The five mandatory components of an Article 9 risk assessment
Article 9.2 of Regulation (EU) 2023/988 imposes a structured obligation. A compliant risk assessment must contain all five of the following components:
Hazard identification across all relevant categories
Physical hazards (sharp edges, pinch points, moving parts), mechanical hazards (structural failure, collapse, tip-over), chemical hazards (toxicity, corrosivity, endocrine disruptors), thermal hazards (burns, scalding, fire), electrical hazards (shock, arc, short circuit), radiation hazards (UV, laser, electromagnetic), flammability hazards, and foreseeable misuse hazards. Not every product has every hazard type — the assessment must identify which categories apply.
Severity rating on a defined scale
Each identified hazard must be rated on a severity scale (typical scales run from negligible through minor, moderate, severe, and catastrophic). The scale must be documented so the rating can be understood by a reviewer.
Probability rating on a defined scale
Each hazard must be rated for probability of occurrence under normal use and under reasonably foreseeable misuse. Typical scales: very unlikely, unlikely, possible, likely, very likely.
Risk matrix derivation
The severity × probability matrix combines the two ratings to produce an overall risk rating per hazard. This matrix is the single most commonly missing component in rejected Amazon uploads — free templates often list hazards and ratings without deriving the risk from the matrix structure.
Mitigation measures and residual risk statement
For each non-negligible risk, the document must record what mitigation is applied (design change, warning label, instructions, packaging) and the residual risk after mitigation. The document concludes with a statement that the residual risk is acceptable for placing the product on the market.
GPSRCheck’s workflow walks through all five components as structured questions, produces the matrix automatically based on your input, and outputs the result as the Article 9 section of the 6-page PDF.
Why free templates from forums get rejected by Amazon
Chinese seller forums, r/FulfillmentByAmazon and various compliance blogs have circulated free GPSR risk assessment templates since late 2024. Most of these templates fail Amazon’s compliance review for one of four reasons:
No severity × probability matrix
The template lists hazards and writes a narrative about each, but does not show the matrix calculation. Amazon’s automated review specifically looks for the matrix structure.
Generic hazard list not specific to the product
The template uses a copy-pasted boilerplate hazard list that does not reflect the actual product. Amazon’s review catches generic language that does not match the product description on the listing.
No mitigation column or residual risk column
The template stops at hazard identification and does not complete the full risk cycle. GPSR Article 9.2 requires the full cycle, not just the first step.
No manufacturer identification in the document
The template is a blank form that was never filled in with the seller’s company details. Amazon rejects documents that do not identify the manufacturer.
GPSRCheck solves all four problems by generating a document tied to your specific product input, with your company details, with the full matrix calculation, and with the complete hazard → severity → probability → matrix → mitigation → residual risk flow.
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, citing Regulation (EU) 2023/988 Article 9.
Printable product label — 2 copies
All mandatory GPSR data: manufacturer identification, traceability identifier, safety warnings. Ready to cut and affix. 10-year document retention statement included.
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 what 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 — typically €150 to €300 per year. You can combine our technical file with any Responsible Person provider. The PDF you download is yours to keep and is not tied to any Responsible Person contract.
We decouple the two on purpose: you own the document, you pick the Responsible Person separately. 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.
Regulation (EU) 2023/988 replaced GPSD 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.
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.
Products flagged as non-compliant are listed publicly, by brand and model. Inclusion is permanent and searchable — 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 |
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
Do I need a professional risk assessor to do this, or can I produce the document myself?
How is the risk assessment different for an electronic product versus a textile product?
How long should the risk assessment section be?
Can the same risk assessment cover multiple product variants (colors, sizes)?
What if my product has no obvious hazards — do I still need a risk assessment?
Does Amazon’s compliance review reject risk assessments that look too ‘generic’ or ‘AI-generated’?
⚠️ 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.