GPSR Technical File for Board Games: €49, 10 Minutes

Q: Is a self-produced technical file legally equivalent to one produced by a consultant?

Yes. Article 9 places the obligation on the manufacturer and does not require the file to be drafted by a third party. A structured self-produced file is equivalent to one a consultant produces.

Q: Do I need laboratory testing on top of the technical file for an adult tabletop game?

No. For an adult tabletop game in the Article 9 scope, lab testing is not a regulatory requirement. Lab testing becomes mandatory only under sector-specific directives such as EN 71 for toys, LVD/EMC for electronic products, PPE or medical devices.

What the file is, component by component, for a tabletop SKU

The Article 9 technical file is a structured document that follows a predictable shape, and once you have produced one for the first SKU of your campaign the subsequent SKUs reuse most of the analysis. The shape is: product identification (title, barcode, manufacturer, intended market), product description with a full component inventory, intended use declaration including the age group, hazard identification against a checklist of categories relevant to the product type, severity-by-likelihood scoring for each identified hazard, mitigation measures applied at design and production stage, residual risk statement, and attached evidence from the manufacturing chain where available.

For a tabletop SKU, the hazard categories that matter include small detachable parts (mitigated by the 14+ declaration and explicit warning), sharp edges on die-cut cardboard and plastic components, choking risk for unintended young users, chemical composition of inks and paints, composition and residual monomers of plastic and resin components, magnetic components where present, and functional gameplay hazards such as injury from manipulation of specific components. The GPSRCheck guided form walks you through each category with component-specific prompts and produces a file that a market surveillance authority can read and validate.

Self-service, consultancy and subscription — the three real options, compared honestly

Option 1 — Traditional compliance consultancies

€400–€2,000 per product · 1–3 weeks turnaround

You hand over your product data, wait one to three weeks, and receive a PDF. The quality is generally high, the price reflects professional liability and manual work, and the turnaround is incompatible with a Kickstarter fulfillment timeline where every week of delay has a real cost in backer communications.

Option 2 — Annual subscription platforms

€199–€600 per year · ongoing billing

Bundles the technical file with ongoing compliance features — updates when the regulation changes, a dashboard of SKUs, sometimes an EU Responsible Person service. Makes sense for a catalog publisher with dozens of active SKUs. For a first-time Kickstarter creator with one or three SKUs who will not be rebilled next year, an annual subscription is a structural mismatch with the one-off nature of the need.

Option 3 — Dedicated tabletop compliance services

Westwood Sourcing and similar · broader compliance bundle

Westwood Sourcing is one visible example in this slot, and RamGames publishes useful educational guides on the adjacent questions of CE marking and testing. These services offer the file as part of a broader bundle that often includes laboratory testing, documentation review and authorised representative services. For creators of games with components that genuinely need lab testing (children’s games under the Toy Safety Directive, games with electronic components under LVD or RED) this is the correct route. For adult tabletop games cleanly in the Article 9 scope, the lab testing component is not required and the bundle includes services you do not need.

Option 4 — GPSRCheck

€49 per SKU, one-time · 10 minutes · No subscription or renewal

A self-service generator built for a single specific purpose. The trade-off is honest: you do the work of filling in the guided form yourself with the data you already have from your manufacturing chain, and in exchange you keep 90% of what a consultant would charge, produce the file in a timeframe that fits a fulfillment wave, and retain the file on your own device without uploading anything to any cloud.

What the 6-page PDF actually contains

Product identification and economic operator data

Your game title, barcode or SKU identifier, the designer or studio as manufacturer, the non-EU manufacturer address on record, and the slot for the EU Responsible Person contact you contract separately.

Product description and intended use

Full component inventory (box, board, cards, tokens, miniatures, rulebook, dice, sleeves, trays, any physical extras from stretch goals), intended age group declared explicitly as 14 and above, intended conditions of use and storage.

3–4

Internal risk analysis under Article 9

Hazard identification across the categories relevant to adult tabletop components (small detachable parts, sharp card edges, choking for unintended young users, chemical composition of printed cardstock and plastic components, paint residues on miniatures, magnetic components if present, functional hazards during gameplay), severity-by-likelihood matrix, mitigation measures, residual risk statement.

EU Declaration of Conformity

Referencing Regulation (EU) 2023/988 Article 9 and ready to sign electronically by the creator or the studio legal representative.

Printable product label — two copies per A4 sheet

Mandatory GPSR information: manufacturer identity and address, EU Responsible Person contact, product identifier, age warning, traceability batch or print run code. Designed to be cut and affixed to the base game box and any expansion boxes.

Technical file and EU Responsible Person — two separate compliance layers most creators conflate

Many first-time Kickstarter creators hear about the GPSR through a single channel — a fulfillment partner email, a BackerKit update, a forum thread — and come away thinking there is one document to buy. There are two, and they come from two different providers.

● Layer 1 — Article 9 (GPSRCheck generates this)

The technical file

The internal risk analysis, the EU Declaration of Conformity and the mandatory label that travel with the physical product. Produced by the manufacturer — in a Kickstarter context, by you as the designer and brand owner of the campaign, not by the factory that printed the components. GPSRCheck generates this file in ten minutes for €49 per SKU. One license per SKU, no subscription. The PDF you download is permanent; 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 natural or legal person established in the EU who can be contacted by market surveillance authorities on your behalf. Several providers serve the tabletop ecosystem directly — Misfit Hobbies and RepGuardia Global are two visible names in the space — and generalist EU Responsible Person services typically charge between €150 and €300 per year. GPSRCheck does not provide this service; that contract is separate.

Both layers are required. Neither one on its own is enough.

