Why the letter arrived now, and why OEKO-TEX and BSCI are not what the buyer needs
European buyers of textiles, leather goods, handicrafts and home decoration from India were operating under the General Product Safety Directive of 2001 until December 2024. Under that directive, national implementation was uneven and documentary enforcement at the supplier qualification level was largely absent — buyers relied on OEKO-TEX, BSCI, amfori, ISO certifications and the supplier’s own quality assurance. On 13 December 2024, Regulation (EU) 2023/988 replaced the directive and introduced direct, uniform enforcement across all 27 Member States. From that moment, the buyer’s own liability downstream changed: if a safety incident occurs with a product sourced from your unit and the buyer cannot produce the Article 9 technical file, the buyer is in breach of its own obligations as the importer of record and faces penalties directly.
The compliance team’s reaction, across the first fifteen months of the regulation being in force, has been to update the supplier qualification process and add the Article 9 file as a condition of continued vendor status. The letter you received is the operational consequence of that internal process, not an escalation or a personal problem with your relationship. The merchandiser you normally deal with probably did not know it was coming.
OEKO-TEX Standard 100 covers harmful substances in textiles under a specific test scheme. BSCI and amfori cover social compliance and labour conditions. ISO 9001 covers quality management. None of these address the Article 9 internal risk analysis that Regulation (EU) 2023/988 requires. Producing it does not replace any of your existing certifications — they remain part of your evidence base — it sits alongside them and satisfies a different regulatory obligation.
From letter received to buyer email answered — the three-day operational path
Generate the first file as a proof of concept
Open GPSRCheck, generate the Article 9 file for the first style in the disputed order. Ten minutes. Download the 6-page PDF. Open it, review it, confirm the content matches your product. This is the operational proof that the workflow works for your case before you commit to producing the rest of the files.
Confirm the Responsible Person arrangement
Decide whether your buyer is already acting as importer of record (most common in textile and leather B2B trade to Europe — the German or Dutch or Italian buyer is the importer of record and therefore already the Responsible Person under Article 16). If yes, proceed. If no, open a parallel track with a Responsible Person provider in the €150–500 per year range and start onboarding within 48 to 72 hours.
Generate remaining files for the full order
Generate the remaining files for the rest of the styles in the disputed order. For a 15-style order at €49 per SKU, total cost €735. For a 40-style order, total cost €1,960. Compare with the €6,000 to €80,000 your buyer’s compliance team absorbs in internal audit time for each supplier that has to be replaced.
Email the buyer’s legal counsel
Email the buyer’s legal counsel with the complete set of PDFs attached, referencing the PO number, confirming the Responsible Person arrangement (whether the buyer themselves or a third-party provider), and requesting confirmation that the supplier qualification is now resolved. Expect a response within 48 hours — buyer compliance teams move fast when the documentation arrives in the correct format.
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
My buyer is asking for a ‘GPSR certificate’. I see EaseCert and EVTL India selling ‘GPSR certification’. Is that a real thing?
My buyer gave me a 45-day deadline. If GPSRCheck takes 10 minutes, why do I need three days of operational path?
My buyer is in Germany, another is in France, a third is in Italy. Do I need separate files for each buyer, or is one file per style enough?
Can I reuse the same file for a product that has colour variants — one style with six colourways?
My buyer is asking for ‘test reports’ alongside the technical file. Does GPSRCheck generate test reports?
I run a small unit with thirty workers and the buyer is asking for the same documentation as a larger supplier with three hundred workers. Is there really no small-business exemption?
⚠️ 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.