What Article 9 actually asks from a first-time Kickstarter creator
Article 9 of Regulation (EU) 2023/988 imposes one central obligation on manufacturers of non-harmonised consumer products: keep an internal technical file that documents the safety of your product, and be able to produce it on request within a short deadline. For a tabletop game designed for adults, “the product” is the full box your backer will open — the board, the cards, the miniatures, the tokens, the rulebook, every physical component that came out of your manufacturing run.
The file has to identify the component inventory, declare the intended age group (for you, 14 and above, explicitly), walk through the relevant hazards for tabletop components, score each hazard on severity and likelihood, document the mitigations you applied at design and manufacturing stage, and state the residual risk you accept. It must be structured, signed, stored for ten years after the last unit is placed on the market (Article 9.4), and available in a language understood by the market surveillance authority that asks for it. English is accepted across the Union as a working language for this kind of documentation.
A traditional consultancy engagement produces exactly this, starting from a questionnaire you fill in and ending in a PDF they send you. GPSRCheck produces exactly this, starting from a guided browser form you fill in and ending in a PDF you download. The difference is the delivery time and the bill.
Your age rating is a legal boundary, not just a marketing choice
The distinction between a game for adults and a game for children is not a matter of taste in the eyes of EU product safety law — it is the border between two different legal regimes. Games that are “designed or intended, whether or not exclusively, for use in play by children under 14 years of age” fall under Directive 2009/48/EC, the Toy Safety Directive, and require a completely different technical file, CE marking, tests under the EN 71 series and in some cases intervention from a notified body.
Games that are designed and marketed explicitly for ages 14 and above fall under the GPSR as general consumer products, and Article 9 is the relevant framework. GPSRCheck only generates the GPSR Article 9 file. If your game is for children under 14, this tool is not the right one and you should contact a consultancy specialising in EN 71 toy testing.
⚠️ The canonical way to stay on the right side of the line: a clear statement on the box, in the rulebook and in your Kickstarter page that reads “designed for ages 14 and above, not suitable for children under 14”. That statement is not cosmetic; it is load-bearing legal architecture.
The full workflow from funded campaign to first EU package shipped
Confirm your game’s age rating
If it is 14 and above, you are in GPSR territory. If it is under 14, stop and look for a toy safety consultant.
List every distinct SKU shipping to EU backers
The base game is one SKU. A deluxe upgrade pack is a second SKU. An expansion is a third. A Kickstarter-exclusive miniatures pack is a fourth. Variants that ship in a different box to the backer count as distinct SKUs for Article 9 purposes.
Generate the Article 9 file for each SKU
GPSRCheck walks you through the guided form once per SKU. Ten minutes each, €49 each. For multi-SKU campaigns and commercial enquiries, visit solidwaretools.com or email hello@solidwaretools.com.
Contract an EU Responsible Person separately
This is the Article 16 layer. GPSRCheck does not provide it. Misfit Hobbies and RepGuardia Global serve the tabletop ecosystem directly; generalist providers work fine too. Budget €150 to €300 per year. The Responsible Person’s contact details go on the product label.
Print the label and affix to the outer box
Page 6 of the PDF is the ready-to-print label, two copies per A4 sheet, with all mandatory GPSR information for a consumer-facing outer package.
Hand the file to your fulfillment partner before they release the pallet
Most EU-based fulfillment partners now refuse to ship non-EU pallets to EU backers without sight of the Article 9 file and confirmation of a designated Responsible Person. The file in PDF plus the signed declaration plus the RP contact is the package they need.
What the 6-page PDF actually contains
Product identification and economic operator data
Your game title, barcode or SKU identifier, the designer or studio as manufacturer, the non-EU manufacturer address on record, and the slot for the EU Responsible Person contact you contract separately.
Product description and intended use
Full component inventory (box, board, cards, tokens, miniatures, rulebook, dice, sleeves, trays, any physical extras from stretch goals), intended age group declared explicitly as 14 and above, intended conditions of use and storage.
Internal risk analysis under Article 9
Hazard identification across the categories relevant to adult tabletop components (small detachable parts, sharp card edges, choking for unintended young users, chemical composition of printed cardstock and plastic components, paint residues on miniatures, magnetic components if present, functional hazards during gameplay), severity-by-likelihood matrix, mitigation measures, residual risk statement.
