Your position under the GPSR as a UK self-employed seller
Post-Brexit, the UK sits outside the EU single market, which means a UK-based seller shipping products to EU consumers is a non-EU manufacturer for GPSR purposes. The regulation treats a sole trader in Manchester, Edinburgh or Cardiff identically to a sole trader in Shenzhen or Austin: you are responsible for the technical file, you must designate an EU-based Responsible Person, and you must cooperate with EU market surveillance authorities through that Responsible Person.
There is no sole-trader exemption. There is no revenue threshold below which the GPSR stops applying. There is no carve-out for handmade, artisanal or craft products. There is no exception for “I only sell a few units a month”. The European Commission’s December 2024 FAQ addressed each of these hypotheticals directly and the answer was the same in every case: the regulation applies to the product placed on the EU market, not to the characteristics of the seller.
The only exemptions that exist are by product type (medicines, food, plants, antiques, funfair equipment, equipment marked “to be repaired before use”) and none of those cover the typical products that self-employed UK sellers ship to Europe.
What a self-employed UK seller actually needs in place
Technical file per SKU
Generated in GPSRCheck for €49 per product. One-time. The file is yours permanently. This is the Article 9 internal risk analysis, the signed EU Declaration of Conformity, and the printable label.
EU Responsible Person
Contracted separately from any EU-based provider. Typical cost for sole traders: €150 to €250 per year for basic catalog coverage. The provider’s name and contact details go on your product label and are the official point of contact for EU authorities.
Product label printed on each unit
The label must carry your name and UK address, the EU Responsible Person’s name and EU address, a traceability identifier (SKU, batch, model), and any mandatory warnings specific to your product category. Page 6 of the GPSRCheck PDF is a printable label template.
Retention of records for 10 years
The technical file must be kept for 10 years from the date the last unit was placed on the EU market. Back up your GPSRCheck PDFs in at least two locations (cloud storage plus a local drive is standard).
Cooperation with authorities through your Responsible Person
If a market surveillance authority in any EU member state contacts your Responsible Person about one of your products, they pass the request to you and you respond within the deadline — typically 10 calendar days for a technical file request.
That is the whole stack. There is nothing else required for non-regulated consumer categories. Children’s toys, PPE, medical devices and machinery have additional layers beyond the GPSR, but most self-employed UK sellers do not work in those categories.
What changed in 2024 for UK sellers and what has not changed since
GPSR enters into force
UK sellers lost the transition period that had been in place since Brexit. Every subsequent shipment to an EU consumer required the full compliance stack.
Discovery and adjustment
Many UK self-employed sellers discovered the change the hard way, through Amazon EU listing suspensions, Etsy compliance prompts, or individual customer queries. A portion of UK sellers simply stopped shipping to the EU during this period rather than complete the compliance work.
Enforcement environment has stabilised
Marketplaces are processing compliance uploads routinely. EU Responsible Person providers have matured their offerings for small sellers. For UK sellers who want to keep or restart EU sales, the path is documented and the tooling exists.
The post-Brexit UK-to-EU position itself
Until the UK rejoins the EU single market or negotiates mutual recognition of product safety regimes (not currently on the table), UK sellers will continue to be treated as non-EU manufacturers under the GPSR.
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 |
20 products in your line? One file at a time is not a plan.
Need GPSR technical files at volume? For high-volume product lines and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.
Commercial enquiriesFrequently asked questions
I am VAT-registered in the UK but my turnover is under £90,000. Does that affect GPSR scope?
I sell exclusively on Etsy to EU customers. Does Etsy handle the GPSR for me?
My products are handmade in my home workshop. Do handmade goods need the same technical file?
What about Northern Ireland customers? Is that the EU or the UK for GPSR purposes?
Can I be my own EU Responsible Person if I have a relative in the EU willing to help?
If I stopped shipping to the EU in 2025 and want to restart now, where do I begin?
⚠️ 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.