GPSR Checklist & Software Guide: 13 Checks (2026)
A GPSR compliance checklist should connect each legal duty to one product, an accountable economic operator and retained evidence. The 13 checks below cover scope, risk assessment, technical documentation, the EU responsible economic operator, traceability, online offers, complaints, accidents and recalls under the EU General Product Safety Regulation (GPSR).
Is there an official GPSR checklist template?
There is no official universal GPSR checklist or file template for every consumer product. The GPSR defines legal duties, but the evidence depends on the product, its risks, the economic operators in the supply chain and any product-specific EU legislation.
The table below is a practical GPSR checklist example. It does not certify a product, so adapt it to each product. The exact legal basis for each check is in the sources table at the end of this page.
What should a GPSR compliance checklist cover?
| Check | Evidence to retain |
|---|---|
| 1. Confirm scope and applicable product law | Product category, intended use, exclusions and applicable sector rules |
| 2. Complete the internal risk assessment | Identified hazards, assessed risks and mitigation decisions |
| 3. Draw up technical documentation | Product description, safety-relevant characteristics and applicable supporting evidence |
| 4. Identify the EU responsible economic operator | EU manufacturer, importer, mandated authorised representative or, if none exists, fulfilment service provider |
| 5. Add a product identifier | Type, batch, serial number or another visible and legible identifier |
| 6. Add manufacturer contact details | Name or trade mark plus postal and electronic address |
| 7. Confirm the EU Responsible Person's details | Name or trade mark plus postal and electronic address on a permitted physical location |
| 8. Provide instructions and safety information where required | Consumer-facing content in a language consumers can easily understand |
| 9. Check every online or distance-sale offer | Manufacturer, Responsible Person where required, product identity, picture, warnings and safety information |
| 10. Keep product-safety controls current | Version history, serial-production controls and current technical documentation |
| 11. Open and monitor consumer communication channels | Public contact route and complaint, accident, recall and corrective-action records |
| 12. Prepare accident and dangerous-product reporting | Safety Business Gateway access, internal escalation and corrective-action records |
| 13. Prepare recall communication and remedies | Consumer contact data, compliant recall notice and remedy process |
What does GPSR compliance software do?
GPSR compliance software is useful for workflow and evidence control. It can assign records to products, flag missing fields, maintain version history and export data. It cannot decide that a product is safe, create missing test evidence, accept an EU Responsible Person mandate or guarantee marketplace approval. Under the GPSR, the manufacturer stays responsible for the product-specific risk analysis and technical documentation.
GPSR software or consultant: which do you need?
| Need | GPSR software can support | Human or legal decision still required |
|---|---|---|
| Product inventory and supply-chain roles | Store product records, assignments, dates and reminders | Decide which legislation applies and which economic operator route is valid |
| Risk assessment | Provide forms, hazard libraries, task ownership and version control | Identify the product's actual hazards, choose controls and approve the evidence |
| Technical documentation | Link files to products, check required fields and create exports | Decide whether the evidence and testing are adequate; keep the file current for 10 years |
| Labels and online offers | Check fields and maintain language or marketplace versions | Approve product-specific warnings, language, placement and the final listing |
| EU responsible economic operator | Store contact data, covered products and a mandate record | An EU economic operator must actually accept the role and perform the applicable tasks |
| Incidents and recalls | Open cases, preserve an audit trail and prepare contact exports | Assess danger, choose corrective action and make required authority or consumer notifications |
Choose GPSR software when the product evidence is already reliable and a larger catalogue needs repeatable record control. Choose a consultant when product scope, hazards, applicable legislation or evidence quality is unclear. A business may need both when a large catalogue also contains safety-relevant product differences. For a few product families, a product-level review can establish the evidence model before a recurring software subscription is chosen.
