Why private label sellers are the GPSR manufacturer by legal definition
GPSR Article 3 defines manufacturer broadly. It is not limited to the party with the physical production facility. It includes any party who “places a product on the market under its own name or trademark”. The test is not where the product was made — the test is whose brand identity attaches to the product on the EU market.
The Article 9 file is yours
Your Chinese supplier may have their own technical documentation under Chinese safety standards. That documentation does not transfer to your brand. The Article 9 risk analysis has to be produced in your name, with your brand identity, for the product as placed on the EU market under your label.
The product label must carry your contact details
Under Article 9.6, the manufacturer’s name, trademark, postal address and email must appear on the product, its packaging or accompanying documents. If your brand is on the product but your supplier’s name is on the label, the label is non-compliant under GPSR.
The EU Responsible Person is appointed by you, not by your supplier
Article 16 requires the manufacturer to appoint the Responsible Person. That is you. Your supplier’s Responsible Person (if any) does not cover your branded product.
GPSRCheck produces the Article 9 file in your brand name, with your company details on the Declaration of Conformity and on the printable product label, ready for private-label use.
Three private label scenarios and what each needs
Private label on Amazon with manufacturer-supplied CE marking
Your product has CE marking from the original manufacturer (common for electronics, toys, PPE). You still need your own Article 9 file because GPSR covers risks CE does not, and because your brand name makes you the GPSR manufacturer regardless of CE status.
Private label on Amazon without CE marking
Your product does not fall under a CE-scoped directive (typical for textiles, home goods, furniture, kitchenware, fashion accessories, jewellery). The Article 9 file is your only compliance document. GPSRCheck produces the full stack.
Private label on your own Shopify/WooCommerce, not Amazon
The GPSR still applies. Direct-to-consumer sales to EU buyers are squarely within scope. Your obligation is the same regardless of sales channel: Article 9 file, EU Responsible Person, manufacturer identification on the 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, with legal basis citations to Regulation (EU) 2023/988.
Printable product label (2 copies)
All mandatory GPSR data: manufacturer identification, traceability identifier, safety warnings. Ready to cut and affix. Document retention statement: 10 years from date of market placement.
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 the document Amazon Seller Central asks you to upload. GPSRCheck generates it in 10 minutes for €49 per product. 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
A separate legal requirement: every non-EU manufacturer must appoint an economic operator established in the EU as the regulatory contact point. This is a service, not a document — typically €150 to €300 per year. You can combine our technical file with any EU Responsible Person provider. The PDF you download is yours to keep and is not tied to any Responsible Person contract.
The industry standard among competitors is to bundle both layers into a single annual subscription of €199 to €2,000. 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 now have a documented Article 9 internal risk analysis and an EU Responsible Person under Article 16.
Member states are implementing national penalty regimes. Fines typically reach up to €100,000 per infraction. Germany additionally imposes criminal penalties of up to one year of imprisonment for persistent infringements. France allows proportional fines up to 10% of annual turnover. Italy, Spain, Netherlands and Poland have enacted comparable ranges.
The EU’s public database of dangerous products (formerly RAPEX). Products flagged as non-compliant are listed publicly, by brand and model. Inclusion in Safety Gate is permanent and searchable — the reputational damage outlasts any fine.
Customs authorities may detain shipments without valid GPSR documentation. The cargo sits in port warehousing, accruing daily storage costs, until documentation is produced or the shipment is returned at the manufacturer’s expense.
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 Chinese supplier already gave me a CE declaration. Does that make me GPSR-compliant automatically?
I have 40 SKUs across three brands. Do I need 40 files or three?
My supplier is willing to give me their Article 9 file. Can I just rebrand it with my details?
We import products from multiple suppliers in China, some with identical products just in different colors. Do I need separate files per color?
What’s the difference between what GPSRCheck generates and what an enterprise consultancy like Intertek or SGS would produce?
If I change my brand name or rebrand a product, do I need a new file?
⚠️ 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.