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

GPSR for Chinese Sellers on Amazon EU: The Operational Playbook for the Regulation That Has Been Quietly Removing Your Catalog Since April 2024

Amazon’s GPSR enforcement started quietly in April 2024, eight months before the regulation technically entered into force, and escalated sharply after 13 December 2024. By March 2026, the removal pattern is no longer quiet. Chinese sellers on Amazon DE, FR, IT, ES and NL have watched catalogs thin out ASIN by ASIN over sixteen months — one listing flagged as GPSR documentation required, another as Responsible Person missing, another as Product detail page removed. The compliance dashboard in Seller Central now has a Regulatory Compliance tab that was invisible two years ago. This is the operational playbook for producing the documents Amazon is asking for at the speed and cost a 50+ SKU catalog requires. €49 per product. 10 minutes. Permanent PDF with a 30-day, 10-regeneration edit window.

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

80 SKUs in your Amazon EU catalog? One file at a time is not a plan.

Need GPSR technical files at volume? For high-volume catalogues and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.

Commercial enquiries
Commercial enquiries via solidwaretools.com or hello@solidwaretools.com
Built on Regulation (EU) 2023/988·Article 9 internal risk analysis·EU Declaration of Conformity included·Printable product label·Data never leaves your browser

The five flag types Amazon uses for GPSR enforcement

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Flag 1 — GPSRCheck addresses this

“GPSR documentation required”

The broad flag. Amazon wants the Article 9 risk analysis. This is the file GPSRCheck generates in 10 minutes.

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Flag 2 — Separate service needed

“Responsible Person information missing”

Article 16 requirement. You need to appoint an EU Responsible Person and provide their details. Separate service — €150 to €300 per year from specialised providers. Not provided by GPSRCheck.

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Flag 3 — Fix in Seller Central directly

“Manufacturer identification missing on product page”

Article 9.6 requirement. The manufacturer’s name, address and email must appear on the Amazon listing page itself. Fill in the relevant fields in Seller Central directly.

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Flag 4 — Per-marketplace translation needed

“Safety warnings and instructions not in local language”

Article 9.7 requirement. Safety information must be available in the language of each EU member state where the product is sold. Upload translated safety documentation per marketplace.

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Flag 5 — GPSRCheck label component addresses this

“Traceability identifier missing”

Article 9.5 requirement. The product must carry a type, batch or serial number. GPSRCheck’s printable label component addresses this directly.

The technical file GPSRCheck generates addresses Flags 1 and 5 directly, and provides the Declaration of Conformity that Amazon also requests in Flag 1 resolutions.

What the playbook looks like for a 60-SKU catalog

1

Week 1 — triage

Export the active ASIN list from Seller Central, identify which products fall under GPSR (almost always all non-food consumer products), group SKUs by product type and shared risk profile. Products with near-identical risk profiles may share documentation under Art. 9.3.

2

Week 2 — EU Responsible Person appointment

Contract a specialised EU Responsible Person provider. Typical onboarding is 48–72 hours. Pick any provider — the GPSRCheck technical files are portable and work with any Responsible Person.

3

Week 3 — technical file production

Generate 60 Article 9 files with GPSRCheck. At 10 minutes per file, the catalog takes 10 hours of specialist time. For commercial enquiries on high-volume catalogues, visit solidwaretools.com or email hello@solidwaretools.com.

4

Week 4 — upload and monitoring

Upload the technical files and Declarations of Conformity to each flagged ASIN in Seller Central. Monitor reinstatement status daily. Typical reinstatement is 24–72 hours after successful upload.

The bottleneck for most Chinese sellers is step 3 — the production of the files themselves. That’s the step GPSRCheck was built to eliminate as a bottleneck.

What’s in the 6-page PDF GPSRCheck generates

1

Cover page

Product identification, manufacturer data, unique file reference and generation date.

2

Product description

Materials, intended users, foreseeable misuse, and life cycle information.

3

Internal risk analysis under Article 9

Severity × probability matrix, hazard identification and mitigation measures across physical, mechanical, chemical, thermal, electrical, radiation and flammability categories.

4

EU Declaration of Conformity

In harmonised format, ready to sign, with legal basis citations to Regulation (EU) 2023/988.

5–6

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.

● 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 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.

∅ Layer 2 — Article 16 (separate service)

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

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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.

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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 now have a documented Article 9 internal risk analysis and an EU Responsible Person under Article 16.

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National fines and penalties

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.

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Safety Gate — permanent public listing

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.

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Customs blockage at EU ports

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?

 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

High-volume catalogues and special pricing

For high-volume catalogues and commercial enquiries, visit solidwaretools.com or email hello@solidwaretools.com.

Commercial enquiries
Commercial enquiries via solidwaretools.com or hello@solidwaretools.com

Frequently asked questions

Does the GPSR apply to Chinese sellers who have no physical presence in the EU?
Yes. The GPSR applies by market, not by where the seller is established. Any non-EU seller placing consumer products on the EU market is an economic operator under the regulation.
We are a trading company in Shenzhen, not the manufacturer. Who is responsible for the Article 9 file, us or the factory?
Under GPSR, the primary obligation falls on whoever acts as manufacturer for the purpose of placing the product on the EU market — which includes parties who brand the product, modify it, or present themselves as the manufacturer to EU buyers. For most private-label trading companies, your company is the manufacturer in GPSR terms and owns the Article 9 file obligation.
We sell the same product on Amazon DE, FR, IT, ES, NL and Pan-EU. Do we need one file or five?
One file per product. The GPSR is directly applicable across all 27 EU member states under the same text, so the technical file does not need member-state variants. Translations of safety warnings may be required per language under Article 9.7, but the underlying technical file is a single document.
What happens if market surveillance authorities ask to inspect our technical file and we cannot produce it within the required timeframe?
Depending on the member state, penalties for failure to produce the technical file on request can include fines up to €100,000 (higher in some jurisdictions), immediate product recall orders, public listing in the Safety Gate database, and in Germany, criminal penalties of up to one year of imprisonment for persistent infringements.
Does Amazon accept the GPSRCheck PDF directly, or do we need to reformat it?
Amazon Seller Central accepts the PDF directly. The GPSRCheck output is structured with the Article 9 components Amazon’s compliance review expects and does not require reformatting before upload.
How is GPSRCheck different from the annual subscription platforms (EAS, Eldris, Euverify, EaseCert)?
Four structural differences: price per product (€49 vs €150–€2,000), billing model (one-time vs annual recurring), whether the Responsible Person is bundled (we decouple, they bundle), and where your data lives (100% in your browser vs vendor servers). See the comparison section above for the full breakdown.

⚠️ 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.

The operational playbook. The right document. Generated at catalog scale.

6 pages. 10 minutes. €49 per product. Five flag types, one primary file. Permanent PDF with a 30-day edit window.

€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