What changed in December 2024 and why the ATR certificate and the Customs Union do not cover the new obligation
Turkish exporters have operated under the EU-Turkey Customs Union since 1995, which eliminated customs duties on industrial products and established the ATR certificate as the standard document of free circulation. For three decades the combination of the ATR, the certificate of origin from the local chamber of commerce, the CMR consignment note for road transport across Kapıkule at the Trakya border, and the usual product certifications demanded by each buyer (OEKO-TEX for textiles, FSC for wood furniture, E1 formaldehyde emission for panels, ISO 9001, BSCI) was enough to move goods into the EU smoothly.
On 13 December 2024 the European Union replaced its previous General Product Safety Directive of 2001 with Regulation (EU) 2023/988, a direct-effect regulation that applies uniformly across all 27 Member States plus the EEA without requiring national transposition. The new regulation introduced two documentary obligations: first, an explicit Article 9 internal technical file with a structured risk analysis for every non-harmonised consumer product placed on the EU market; second, an Article 16 designation of an EU Responsible Person for non-EU manufacturers. Neither of these obligations is covered by the ATR, by the Customs Union framework, or by any existing Turkish national certification. The ATR confirms that your product is in free circulation for customs purposes; the Article 9 file confirms that your product has been safety-assessed under the EU regulatory framework. They sit in two different legal layers and both are needed.
The Republic of Türkiye Ministry of Trade has publicly confirmed that Türkiye has transposed the horizontal legislation of the EU on CE marking, notified bodies, market surveillance, general product safety and mutual recognition. There is no exemption for Turkish manufacturers based on the Customs Union. The Article 9 file is required for Turkish exporters exactly as it is required for manufacturers in any other non-EU country.
The three verticals where Turkish exporters face this request most frequently, and the scope boundary for each
Bedroom, living room, dining, storage and occasional furniture for adults
Turkish furniture manufacturers — especially those based in the İnegöl cluster near Bursa, which supplies a significant share of the European mid-market and upper-mid-market — are among the first to receive formal GPSR documentation requests from their German, Dutch and French buyers. In scope: bedroom furniture, living room furniture, dining room furniture, youth furniture for 14 and above, occasional furniture. Excluded from GPSRCheck scope: motorised recliners, electric beds, furniture with integrated LED lighting, children’s furniture for under-14, and medical-function mattresses.
Knitwear, woven garments, home textiles, hosiery, fashion accessories
Turkey is the second-largest exporter of garments to the European Union after China, with deep B2B relationships spanning fast fashion to workwear. In scope: knitwear, woven garments, home textiles (bed linen, table linen, towels from Denizli), hosiery, scarves, shawls, fashion accessories and non-PPE workwear. Excluded: PPE workwear under Regulation (EU) 2016/425, children’s apparel falling under the Toy Safety Directive scope, and medical textiles.
Bags, belts, wallets, garments, non-PPE gloves, adult leather footwear
Turkish leather manufacturers export finished bags, belts, wallets, small leather goods, non-PPE gloves, leather garments for adults and leather footwear (non-PPE) to European buyers. In scope: the full chemical hazard analysis under REACH (chromium VI, azo dyes, heavy metals), mechanical hazards, traceability. Excluded: PPE safety footwear under Regulation (EU) 2016/425, medical-use leather products under the MDR, children’s leather items under the Toy Safety Directive.
What the 6-page PDF actually contains, for a Turkish or Egyptian exporter serving European buyers
Product identification and economic operator data
The model number or SKU identifier your buyer uses in the PO, the brand name under which the product is placed on the EU market, your manufacturing unit as manufacturer of record with full postal address in Turkey or Egypt, and the slot for the EU Responsible Person contact — which may be the European buyer acting as importer of record, or a dedicated EU Responsible Person provider.
Product description and intended use
Full composition inventory (wood species for furniture, fibre blend for textiles, leather type and tanning method, fittings, hardware, fabrics, finishes, adhesives), intended use and target consumer, declared age range where relevant, conditions of use and care instructions.
Internal risk analysis under Article 9
Hazard identification across the categories relevant to your vertical. For furniture: structural stability, tipping risk, sharp edges, pinch points, chemical emissions from panels and finishes, entrapment risks, joint strength. For textiles: chemical composition under REACH (azo dyes, nickel release, phthalates, flame retardants), mechanical hazards, flammability, colourfastness. For leather goods: chromium VI, azo dyes, heavy metals, sharp trims, attachment point strength. Severity-by-likelihood scoring, mitigation measures, residual risk statement.
EU Declaration of Conformity
Referencing Regulation (EU) 2023/988 Article 9 and ready for electronic signature by the manufacturer or authorised signatory. The document the European buyer’s legal counsel needs to close the compliance file and issue the PO.
Printable product label — two copies per A4 sheet
Manufacturer name and postal address, EU Responsible Person contact, product identifier, warnings where applicable, traceability batch code. Ready to be printed at your facility, attached to the product, sewn into a care label for textiles, or affixed to the master carton for furniture.
The document your European buyer is asking about
When a European buyer’s legal department or quality and compliance team sends you a formal email asking for “GPSR documentation per Regulation (EU) 2023/988” they are asking for a structured internal risk analysis under Article 9, the EU Declaration of Conformity that references it, and confirmation of an EU Responsible Person designation under Article 16. The internal risk analysis is the substance of the file — not a test report from an accredited laboratory, not an OEKO-TEX certificate, not a BSCI audit, not an ISO 9001 statement, not an ATR certificate, not a certificate of origin from your chamber of commerce. These adjacent documents are already in your buyer’s tech pack and they do not replace the Article 9 file under the Regulation.
