What the Article 9 file looks like for a finished leather SKU — the hazard categories specific to leather
An Article 9 technical file for a finished leather product — let us say a full-grain vegetable-tanned leather belt manufactured in Kanpur for a German boutique brand — walks through the hazard categories that matter for leather specifically, which are a subset of the general GPSR hazard framework with additional chemical emphasis specific to the material.
Chemical hazards under REACH
Chromium VI (primary concern for chrome-tanned leather, restricted under REACH Annex XVII), azo dyes that can release certain aromatic amines, formaldehyde and hide preservatives, nickel release on metal trims (buckles, zips, rivets) when in prolonged contact with skin, phthalates in any plasticised component. The risk analysis identifies each hazard category and references your test reports from SGS, Bureau Veritas, Intertek or local accredited labs as evidence of compliance with REACH limits.
Physical and mechanical hazards
Sharp metal edges on buckles or rivets, small detachable parts that could create choking risk, the strength of attachment points for straps and handles (to prevent sudden breakage during use), colour transfer to skin and clothing from dye fastness issues. Mitigation includes design review, quality control of incoming metal hardware, fastness testing and buyer-side pre-shipment inspection.
Traceability and labelling
Leather goods need manufacturer identity, batch code, and the EU Responsible Person contact on the hang tag or sewn-in label. For leather specifically, the leather type declaration (full-grain, top-grain, split, bonded) applies under consumer protection frameworks in some Member States (in France, the Décret n° 2010-29 on leather labelling) which applies in parallel to the GPSR labelling requirements. GPSRCheck’s guided form prompts you through each of these categories.
Honest note on the EU Deforestation Regulation (EUDR) — a second compliance layer arriving from June 2027 for leather of bovine origin
Two separate compliance layers: GPSR for product safety, EUDR for supply chain sustainability
Regulation (EU) 2023/1115 on deforestation-free products — the EUDR — introduces additional traceability obligations for products containing cattle, among other commodities. For cattle leather specifically, the EUDR requires that the bovine hide used in the finished leather product can be traced back to the farm of origin with geolocation coordinates, and that the farm is proven not to be on land deforested after 31 December 2020. The EUDR applies to large operators from 30 December 2025 and to small and medium-sized enterprises from 30 June 2027.
What this means for an Indian leather exporter shipping finished bovine leather goods to Europe: from 30 June 2027 onwards (SME date), in addition to the GPSR Article 9 technical file, you will need an EUDR due diligence statement and the underlying traceability documentation proving the geolocation of the bovine farm. These are two separate compliance layers covering two different regulatory objectives — GPSR covers product safety, EUDR covers supply chain sustainability and deforestation.
GPSRCheck generates the GPSR Article 9 file. GPSRCheck does not generate EUDR due diligence statements. If your buyer is already asking for EUDR preparation alongside GPSR, treat them as two separate workstreams: resolve the GPSR with GPSRCheck today at €49 per SKU, and plan the EUDR preparation with your traceability team and your hide suppliers through 2026. Leather goods made from non-bovine leather (ovine, caprine, reptile, exotic) are outside the EUDR’s cattle scope and only need the GPSR file.
What the 6-page PDF actually contains, for an Indian exporter serving European buyers
Product identification and economic operator data
The style number, SKU identifier or tech pack reference 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, and the slot for the EU Responsible Person contact — which may be the European importer acting as importer of record, or a dedicated EU Responsible Person provider.
Product description and intended use
Full composition inventory (fibre blend or leather type with tanning method, lining, trims, hardware, dyes, prints, finishes), intended use and target consumer, declared age range if relevant, conditions of use and care instructions.
Internal risk analysis under Article 9
Hazard identification across the categories relevant to non-harmonised consumer products (chemical composition under REACH for textiles and leather, azo dyes, nickel release on metal trims, chromium VI for leather, mechanical hazards, flammability for textile categories, choking and strangulation risks where drawstrings or cords are involved), severity-by-likelihood matrix per hazard, 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. This is the document your European buyer’s legal team 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 and attached to the hang tag, sewn into a care label, or affixed to the master carton.
The specific document your European buyer is asking about
When a European buyer’s legal counsel asks for “GPSR documentation” they are asking for a structured internal risk analysis under Article 9 of Regulation (EU) 2023/988, the EU Declaration of Conformity that references it, and confirmation of a designated EU Responsible Person 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 summary, not a certificate of origin, not an ISO 9001 statement. These adjacent documents may already be in your buyer’s tech pack and they do not replace the Article 9 file.
