What “independent brand” means in the compliance conversation
An independent brand, for the purposes of this tool, is a brand that owns its product line — the design, the sourcing decisions, the quality control, the storytelling — and sells under its own name to EU consumers, directly or through wholesale retailers. This covers a wide range of business structures:
What unites these profiles is that the brand is the manufacturer under Article 3 of the GPSR — not a distributor, not a reseller, not a licensee. The responsibility for the technical file sits with the brand, and the brand is typically a small team where one founder wears the compliance hat in addition to several others.
Why enterprise compliance tools do not fit independent brands
The compliance market for EU product safety has three dominant archetypes and none of them match the independent brand profile:
Comprehensive but priced for corporate budgets
A full engagement including lab testing, notified body liaison, and a detailed certification audit. For an independent brand with 20 SKUs, this adds up to €8,000 to €40,000 — more than the annual profit of many small brands.
Works for stable catalogs but creates dependency
Bundles the technical file with a Responsible Person service, a dashboard, and ongoing updates. If you stop paying, you lose access to the files. The technical file is not portable.
Excellent for complex edge cases, expensive for the standard Article 9 file
The right path for complex regulatory questions, but a disproportionate spend for the straightforward Article 9 file that most non-regulated consumer categories actually need.
The independent brand needs a fourth option: self-service, structured, with a permanent PDF and no annual subscription. GPSRCheck is that option.
How the GPSRCheck file travels with your brand
One of the design choices that matters most for independent brands is portability. The 6-page PDF that GPSRCheck generates is a standard file: no DRM, no platform binding, no vendor lock-in. You download it, save it to your Google Drive or Dropbox, send it to retailers on request, upload it to Amazon Seller Central if you also list there, and hand it to your accountant if you sell the business.
When you change sales channels
A brand that starts D2C on Shopify and later opens Amazon EU can use the same files for both channels. No separate Amazon compliance package, no duplicate investment.
When you change Responsible Person providers
If you switch providers (for price, for service quality, for geographic fit), your GPSRCheck files do not care — you update the Responsible Person placeholder and continue. Files generated through bundled annual subscription platforms typically cannot be exported and used with a different Responsible Person.
When you sell the brand
If you exit the business, the new owner inherits the technical files as part of the brand assets. Files held inside a rented platform subscription may not transfer cleanly.
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
My brand has 15 products in one line. Is GPSRCheck cheaper than a subscription platform?
I produce in small batches with slight variations. Do I need a new file every batch?
My brand uses sustainable or natural materials. Does that change the risk analysis?
Can I generate the file before I finalise my EU Responsible Person?
Is the file accepted at trade fairs where European retailers ask for documentation on the spot?
What happens if my brand grows and I later need enterprise-level compliance?
⚠️ 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.