Enforcement reality for Kickstarter creators shipping to EU backers

📅

1 April 2024 — Amazon begins enforcement

Amazon started suspending EU listings of non-EU sellers without a designated EU Responsible Person eight months before the official entry into force of the regulation. Non-Amazon channels have been following at their own pace: BackerKit has issued project updates to creators, and fulfillment partners with EU warehouses now ask for documentation before releasing pallets.

⚖️

13 December 2024 — Regulation (EU) 2023/988 enters into force

The regulation replaced the 2001 General Product Safety Directive across all 27 EU Member States. Customs at the major EU entry ports check paperwork on non-EU consignments and fulfillment partners have updated their contracts to require sight of the Article 9 technical file before releasing pallets.

⏳

Ten working days to produce the file on request

Market surveillance authorities have the power to require the technical file within a short deadline of typically ten working days, depending on the Member State. Failure to produce the file can result in withdrawal from the market and inclusion in the Safety Gate public database.

⚖️

No small-creator exemption

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 solo creator running a Kickstarter campaign carries the same documentary obligations as a publisher with a warehouse.

🔒

Financial penalties vary by Member State

In Germany, persistent infringements can carry fines of up to €100,000 or imprisonment of up to one year. Other Member States have comparable penalty regimes. Safety Gate listings are permanent and searchable by product and brand.

Traditional consultancy vs subscription platforms vs GPSRCheck

	Traditional consultancy	Annual subscription platforms	GPSRCheck
Price	€400–€2,000 per product	€199–€600 per year	€49 per product, one-time
Time to deliver	3–15 business days	Depends on onboarding	10 minutes
Renewal	None	Annual	No subscription · Permanent PDF · 30-day edit window
Legal basis	Varies by firm	Varies by platform	Article 9, Reg. (EU) 2023/988
Data handling	Uploaded to consultant	Uploaded to cloud	100% browser-side
Printable product label	Varies	Varies	Yes, two copies per sheet
Tabletop 14+ scoping	No	No	Explicit in the workflow

Multi-SKU campaign? Deluxe edition, expansion pack and base game each need their own file.

Shipping more than one SKU to EU backers? For multi-SKU campaigns and special pricing, visit solidwaretools.com or email hello@solidwaretools.com.

Commercial enquiries

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

Frequently asked questions

Is a self-produced technical file legally equivalent to one produced by a consultant?

Yes, in the sense the regulation cares about. Article 9 places the obligation to keep an internal technical file on the manufacturer and does not require the file to be drafted by a third party. What the regulation requires is that the file exist, be complete, be structured, be signed, be stored for ten years and be producible on request. A file you produce yourself with a structured tool is equivalent to one a consultant produces, provided the substance is the same. The economic argument for a consultant is that they bring methodology and liability insurance; the methodology is what GPSRCheck encodes into its guided form, and the liability sits with the manufacturer in both cases under EU law.

Do I need laboratory testing on top of the technical file for an adult tabletop game?

For an adult tabletop game in the Article 9 scope, no — lab testing is not a regulatory requirement. The risk analysis is based on the evidence you have from your manufacturing chain, which for tabletop components typically includes material safety data on plastics and resins, paint and ink composition information, and age-grading documentation. Lab testing becomes mandatory when the product falls under a sector-specific directive that requires it — toys under 14 (EN 71 tests), products with electronic components (LVD/EMC tests), PPE, medical devices. Adult tabletop games are outside all of those.

How often do I need to update the technical file after I produce it?

The file is valid as long as the product and the underlying regulations do not change. Material changes to the product — a new print run with different paper stock, a new plastic supplier for the miniatures, a redesigned component, a new expansion pack shipped to the same backers — trigger the need for an updated file. Changes to the regulation itself or to the harmonised standards referenced in the file also trigger updates. For a stable product in steady fulfillment, the file you generate at campaign close is the same file you hand a market surveillance authority two years later.

In what language do I have to keep the technical file?

English is accepted across the 27 EU Member States as a working language for technical documentation. Most market surveillance authorities will accept an English-language file without translation. The EU Declaration of Conformity and the printable label are different: those should be available in the language of the Member State where the product is placed on the market, or in a language the consumer reasonably understands. GPSRCheck generates the technical file in English by default and the declaration and label in the market language you select.

An authority has asked me for the file and given me a short deadline. Can I produce it and send it in time?

Typical market surveillance deadlines are around ten working days, depending on the Member State. GPSRCheck’s 10-minute production time leaves room for generating the file, reviewing it, signing it and emailing it well within any standard deadline. The limiting factor when an authority asks is usually not the production time but the gathering of component-level evidence from your manufacturing chain — supplier data sheets, paint composition declarations, age-grading documentation. Generating the file before an authority asks means that when they do ask, your only action is to forward the PDF.

I already have a Declaration of Conformity template I downloaded from a legal blog. Why can’t I just use that?

A Declaration of Conformity in isolation is not the technical file. The declaration references the technical file and states that the product complies on the basis of the analysis documented in that file. A downloaded template with no underlying risk analysis is a declaration without substance — it is legally incomplete and can be rejected by retailers, fulfillment partners or authorities who ask for the file itself. What GPSRCheck produces is both the technical file (the substance) and the declaration (the signable summary that references it), in a single 6-page PDF.

⚠️ Important notice: GPSRCheck generates the Article 9 technical file for adult tabletop games designed for ages 14 and above only. Games designed for children under 14 fall under the Toy Safety Directive 2009/48/EC and require a different compliance path. GPSRCheck does not provide the EU Responsible Person service under Article 16.

The GPSR technical file for your board game, generated in 10 minutes and kept on your own hard drive