CE Declaration vs GPSR Declaration: the operational differences
Attests compliance with specific directives
- Cites specific directives: Low Voltage 2014/35/EU, EMC 2014/30/EU, Toy Safety 2009/48/EC, etc.
- States that the product meets the essential requirements of the listed directives
- Results in the CE mark being physically affixed to the product
- Covers electrical safety, EMC, toy safety, medical device requirements, etc.
- Required by sector-specific regulations with explicit CE marking obligations
- Amazon does NOT accept this in response to a GPSR flag
Attests compliance with Regulation (EU) 2023/988
- Cites Regulation (EU) 2023/988 Article 5 and Article 9 specifically
- States that the Article 9 technical file is held and available to authorities
- No new logo on the product — GPSR requires contact details, traceability ID, safety warnings
- Covers general consumer product safety aspects not addressed by sector directives
- Required from all non-food consumer products on the EU market since 13 December 2024
- This is what Amazon Seller Central asks for in GPSR compliance flags
The single most common rejection pattern: sellers upload CE Declarations in response to GPSR flags and get rejected by the automated review. CE and GPSR are different documents. Submit the GPSR Declaration that GPSRCheck generates.
When you need a GPSR Article 9 file and when the sector-specific file is what you hold instead
The GPSR Article 9 technical file is the document required for consumer products that are not covered by Union harmonisation legislation — textiles, leather goods, ceramics, stationery, wooden furniture, homeware, fashion accessories and similar non-harmonised categories. For products that fall under harmonisation legislation (toys under Directive 2009/48/EC, low-voltage electrical equipment under LVD 2014/35/EU, EMC under 2014/30/EU, radio equipment under RED 2014/53/EU, cosmetics under Regulation (EC) 1223/2009, medical devices under Regulation (EU) 2017/745, machinery under Regulation (EU) 2023/1230, etc.), Article 2(1) of Regulation (EU) 2023/988 excludes Chapter II of the GPSR and the Article 9 file does not apply to the risks covered by that sector legislation: the sector-specific technical file backing the CE Declaration is the document you hold. GPSRCheck generates the Article 9 file for the non-harmonised category only.
Determine whether your product is covered by Union harmonisation legislation
Before producing any documentation, identify whether your product falls under a sector-specific Union harmonisation act (LVD, EMC, RED, Toy Safety Directive, Cosmetics Regulation, MDR, Machinery Regulation, PPE Regulation, etc.). Union harmonisation legislation is defined in Article 3(27) of Regulation (EU) 2023/988.
If it is harmonised, the sector-specific technical file is your primary document
For products under harmonisation legislation the GPSR Article 9 file does not apply to the risks covered by that legislation. What you hold is the technical file mandated by the sector act (EN 71 file for toys, PIF with CPSR for cosmetics, MDR technical documentation for medical devices, LVD/EMC technical file for electrical equipment, etc.). GPSRCheck is not the correct tool for these products.
If it is non-harmonised, generate the Article 9 file with GPSRCheck
For non-harmonised consumer products the Article 9 internal risk analysis is the document Amazon Seller Central, EU retailers and market surveillance authorities are asking for. GPSRCheck produces the Article 9 file, the accompanying GPSR Declaration of Conformity and the printable product label in 10 minutes at €49 per product.
What’s in the 6-page PDF GPSRCheck generates
Cover page
Product identification, manufacturer data, unique file reference and generation date.
Product description
Materials, intended users, foreseeable misuse, and life cycle information.
Internal risk analysis under Article 9
Severity × probability matrix, hazard identification and mitigation measures across physical, mechanical, chemical, thermal, electrical, radiation and flammability categories.
EU Declaration of Conformity
In harmonised format, ready to sign, citing Regulation (EU) 2023/988 Article 9.
Printable product label — 2 copies
All mandatory GPSR data: manufacturer identification, traceability identifier, safety warnings. Ready to cut and affix. 10-year document retention statement included.
Generated from your own input, in your own browser. No data leaves your device.
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 what 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 — typically €150 to €300 per year. You can combine our technical file with any Responsible Person provider. The PDF you download is yours to keep and is not tied to any Responsible Person contract.
We decouple the two on purpose: you own the document, you pick the Responsible Person separately. 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.
Regulation (EU) 2023/988 replaced GPSD 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.
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.
Products flagged as non-compliant are listed publicly, by brand and model. Inclusion is permanent and searchable — 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 |
High-volume catalogues and special pricing
For high-volume catalogues and commercial enquiries, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
My product already has CE marking. Do I really need a separate GPSR Declaration?
Can the GPSR Declaration and the CE Declaration be combined into one document?
What specific text does the GPSR Declaration need to include?
Who signs the GPSR Declaration?
Does Amazon verify the signature on the Declaration of Conformity?
How often should I refresh the GPSR Declaration?
⚠️ 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.