Under Article 2 of Regulation (EU) 2023/988, for products covered by Union harmonisation legislation (Low Voltage Directive 2014/35/EU, EMC 2014/30/EU, RED 2014/53/EU, Toy Safety Directive 2009/48/EC, Cosmetics Regulation (EC) 1223/2009, Medical Device Regulation 2017/745, Machinery Regulation 2023/1230 and similar) the GPSR Chapter II does not apply to the risks covered by that harmonisation legislation. For non-harmonised consumer products — furniture without electrical components, textiles without PPE function, leather goods, fashion accessories, home decoration, ceramics, non-electric homeware, stationery — the Article 9 file is the primary compliance document.
GPSRCheck generates that file. What it does not generate — and what no compliance tool generates legitimately — is a “GPSR certification”, because the Regulation does not establish a certification scheme. Any vendor selling you a “GPSR certificate” is using marketing terminology that does not match the text of the Regulation. What exists under the Regulation is the technical file, the EU Declaration of Conformity, and the Responsible Person designation. That is the package your European buyer is asking for.
The two compliance layers and why most Turkish and Egyptian B2B exporters do not need a separate Responsible Person contract
Regulation (EU) 2023/988 imposes two distinct documentary obligations on a non-EU manufacturer placing consumer products on the EU market.
The technical file
The risk analysis, the EU Declaration of Conformity and the printable label — the manufacturer’s own responsibility to produce and keep for ten years (Article 9(4)). For a Turkish or Egyptian B2B exporter, this is the €49 GPSRCheck file. GPSRCheck produces it in ten minutes per SKU. One license per SKU, no subscription: the PDF is permanent, and the license lets you regenerate the file up to 10 times within 30 days from first activation to correct details.
The EU Responsible Person
For Turkish and Egyptian exporters selling B2B to a European buyer who is the importer of record, the buyer is already the Responsible Person by operation of law under Articles 13 and 16 — no separate contract needed. For direct B2C export (Amazon EU, Shopify, Etsy), a separate EU AR is required: EaseCert, Euverify, Lovat Compliance, EU Compliance Partner or gpsrcompliant.eu at €150–500 per year.
GPSRCheck deliberately does not bundle the Responsible Person service into its €49 fee, because many Turkish and Egyptian exporters in B2B structures do not need a separate Responsible Person at all. Unbundling keeps the price at €49, keeps the tool focused on the document only the manufacturer can produce, and lets you choose the Responsible Person arrangement that fits the commercial structure of each buyer relationship.
Enforcement reality for Turkish and Egyptian exporters shipping consumer products to Europe
Amazon started suspending EU listings of non-EU sellers without a designated EU Responsible Person eight months before the GPSR’s official entry into force. Non-Amazon channels followed through 2025: European B2B buyers updated their PO templates to require the Article 9 technical file as a condition of PO issuance.
The regulation entered into force across all 27 EU Member States and the EEA. EU customs at Kapıkule at the Trakya border, Piraeus, Thessaloniki, Rotterdam and Hamburg intensified documentary inspection on non-EU consignments of consumer products from Turkey and Egypt.
Market surveillance authorities have the power to require the technical file within a short deadline of typically ten working days. 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 Turkish furniture manufacturer with a hundred-worker unit in İnegöl carries the same documentary obligations as a multinational manufacturer with EU subsidiaries.
For Turkish and Egyptian exporters with B2B buyer relationships, the most common enforcement pathway is commercial: the European buyer’s legal department updates the supplier qualification process and adds the Article 9 file to the list of documents required for continued supplier status. Suppliers who produce the file continue receiving POs. Suppliers who cannot get suspended from the vendor list and replaced. For a Turkish furniture exporter whose largest client represents 20–30% of annual turnover, a suspended vendor status is an existential event. The €49 file restores the relationship.
Consultancy, subscription platforms, bundled enterprise services and GPSRCheck
| Traditional consultancy (local) | Annual subscription platforms | Bundled enterprise (EaseCert) | GPSRCheck | |
|---|---|---|---|---|
| Indicative price | €250–800 per product | €199–500 per year | €400 standard / €500 furniture, one-time | €49 per SKU, one-time |
| EU Responsible Person | No | Yes, bundled | Yes, bundled | No — contract separately if needed |
| Time to deliver | 3–8 weeks | 24–48 h after onboarding | 3–5 business days | 10 minutes |
| Data handling | Sent to consultant | Cloud storage on vendor servers | Cloud storage on vendor servers | 100% browser-side |
| Per-SKU cost at 30 SKUs | €7,500–€24,000 | €199–500 + tier surcharges | €12,000–€15,000 | €1,470 (30 × €49) |
Competitor prices verified from their public pricing pages as of April 2026. For high-volume catalogues and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.
High-volume seasonal catalogues and special pricing
For seasonal catalogues and commercial enquiries, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
Turkey is in a Customs Union with the EU since 1995. Does that not exempt Turkish manufacturers from the GPSR?
Our buyer has been buying from us for fifteen years. Can they accept our previous certifications (ISO 9001, BSCI, OEKO-TEX, FSC) instead of the GPSR file?
We export to Germany, Netherlands, France and Italy through different buyers. Do we need separate files for each buyer?
Our unit ships 80 product lines per year in seasonal collections. Do we really need 80 separate files?
We already use the ATR certificate for every shipment and a certificate of origin from our chamber of commerce. Are those not enough?
Some online sources said Turkish manufacturers do not need an EU Authorised Representative. Is that true?
⚠️ Important notice: GPSRCheck generates the Article 9 technical file for non-harmonised consumer products only. Products under Union harmonisation legislation (Toy Safety Directive for children under 14, Low Voltage/EMC/RED for electrical equipment, MDR for medical devices, Machinery Regulation, PPE Regulation) require different documentation. GPSRCheck does not provide the EU Responsible Person service under Article 16.