What should you check before choosing GPSR software?
| Acceptance test | Evidence to request from the software provider | Warning sign |
|---|---|---|
| Legal-scope mapping | Dated rules, source links and a documented manual override | One universal GPSR template for every product |
| Product-family and SKU control | Version history and rules for separating safety-relevant variants | Every SKU is cloned without a material, warning or design-change check |
| Evidence access | A complete, readable export with file links and audit history | Compliance evidence exists only inside the provider dashboard |
| EU Responsible Person role | Separate legal identity, covered products, tasks and written mandate where applicable | A database entry is presented as appointment of an EU Responsible Person |
| Marketplace workflow | Field mapping, change log and post-submission verification | Guaranteed Amazon, Etsy or other marketplace approval |
| Security and accountability | Role-based access, backups, processing terms and an audit log | AI-generated output is treated as the final compliance decision |
1. Is the product within GPSR scope?
Record the product, its intended use, its reasonably foreseeable use and the business placing it on the EU market or making it available there. The GPSR scope rules list exclusions and explain how the GPSR works alongside specific EU harmonisation legislation. Include product-specific rules wherever they cover the same product or risk.
2. Has the manufacturer completed an internal risk assessment?
Before placing the product on the market, the manufacturer must carry out an internal risk analysis. It should cover the safety aspects the GPSR lists, the intended and reasonably foreseeable use, relevant consumer groups, interactions with other products and the solutions chosen to remove or reduce the identified risks.
Use the GPSR risk assessment guide to connect hazards, risk levels and controls to the exact product.
3. Is the GPSR technical documentation complete and current?
At a minimum, the technical documentation must contain a general product description and the essential characteristics relevant to assessing safety. Where the possible risks call for it, it also includes the risk analysis, the mitigation solutions, test evidence and the standards or other safety elements applied.
As the manufacturer, you must keep the technical documentation up to date and available to authorities for 10 years after the product is placed on the market. The GPSR technical documentation guide explains the product-level file structure.
4. Who is the EU responsible economic operator?
The GPSR does not require every non-EU manufacturer to buy a separate service. It requires an economic operator established in the EU to be responsible for the product and to carry out the tasks set by the EU market surveillance rules. This can be an EU manufacturer, an importer, an authorised representative with an appropriate written mandate or, where none of those exists, an EU fulfilment service provider.
Where a written mandate is the right route, a Germany-based EU Responsible Person service can cover the agreed products and tasks. The mandate does not remove the manufacturer's own GPSR duties.
5-8. Are product identity, contact details and safety information correctly placed?
Different GPSR information has different placement rules:
- The product identifier belongs on the product; only the product's size or nature can justify moving it to the packaging or an accompanying document.
- Manufacturer and importer details belong on the product; they may move to the packaging or an accompanying document where product placement is not possible.
- The EU responsible economic operator's details may appear on the product, packaging, parcel or an accompanying document.
- Required instructions and safety information must accompany the product in a language consumers can easily understand, as determined by the target Member State.
The GPSR labelling requirements guide provides the full placement table.
9. Does every online offer show the required information?
For an online or other distance-sale offer, the GPSR requires the manufacturer's name or trade name, postal address and electronic address. If the manufacturer is outside the EU, the offer must also show the EU Responsible Person's name, postal address and electronic address.
The offer must identify the product with a picture, its type and another product identifier. It must also show applicable warnings or safety information in a language consumers understand. See the GPSR online sales information guide.
10-11. Are safety controls and complaint channels operating after launch?
GPSR compliance continues after the first sale. Manufacturers must keep technical documentation current, maintain procedures for serial-production safety, publish consumer communication channels and investigate complaints or accident information that may concern a dangerous product.
Link complaint, recall and corrective-action records to the affected product identifier and document version.
12. Can the business report an accident or dangerous product?
The manufacturer must notify a product-safety accident through the Safety Business Gateway without undue delay after learning of it. When a product is dangerous, the manufacturer must take effective corrective measures, inform affected consumers and notify the authorities in the Member States where the product was made available.
Your internal procedure should say who evaluates the event, who can access the Safety Business Gateway and how the affected product, countries and corrective measures are recorded.
13. Is the recall process ready before an incident?
A recall process should identify affected consumers, produce a recall notice in the form the GPSR requires and provide the remedies it requires. The remedy must be effective, cost-free and timely. Under the conditions the GPSR sets, consumers can choose between at least two of these: repair, replacement or an adequate refund.