Under Article 2 of Regulation (EU) 2023/988, for products covered by Union harmonisation legislation (LVD, EMC, RED, Cosmetics Regulation, Toy Safety Directive, Medical Device Regulation, Machinery Regulation and similar sector-specific acts) the GPSR Chapter II does not apply to the risks covered by that harmonisation legislation — but for non-harmonised consumer products such as textiles, leather goods, bags, footwear (non-PPE), fashion accessories, home decoration, ceramics, wooden furniture, stationery and most handicrafts, the Article 9 file is the primary compliance document the buyer’s legal team is asking for. GPSRCheck generates it.
What it does not generate — and what no compliance tool on the market generates legitimately — is a “GPSR certification”, because the regulation does not establish a certification scheme. Any vendor selling you a “GPSR certificate” is using terminology that does not match the text of the Regulation. What exists is the technical file, the declaration and the Responsible Person designation. That is the package your buyer needs.
Technical file and EU Responsible Person are two separate compliance layers — and many Indian exporters already have the second one resolved through their European buyer
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 after the last unit is placed on the market (Article 9.4). GPSRCheck produces this in ten minutes at €49 per SKU.
The EU Responsible Person
A natural or legal person established in the EU who acts as the contact point for market surveillance authorities. For Indian exporters selling B2B to a European buyer who is the importer of record, the buyer is already the Responsible Person by operation of law — no separate contract needed. For direct B2C export (Amazon EU, own Shopify, Etsy), a separate AR provider is needed: ecinternational.co.in, Veteran Group, EaseCert, Euverify, gpsrcompliant.eu at €150–500 per year.
GPSRCheck deliberately does not bundle the Responsible Person service into its €49 fee, because many Indian 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 one document only the manufacturer can produce, and lets you choose whatever Responsible Person arrangement fits the commercial structure of each buyer relationship.
Enforcement reality for Indian 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 Rotterdam, Hamburg, Antwerp, Valencia, Piraeus and Gdańsk intensified documentation checks on non-EU consignments of consumer products.
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 of the product 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. An Indian exporter with a manufacturing unit of thirty workers carries the same documentary obligations as a large manufacturing group.
For Indian exporters with B2B buyer relationships, the most common enforcement pathway is commercial, not regulatory: the European buyer’s legal department adds the Article 9 file to the supplier qualification process. Suppliers who produce the file continue receiving POs. Suppliers who cannot get suspended from the vendor list and replaced. The €49 file restores the relationship; the alternative is permanent displacement.
Consultancy, subscription platforms, bundled enterprise services and GPSRCheck
| Traditional consultancy | Annual subscription platforms | Bundled enterprise (EaseCert) | GPSRCheck | |
|---|---|---|---|---|
| Indicative price | €400–2,000 per product | €199–500 per year | €400–500 one-time per product | €49 per SKU, one-time |
| Payment model | Invoiced per engagement | Annual subscription | One payment per product | One payment per SKU, pay with card |
| EU Responsible Person | No | Yes, bundled | Yes, bundled | No — contract separately, choose freely |
| Time to deliver | 1–3 weeks | 24–48 h after onboarding | 3–5 business days | 10 minutes |
| Data handling | Uploaded to consultant | Cloud storage on vendor servers | Cloud storage on vendor servers | 100% browser-side |
| Per-SKU cost at 20 SKUs | €8,000–€40,000 | €199–500 + per-SKU surcharges | €8,000–€10,000 | €980 (20 × €49) |
Prices for competitor services 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
Our tannery is IULTCS-compliant and we have SGS test reports on chromium VI under the REACH limit. Is that enough for the GPSR file?
We produce bags in full-grain cattle leather for a German brand that is already asking us about EUDR preparation. Does GPSRCheck cover EUDR?
We produce small leather goods (wallets, card holders, keyrings) where the leather content is small. Does Article 9 still apply?
We also make leather gloves. Are they covered by GPSR or by PPE?
Leather footwear — covered or not?
Our buyer is asking for a chromium VI test report attached to the GPSR file. Do we need to test every batch?
⚠️ Important notice: GPSRCheck generates the Article 9 technical file for non-harmonised consumer products only. Products under Union harmonisation legislation (Toy Safety Directive, Cosmetics Regulation, LVD, EMC, RED, MDR, Machinery Regulation, PPE Regulation) require different documentation. GPSRCheck does not provide the EU Responsible Person service under Article 16.