
Full composition inventory (fibre blend or leather type with tanning method, lining, trims, hardware, dyes, prints, finishes), intended use and target consumer, declared age range if relevant, conditions of use and care instructions.
Internal risk analysis under Article 9
Hazard identification across the categories relevant to non-harmonised consumer products (chemical composition under REACH for textiles and leather, azo dyes, nickel release on metal trims, chromium VI for leather, mechanical hazards, flammability for textile categories, choking and strangulation risks where drawstrings or cords are involved), severity-by-likelihood matrix per hazard, 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. This is the document your European buyer’s legal team 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 and attached to the hang tag, sewn into a care label, or affixed to the master carton.
The specific document your European buyer is asking about
When a European buyer’s legal counsel asks for “GPSR documentation” they are asking for a structured internal risk analysis under Article 9 of Regulation (EU) 2023/988, the EU Declaration of Conformity that references it, and confirmation of a designated EU Responsible Person 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 summary, not a certificate of origin, not an ISO 9001 statement. These adjacent documents may already be in your buyer’s tech pack and they do not replace the Article 9 file.
Under Article 2 of Regulation (EU) 2023/988, for products covered by Union harmonisation legislation (LVD, EMC, RED, Cosmetics Regulation, Toy Safety Directive, Medical Device Regulation, Machinery Regulation and similar sector-specific acts) the GPSR Chapter II does not apply to the risks covered by that harmonisation legislation — but for non-harmonised consumer products such as textiles, leather goods, bags, footwear (non-PPE), fashion accessories, home decoration, ceramics, wooden furniture, stationery and most handicrafts, the Article 9 file is the primary compliance document the buyer’s legal team is asking for. GPSRCheck generates it.
What it does not generate — and what no compliance tool on the market generates legitimately — is a “GPSR certification”, because the regulation does not establish a certification scheme. Any vendor selling you a “GPSR certificate” is using terminology that does not match the text of the Regulation. What exists is the technical file, the declaration and the Responsible Person designation. That is the package your buyer needs.
Technical file and EU Responsible Person are two separate compliance layers — and many Indian exporters already have the second one resolved through their European buyer
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 after the last unit is placed on the market (Article 9.4). GPSRCheck produces this in ten minutes at €49 per SKU.
The EU Responsible Person
A natural or legal person established in the EU who acts as the contact point for market surveillance authorities. For Indian exporters selling B2B to a European buyer who is the importer of record, the buyer is already the Responsible Person by operation of law — no separate contract needed. For direct B2C export (Amazon EU, own Shopify, Etsy), a separate AR provider is needed: ecinternational.co.in, Veteran Group, EaseCert, Euverify, gpsrcompliant.eu at €150–500 per year.
GPSRCheck deliberately does not bundle the Responsible Person service into its €49 fee, because many Indian 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 one document only the manufacturer can produce, and lets you choose whatever Responsible Person arrangement fits the commercial structure of each buyer relationship.
Enforcement reality for Indian 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 Rotterdam, Hamburg, Antwerp, Valencia, Piraeus and Gdańsk intensified documentation checks on non-EU consignments of consumer products.
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 of the product 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. An Indian exporter with a manufacturing unit of thirty workers carries the same documentary obligations as a large manufacturing group.
For Indian exporters with B2B buyer relationships, the most common enforcement pathway is commercial, not regulatory: the European buyer’s legal department adds the Article 9 file to the supplier qualification process. Suppliers who produce the file continue receiving POs. Suppliers who cannot get suspended from the vendor list and replaced. The €49 file restores the relationship; the alternative is permanent displacement.
Consultancy, subscription platforms, bundled enterprise services and GPSRCheck
| Traditional consultancy | Annual subscription platforms | Bundled enterprise (EaseCert) | GPSRCheck | |
|---|---|---|---|---|
| Indicative price | €400–2,000 per product | €199–500 per year | €400–500 one-time per product | €49 per SKU, one-time |
| Payment model | Invoiced per engagement | Annual subscription | One payment per product | One payment per SKU, pay with card |
| EU Responsible Person | No | Yes, bundled | Yes, bundled | No — contract separately, choose freely |
| Time to deliver | 1–3 weeks | 24–48 h after onboarding | 3–5 business days | 10 minutes |
| Data handling | Uploaded to consultant | Cloud storage on vendor servers | Cloud storage on vendor servers | 100% browser-side |
| Per-SKU cost at 20 SKUs | €8,000–€40,000 | €199–500 + per-SKU surcharges | €8,000–€10,000 | €980 (20 × €49) |
Prices for competitor services 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
Can a single EU Authorised Representative serve multiple Indian manufacturers, or do we each need our own dedicated AR?
Our medical device-specialised AR (Veteran Group, CMS MedTech, I3CGlobal) wants to also serve us as the GPSR AR. Is that fine?
We have an existing EU AR contract from 2023 under the old General Product Safety Directive. Does that contract automatically cover the new GPSR?
Our AR provider is asking us for a ‘technical file’ as part of the onboarding. Isn’t that what they’re supposed to provide?
How do we handle AR designation for a new SKU added mid-contract (e.g. we add new styles in July for an AW26 programme)?
Is it legally safer to have a dedicated AR from a provider, or to rely on the European buyer being the importer of record?
⚠️ Important notice: GPSRCheck generates the Article 9 technical file for non-harmonised consumer products only. Products under Union harmonisation legislation (Toy Safety Directive, Cosmetics Regulation, LVD, EMC, RED, MDR, Machinery Regulation, PPE Regulation) require different documentation. GPSRCheck does not provide the EU Responsible Person service under Article 16.