Reg. (EU) 2023/988 · Art. 9 Generate — €49

GPSR compliance for Shopify brands selling to the EU: the technical file without the app subscription.

A growing share of Shopify D2C brands ship to EU consumers without ever touching Amazon. Own storefront, own brand, own margin — the whole point. Then the GPSR arrived on 13 December 2024 and the question became: does Shopify handle this? The answer is no. Shopify is a platform — it does not produce Article 9 technical files, does not sign Declarations of Conformity and does not act as a Responsible Person on your behalf. The app store is full of apps that promise GPSR compliance but most of them handle the front-end disclosure without generating the underlying document that a Shopify brand actually needs to hold on file. GPSRCheck produces the document itself: the 6-page PDF with risk analysis, Declaration of Conformity and printable label, portable and owned by you, not tied to any Shopify app or subscription.

Generate GPSR Technical File Free diagnostic: do you need GPSR documentation?

€49 per product · 10 minutes · 6-page PDF: technical file + EU Declaration of Conformity + printable label · 100% in your browser · Permanent PDF · 30-day edit window, up to 10 regenerations

Built on Regulation (EU) 2023/988·Article 9 internal risk analysis·EU Declaration of Conformity included·Printable product label·Data never leaves your browser

What Shopify does and does not do for GPSR compliance

✓ What Shopify does

Commerce infrastructure and display

Shopify provides the commerce infrastructure. The platform allows merchants to display compliance-related information on product pages (manufacturer name, Responsible Person, safety warnings) through product metafields and theme customisation. Shopify Markets allows differentiated content per country, which can be used to show EU-required information to EU customers only.

∅ What Shopify does not do

The actual Article 9 document layer

Shopify does not generate the Article 9 technical file, does not produce or sign the Declaration of Conformity, does not act as the EU Responsible Person, does not verify that the manufacturer data entered is correct, and does not respond to market surveillance authority requests on the merchant’s behalf. These obligations sit with the brand owner — you — regardless of which commerce platform you use.

When evaluating a Shopify app, ask specifically: does it produce a downloadable Article 9 risk analysis that you keep on file and can send to a retailer or an authority on request? Most apps do not. GPSRCheck is a separate tool that does exactly that — and the PDF it generates is yours, not rented through an app subscription.

The Shopify brand compliance stack, end to end

1

Technical file per SKU — GPSRCheck handles this

Generated in GPSRCheck. Stored by you (Google Drive, Dropbox, Notion, anywhere). Sent to retailers or authorities on request. One-time €49 per product.

2

Product page disclosure — Shopify theme work

Manufacturer name and address, EU Responsible Person contact, safety warnings and use instructions, all displayed on the product page in the EU customer’s language. Handled on the platform side, not by GPSRCheck.

3

EU Responsible Person service — separate contract

Contracted from an EU-based provider separately. Typical cost €150 to €300 per year. Their name and contact goes both on the product label (physical) and on the product page (digital).

4

Physical label on product or packaging — GPSRCheck page 6

Generated as page 6 of the GPSRCheck PDF, printed and applied to each unit before it ships from your warehouse or fulfilment centre.

5

Record retention — 10 years

The technical file must be retained for 10 years from the date the last unit was placed on the market. Keep your GPSRCheck PDFs backed up in at least two locations.

The layers that GPSRCheck handles (1 and 4, plus the Declaration that supports layer 2) are the hardest to produce. Layers 2 and 3 are platform configuration and a contracted service.

What’s in the 6-page PDF

1

Product identification and traceability

Manufacturer name and address, EU Responsible Person placeholder, SKU, batch reference, product category.

2

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.

3–4

Article 9 internal risk analysis

Hazard identification, likelihood and severity assessment, mitigation measures, residual risk statement.

5

EU Declaration of Conformity

Signed template referencing Regulation (EU) 2023/988 and any additional applicable directives (LVD, EMC, RoHS, toy safety, etc. as applicable).

6

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.

● Layer 1 — Article 9 (GPSRCheck does this)

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.

∅ Layer 2 — Article 16 (separate service)

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

📅
1 April 2024 — Amazon begins enforcement

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.

⚖️
13 December 2024 — GPSR enters into force

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.

Ten-day response window

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.

⚖️
National fines up to €100,000+

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.

🔒
Safety Gate — permanent public listing

Products flagged as non-compliant are listed publicly, by brand and model. Inclusion is permanent and searchable — the reputational damage outlasts any fine.

⚓️
Customs blockage at EU ports

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?

 ConsultancyAnnual subscription platformGPSRCheck
Price€400–2,000 per product€199–600 per year€49 per product
Time to delivery3–15 business days48h onboarding + setup10 minutes
Billing modelQuote-based invoiceAnnual recurringOne payment per SKU · Permanent PDF · 30-day edit window
EU Responsible PersonIncluded in packageIncluded in packageSeparate (pick any provider)
Legal basisArt. 9 Reg. (EU) 2023/988Art. 9 Reg. (EU) 2023/988Art. 9 Reg. (EU) 2023/988
Data handlingSent to consultancyStored on vendor servers100% in your browser
PortabilityFile belongs to consultancyFile tied to subscriptionFile 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 enquiries
Commercial enquiries via solidwaretools.com or hello@solidwaretools.com

Frequently asked questions

I use a Shopify app that says it handles GPSR compliance. Do I still need GPSRCheck?
Depends on what the app actually produces. If the app generates a downloadable Article 9 technical file with the full risk analysis structure and the signed Declaration of Conformity, and the file remains accessible if you cancel the app subscription, then you are covered. Most apps handle the front-end disclosure but the underlying file either does not exist or disappears on cancellation.
My Shopify store uses Printful or Printify for fulfilment. Does the fulfilment partner generate the GPSR file?
Printful and Printify maintain some documentation for their own manufactured base products, but the final responsibility sits with the brand that places the product on the EU market — that is you, the Shopify merchant. For print-on-demand products where you customise the base, the customised product is considered a new placed product and you need your own technical file.
Does the GPSR apply if I ship one unit at a time to EU customers from outside the EU?
Yes. The GPSR applies to products placed on the EU market regardless of the shipping model. A single D2C shipment to an EU consumer is still placement on the market. The trigger is the sale to an EU consumer, not the batch size.
Can I block EU orders in Shopify to avoid GPSR entirely?
Yes, technically — you can use Shopify Markets to disable shipping to EU countries. The trade-off is lost revenue from EU customers. For brands with meaningful EU sales, compliance is usually cheaper than geoblocking.
What about the UK? Does the GPSR apply to Shopify brands selling to British customers?
The GPSR applies to Northern Ireland (Windsor Framework) but not to Great Britain. For GB-only sales, UK product safety rules apply separately. If your shipping zones include both EU and GB/NI, treat EU+NI as the GPSR scope and GB as a separate regime.
How do I attach the GPSR PDF to a Shopify product for internal reference?
Shopify product metafields can hold a link to a file stored in Shopify Files or in an external service. The PDF does not need to be shown to customers — it is your internal record and your response asset for retailer requests and authority audits.

⚠️ 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.

Shopify handles the store. GPSRCheck handles the document.

6 pages. 10 minutes. Article 9 risk analysis + EU Declaration of Conformity + printable label. €49 per product. Portable PDF, owned by you, not tied to any app subscription.

€49 per product
6-page PDF · 10 minutes · €49 per SKU · 100% in your browser · Permanent PDF, 30-day edit window
Generate the Technical File
✓ Last regulatory check: 27 April 2026 · No substantive changes detected · View history