What the authority’s request actually says, and what it actually wants
A market surveillance authority’s reasoned request for documentation under the GPSR typically includes: the product identifier (brand, model, SKU, EAN code if known), the reason for the request (consumer complaint, Safety Gate notification, routine inspection, follow-up to an earlier finding), the legal basis (Article 9 and Article 24 of Regulation (EU) 2023/988), the documents requested (technical file, Declaration of Conformity, test reports if any), and the response deadline.
The deadline is 10 calendar days in most cases, starting from the date of receipt of the request. In urgent cases — a product suspected of causing injury, a product being sold during a recall — the deadline can be shorter. The response must be complete on first delivery: partial responses do not restart the clock.
What the authority wants, specifically, is the document that proves you did the risk analysis the GPSR requires: hazards identified, severity and likelihood assessed, mitigation measures documented, residual risk stated. What they do not want is a marketing brochure, a factory inspection certificate, or an ISO 9001 quality management certificate — those are not substitutes for the Article 9 file.
The response, in practice: what to send, how to format it, how to deliver it
Format
A single PDF per product, structured in the order the regulation expects: product identification and traceability, product description and intended use, risk analysis, Declaration of Conformity, label. The GPSRCheck output is in exactly this order.
Language
The authority accepts English in almost all cases. Some authorities prefer their national language and will say so in the request — when in doubt, send the English file and offer to provide a translation of the Declaration page if needed.
Delivery
Usually by email to the contact address in the authority’s request letter, or through a designated compliance portal if the authority operates one. Your EU Responsible Person can deliver the response on your behalf, and in many cases must, because the Responsible Person is the legal intermediary under Article 16.
Cover note
A short email with: your brand name, the product identifier, the request reference number from the authority’s letter, confirmation that the attached file is the complete response, and the EU Responsible Person’s contact details. Do not add lengthy explanations or justifications — the authority wants the document, not a narrative.
What not to send
Do not send the raw files you have been given by the factory (test certificates, material safety data sheets, COA documents) as a substitute for the technical file. Those documents may be referenced inside the technical file as evidence, but the technical file itself is a separate structured document that the authority is asking for.
What happens if you miss the 10-day window
Formal non-compliance finding
The authority issues a formal finding recorded in the authority’s internal system and typically shared with other EU member state authorities through ICSMS (the Information and Communication System on Market Surveillance), which means the finding follows the product across all 27 EU markets.
Corrective action order
The authority orders corrective action, which can range from a mandatory warning to consumers, to withdrawal of the product from the market, to a full recall of units already sold. The scope depends on the assessed risk.
Administrative fine
Fines up to €100,000 per infraction in most member states, with Germany imposing up to one year of imprisonment for persistent violations and France allowing fines up to 10% of annual turnover.
Safety Gate listing
The product may be listed on Safety Gate, the EU’s public database of dangerous products. Safety Gate listings are permanent, searchable by brand and model, and create reputational damage that outlasts the fine.
The rational path is to respond within the window. Ten days is short but not impossibly so for a single product — the bottleneck is usually the inertia of starting, not the actual work.
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
The authority’s letter mentioned a 10-day deadline. Does that start from when they sent it or when I received it?
Can I ask for an extension?
The authority is asking about a product I stopped selling a year ago. Do I still need to respond?
My product is also CE-marked. Do I send the CE Declaration of Conformity or the GPSR file?
The request came through my EU Responsible Person. Do I respond directly to the authority or through them?
What if I do not have the file yet — is generating one now too late?
⚠️ 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.