Why your retailer is asking, in plain terms
The retailer is not being difficult. Under the GPSR, distributors and retailers have their own compliance obligations: before placing a product on the market they must verify that the manufacturer has fulfilled its Article 9 and Article 16 obligations. The verification is performed through a documentary request — the retailer asks the supplier (you) for the technical file and the Declaration of Conformity, archives the documents, and can produce them if a market surveillance authority audits the retailer’s supply chain.
The buyer’s email with the compliance request is not a bureaucratic annoyance — it is the retailer’s own compliance team protecting the retailer from GPSR exposure. The retailers that ask first are the ones that will continue placing orders.
What the Declaration of Conformity contains and how it relates to the technical file
The Declaration of Conformity and the technical file are two distinct documents that work together. The technical file is the internal dossier: the Article 9 risk analysis, the hazard-mitigation mapping, the list of applied EU standards, the product description. The Declaration of Conformity is the signed public statement by the manufacturer attesting that the product complies with the applicable EU regulations — it references the technical file as its supporting evidence but does not reproduce it in full.
When a retailer asks for “the Declaration of Conformity”, what they typically want is the signed Declaration plus the supporting technical file. The GPSRCheck PDF includes both: the signed Declaration on page 5, and the full risk analysis on pages 3–4.
What to send back to your retailer, and how
Send: the GPSRCheck PDF for each SKU
One PDF per product code. Attach them to the reply email together with a short cover note referencing the request email.
Include in the cover note
Your brand name, the list of SKUs covered by the attached files, the name and contact of your EU Responsible Person (the retailer’s compliance team will check this), and your availability for follow-up questions.
Keep the response tight
Do not send raw test reports from a lab, marketing brochures, ISO 9001 certificates (unless specifically requested), or a mix of different document types. The PDFs, the cover note, nothing else.
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 retailer gave me a 30-day deadline. Is the GPSRCheck file enough or do I need a lab test?
The retailer asked for the Declaration in Italian. Does GPSRCheck generate translated versions?
Do I need to sign the Declaration of Conformity physically or is an electronic signature enough?
What if my product line has 25 SKUs and the retailer asked for all of them?
The retailer mentioned they want the file “for their archive”. Do I retain the original or does it become theirs?
Can the same PDF be sent to multiple retailers or do I need a separate version for each?
⚠️ 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.