Frequently asked questions about the GPSR compliance checklist
Is there an official GPSR checklist template?
No. The GPSR defines duties, but it does not publish one universal checklist or file template for every product. A usable checklist links the product, its risks, the supply-chain roles and all applicable product-specific EU laws to evidence.
Can GPSR compliance software prove a product is safe?
No. Software can organise product records, version control and missing-data checks, but it cannot replace the manufacturer's product-specific risk assessment, technical evidence or legal decisions. The manufacturer and the relevant economic operators remain responsible for their GPSR duties.
Does every product need independent laboratory testing?
No. The GPSR mentions test reports where they are appropriate for the product's possible risks. It does not require independent laboratory testing for every product. Product-specific EU laws can add separate testing or conformity-assessment duties.
Does every GPSR product need an EU Declaration of Conformity?
No. GPSR does not create a general EU Declaration of Conformity requirement for every consumer product. You need a declaration only when the product-specific EU law that applies to your product requires it.
Can one GPSR checklist cover every SKU?
Only when the same evidence genuinely covers the product design, intended users and safety-relevant characteristics. If you change materials, warnings, electronics, intended use or another risk factor, check and document whether the existing assessment still applies.
How does Grüner Baum GmbH help?
Grüner Baum GmbH's GPSR compliance service reviews the product-level evidence behind this checklist. The linked service is human-reviewed support, not an automated software certificate. We support manufacturers with risk assessment, technical documentation, labelling and online-offer checks. Where a written mandate is the right route, we also act as EU Responsible Person from Germany.
You can send the product category, manufacturer location, target EU markets and current records through our assessment request form.
Official sources
| Topic | Legal basis | Official text |
|---|---|---|
| Check 1: scope, exclusions and the general safety requirement | GPSR, Articles 2 and 5 | Regulation (EU) 2023/988 — consolidated GPSR text of 29 May 2026 |
| Check 2: internal risk analysis and the safety aspects to assess | GPSR, Articles 6 and 9(2) | Consolidated GPSR text |
| Check 3: technical documentation, test reports where appropriate, 10-year retention | GPSR, Article 9(2) and (3) | Consolidated GPSR text |
| Check 4: EU responsible economic operator | GPSR, Article 16 | Consolidated GPSR text |
| Check 4: tasks of the EU responsible economic operator | Regulation (EU) 2019/1020, Article 4(3) | Regulation (EU) 2019/1020 — consolidated text of 12 August 2026, including Article 4 |
| Check 5: product identifier and where it goes | GPSR, Article 9(5) | Consolidated GPSR text |
| Check 6: manufacturer contact details (importer details follow the same placement rule) | GPSR, Article 9(6); for importers, Article 11(3) | Consolidated GPSR text |
| Check 7: EU Responsible Person's details on the product, packaging, parcel or document | GPSR, Article 16(3) | Consolidated GPSR text |
| Check 8: instructions and safety information in the consumer's language | GPSR, Article 9(7) | Consolidated GPSR text |
| Check 9: information in online and distance-sale offers | GPSR, Article 19 | Consolidated GPSR text |
| Check 10: up-to-date file and serial-production controls | GPSR, Article 9(3) and (4) | Consolidated GPSR text |
| Check 11: communication channels and complaint handling | GPSR, Article 9(11) to (13) | Consolidated GPSR text |
| Check 12: accident notification and dangerous products | GPSR, Articles 9(8) and 20 | Consolidated GPSR text |
| Check 13: recall information, recall notice and remedies | GPSR, Articles 35, 36 (recall notice) and 37 (remedies) | Consolidated GPSR text |
| How the Commission applies the GPSR in practice | European Commission guidelines, C/2025/6233 | European Commission guidelines on applying the EU general product safety framework |
| Product safety overview for businesses | European Commission portal (information, not law) | European Commission product safety portal |
This checklist is general information, not legal advice; the exact requirements depend on your product, its risks, the supply-chain roles and all applicable laws.
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