The five obligations US sellers have under the GPSR
Technical file per SKU
Every non-food consumer product listed on an EU Amazon marketplace needs an Article 9 technical file: internal risk analysis, product description with intended use and foreseeable misuse, list of applicable EU standards, EU Declaration of Conformity. This is the document Amazon Seller Central asks you to upload. This is what GPSRCheck generates.
EU Responsible Person
Under Article 16, every product placed on the EU market by a non-EU manufacturer must have a designated Responsible Person established in the EU — whose name and contact details appear on the product label and who responds to market surveillance requests. Contracted separately from any EU-based provider, typically €150 to €300 per year.
Product label with traceability data
The label must carry the manufacturer’s name and address, the EU Responsible Person’s name and contact, and traceability identifiers (model, batch, serial where applicable). GPSRCheck generates a printable label on page 6 of the PDF.
Safety Gate readiness
If a safety issue emerges after the product is on the market, the manufacturer must notify member state authorities via the Safety Business Gateway. This is a reactive obligation — you do not file anything in advance, but you must have the internal procedure ready.
Document retention
The technical file must be retained for 10 years from the date the last unit was placed on the market.
What is different for a US seller versus an EU-based seller
Cannot self-designate as Responsible Person
An EU-based seller with an EU entity can self-designate. A US seller must contract a separate EU-based Responsible Person. This is a permanent ongoing cost.
Time zone creates a response-window problem
When a German BAuA or French DGCCRF inspector emails with a 10-day deadline, you have 10 calendar days, not 10 business days, and the email may arrive at 3am your time. The technical file needs to be ready before the email arrives.
Amazon’s flags are asymmetric
A US seller with a missing GPSR file typically gets flagged faster and reinstated slower than an EU-resident seller, because Amazon’s automated systems treat non-EU manufacturers as higher-risk.
The GPSR is not the same as the CPSC, and your US certifications do not carry over
The US Consumer Product Safety Commission (CPSC) framework and the EU GPSR are two independent regulatory regimes. Nothing from the US side — ASTM testing, FCC certification, UL listing, CPSIA children’s product certificates, Prop 65 compliance — transfers automatically to the EU framework. The EU regime requires an EU-referenced Declaration of Conformity citing Regulation (EU) 2023/988, an internal risk analysis referencing EN standards (not ASTM or ANSI), and a Responsible Person under Article 16 that has no US equivalent.
For US sellers building a first-time EU compliance package, the correct mental model is: your US certifications stay in place for the US market, and a separate EU compliance package is built on top for the EU market. GPSRCheck produces the EU compliance package.
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 |
40 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 enquiriesFrequently asked questions
I already pay for a US-based compliance consultant. Can they produce the EU file too?
Do I need a separate Responsible Person for each product or can one cover my whole catalog?
If my listings are only on Amazon.co.uk and not on any EU marketplace, does the GPSR apply?
What’s the fastest way for a US seller to get one SKU compliant for a listing reinstatement?
Can I put a US address on the product label?
Does a single technical file cover multiple Amazon marketplaces (DE, FR, IT, ES, NL)?
⚠️ 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.