EU Declaration of Conformity
Referencing Regulation (EU) 2023/988 Article 9 and ready to sign electronically by the creator or the studio legal representative.
Printable product label — two copies per A4 sheet
Mandatory GPSR information: manufacturer identity and address, EU Responsible Person contact, product identifier, age warning, traceability batch or print run code. Designed to be cut and affixed to the base game box and any expansion boxes.
Technical file and EU Responsible Person — two separate compliance layers most creators conflate
Many first-time Kickstarter creators hear about the GPSR through a single channel — a fulfillment partner email, a BackerKit update, a forum thread — and come away thinking there is one document to buy. There are two, and they come from two different providers.
The technical file
The internal risk analysis, the EU Declaration of Conformity and the mandatory label that travel with the physical product. Produced by the manufacturer — in a Kickstarter context, by you as the designer and brand owner of the campaign, not by the factory that printed the components. GPSRCheck generates this file in ten minutes for €49 per SKU. One license per SKU, no subscription. The PDF you download is permanent; 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 natural or legal person established in the EU who can be contacted by market surveillance authorities on your behalf. Several providers serve the tabletop ecosystem directly — Misfit Hobbies and RepGuardia Global are two visible names in the space — and generalist EU Responsible Person services typically charge between €150 and €300 per year. GPSRCheck does not provide this service; that contract is separate.
Both layers are required. Neither one on its own is enough.
Enforcement reality for Kickstarter creators shipping to EU backers
Amazon started suspending EU listings of non-EU sellers without a designated EU Responsible Person eight months before the official entry into force of the regulation. Non-Amazon channels have been following at their own pace: BackerKit has issued project updates to creators, and fulfillment partners with EU warehouses now ask for documentation before releasing pallets.
The regulation replaced the 2001 General Product Safety Directive across all 27 EU Member States. Customs at the major EU entry ports check paperwork on non-EU consignments and fulfillment partners have updated their contracts to require sight of the Article 9 technical file before releasing pallets.
Market surveillance authorities have the power to require the technical file within a short deadline of typically ten working days, depending on the Member State. Failure to produce the file can result in withdrawal from the market and inclusion in the Safety Gate public database.
The European Commission’s official FAQ on the GPSR, published in December 2024, is explicit that exceptions cannot be made on the basis of business size. A solo creator running a Kickstarter campaign carries the same documentary obligations as a publisher with a warehouse.
In Germany, persistent infringements can carry fines of up to €100,000 or imprisonment of up to one year. Other Member States have comparable penalty regimes. Safety Gate listings are permanent and searchable by product and brand.
Traditional consultancy vs subscription platforms vs GPSRCheck
| Traditional consultancy | Annual subscription platforms | GPSRCheck | |
|---|---|---|---|
| Price | €400–€2,000 per product | €199–€600 per year | €49 per product, one-time |
| Time to deliver | 3–15 business days | Depends on onboarding | 10 minutes |
| Renewal | None | Annual | No subscription · Permanent PDF · 30-day edit window |
| Legal basis | Varies by firm | Varies by platform | Article 9, Reg. (EU) 2023/988 |
| Data handling | Uploaded to consultant | Uploaded to cloud | 100% browser-side |
| Printable product label | Varies | Varies | Yes, two copies per sheet |
| Tabletop 14+ scoping | No | No | Explicit in the workflow |
Multi-SKU campaign? Deluxe edition, expansion pack and base game each need their own file.
Shipping more than one SKU to EU backers? For multi-SKU campaigns and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
My game is designed for ages 10 and up. Is that adult enough for GPSRCheck or do I fall under the Toy Safety Directive?
My game has metal miniatures and resin sculpts. Does the material change the risk analysis under Article 9?
I’m a solo creator, not an incorporated company. Can I still be the ‘manufacturer’ for Article 9 purposes?
Do I need separate files for my base game and my deluxe upgrade pack, or does one file cover both?
My game is manufactured in China by Panda (or LongPack, Hota, Whatz). Under the regulation, is the manufacturer them or me?
My Kickstarter funded in 2023 and I’m still fulfilling outstanding pledges in 2026. Do I need the technical file retroactively?
⚠️ Important notice: GPSRCheck generates the Article 9 technical file for adult tabletop games designed for ages 14 and above only. Games designed for children under 14 fall under the Toy Safety Directive 2009/48/EC and require a different compliance path. GPSRCheck does not provide the EU Responsible Person service under Article 16.