What a Declaration of Conformity actually is under the GPSR
The Declaration of Conformity is a legal document in which the manufacturer (or their authorised representative) declares, under their own responsibility, that the product meets the applicable EU legal requirements. It is signed, dated, and references the specific regulation or directive that the declaration addresses — for the GPSR, that is Regulation (EU) 2023/988.
The Declaration is a short document, typically one page, that follows a structure established in EU product legislation: issuer identification, product identification, list of applicable EU legal acts, reference to harmonised standards applied, date and place of issue, signature. Templates circulating online for free typically get the structure right — the problem is not the structure.
The problem is the backing. The Declaration of Conformity is a public-facing attestation that presumes the existence of a private-facing technical file. When a retailer, a marketplace or a market surveillance authority asks “show me your compliance”, they ask for the technical file that supports the Declaration, not just the Declaration itself. A Declaration signed without a real underlying Article 9 risk analysis is technically a false declaration — the kind of thing that creates personal legal exposure for the signatory.
What small businesses typically get wrong with free templates
Four failure modes show up consistently when small brands try to compile GPSR documentation from free templates found online:
Declaration without risk analysis
The template produces a clean Declaration page but no risk analysis. When Amazon or a retailer asks for the technical file, the seller has only the Declaration to send. The response is rejected as incomplete.
Generic risk analysis copy-pasted from another product
The template comes with sample risk analysis text that the user adapts minimally. Market surveillance authorities reviewing the file spot the generic language immediately, and the product is flagged as having no real assessment.
Wrong regulation references
The free template was drafted for the old GPSD (Directive 2001/95/EC) and still references it. The Declaration needs to reference Regulation (EU) 2023/988 specifically, and any applicable additional directives (LVD, EMC, RoHS, etc.). Outdated references create immediate rejection.
Missing EU Responsible Person
The Declaration identifies the manufacturer but leaves blank the Responsible Person field because the small business has not yet contracted one. An incomplete Declaration is not legally valid.
GPSRCheck avoids all four by structuring the full dossier together: the risk analysis is specific to the product you enter, the references are current (Regulation (EU) 2023/988), and the Responsible Person placeholder is a deliberate field that you fill in once you contract a provider.
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
Can I just use a free Declaration of Conformity template and skip the risk analysis?
Is the Declaration of Conformity the same document as the CE Declaration of Conformity I already have?
Who has to sign the Declaration of Conformity?
How often do I need to update the Declaration?
Can I write the Declaration in English if I sell across multiple EU countries?
How is the GPSRCheck output different from buying a premium template from a compliance site?
⚠️ 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.