GPSR Checklist & Software Guide: 13 Checks (2026)
As of 1 September 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 Regulation (EU) 2023/988.
What changed in this GPSR checklist?
- September 2026: Corrected the rules on independent testing, EU Declarations of Conformity and physical information placement.
- September 2026: Added direct answers for GPSR template, example and software searches, plus Article 19 online-offer checks.
- September 2026: Added software-versus-consultant decision and vendor acceptance tables; updated Regulation (EU) 2019/1020 to its 12 August 2026 consolidated version.
Is there an official GPSR checklist template?
There is no official universal GPSR checklist or file template for every consumer product. Regulation (EU) 2023/988 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 and should be adapted at product level.
What should a GPSR compliance checklist cover?
| Check | Evidence to retain | Primary legal reference |
|---|---|---|
| 1. Confirm scope and applicable product law | Product category, intended use, exclusions and applicable sector rules | GPSR Articles 2 and 5 |
| 2. Complete the internal risk assessment | Identified hazards, assessed risks and mitigation decisions | GPSR Articles 6 and 9(2) |
| 3. Draw up technical documentation | Product description, safety-relevant characteristics and applicable supporting evidence | GPSR Article 9(2)-(3) |
| 4. Identify the EU responsible economic operator | EU manufacturer, importer, mandated authorised representative or, if none exists, fulfilment service provider | GPSR Article 16; Regulation (EU) 2019/1020 Article 4 |
| 5. Add a product identifier | Type, batch, serial number or another visible and legible identifier | GPSR Article 9(5) |
| 6. Add manufacturer contact details | Name or trade mark plus postal and electronic address | GPSR Article 9(6) |
| 7. Confirm the Article 16 operator details | Name or trade mark plus postal and electronic address on a permitted physical location | GPSR Article 16(3) |
| 8. Provide instructions and safety information where required | Consumer-facing content in a language consumers can easily understand | GPSR Article 9(7) |
| 9. Check every online or distance-sale offer | Manufacturer, Responsible Person where required, product identity, picture, warnings and safety information | GPSR Article 19 |
| 10. Keep product-safety controls current | Version history, serial-production controls and current technical documentation | GPSR Article 9(3)-(4) |
| 11. Open and monitor consumer communication channels | Public contact route and complaint, accident, recall and corrective-action records | GPSR Article 9(11)-(13) |
| 12. Prepare accident and dangerous-product reporting | Safety Business Gateway access, internal escalation and corrective-action records | GPSR Articles 9(8) and 20 |
| 13. Prepare recall communication and remedies | Consumer contact data, compliant recall notice and remedy process | GPSR Articles 35-37 |
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 Article 16 mandate or guarantee marketplace approval. Under GPSR Article 9, the manufacturer remains 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 |
| Article 16 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 |
| Article 16 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, intended use, reasonably foreseeable use and the actor placing or making it available on the EU market. GPSR Article 2 lists exclusions and explains how GPSR interacts with specific EU harmonisation legislation. Product-specific rules must be included where they cover the same product or risk.
2. Has the manufacturer completed an internal risk assessment?
GPSR Article 9(2) requires the manufacturer to perform an internal risk analysis before placing the product on the market. The assessment should address the safety characteristics in Article 6, the intended and reasonably foreseeable use, relevant consumer groups, interactions with other products and the solutions chosen to remove or reduce 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?
GPSR Article 9(2) requires at least a general product description and the essential characteristics relevant to assessing safety. Where appropriate for the possible risks, the technical documentation also includes the risk analysis, mitigation solutions, test evidence and the standards or other safety elements applied.
The manufacturer must keep the technical documentation current 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?
GPSR Article 16 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 Article 4(3) tasks for the product. The route can be an EU manufacturer, importer, authorised representative with an appropriate written mandate or, where none of those exists, an EU fulfilment service provider.
Where a written mandate is the correct 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 Article 16 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 Article 19 information?
GPSR Article 19 requires an online or other distance-sale offer to show 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 Article 16 Responsible Person's name, postal address and electronic address.
The offer must identify the product with a picture, type and another product identifier and display applicable warnings or safety information in the consumer-understood language. 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.
Complaint, recall and corrective-action records should connect 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.
The internal procedure should identify 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 the Article 36 recall notice and provide the remedies required by Article 37. The remedy must be effective, cost-free and timely. Subject to Article 37's conditions, consumers receive a choice between at least two of repair, replacement or an adequate refund.
Frequently asked questions about the GPSR compliance checklist
Is there an official GPSR checklist template?
No. Regulation (EU) 2023/988 defines duties, but it does not publish one universal checklist or file template for every product. A usable checklist must map the product, its risks, the supply-chain roles and all applicable product-specific EU legislation 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. GPSR Article 9(2) refers to test reports where appropriate for the product's possible risks; it does not impose independent laboratory testing on every product. Product-specific EU legislation may create 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. A declaration is required when the product-specific EU legislation applicable to that 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. A change to materials, warnings, electronics, intended use or another risk factor requires a documented check of 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 and, where a written mandate is the appropriate Article 16 route, EU Responsible Person services from Germany.
You can send the product category, manufacturer location, target EU markets and current records through our assessment request form.
Official sources
- Regulation (EU) 2023/988 — consolidated GPSR text of 29 May 2026
- European Commission guidelines on applying the EU general product safety framework
- Regulation (EU) 2019/1020 — consolidated text of 12 August 2026, including Article 4
- European Commission product safety portal
This checklist provides general information. The exact requirements depend on the product, its risks, the supply-chain roles and all applicable legislation.
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