Does the GPSR apply to software and digital products?
Does the GPSR apply to digital products? When apps and software count as products, when a firmware update is a substantial modification, and who answers.
Compliance gap assessment for your products
We check your products, documents and target markets against the rules that apply and show you what is missing. You get a written overview of gaps and priorities, so you know what to fix first.
You are not sure what is still missing
A launch, a new distributor or a marketplace review is coming up, or an authority has asked for documents. Your files should hold up, but nobody has checked them against every market you sell in. A check now shows the gaps while you can still close them.
What your products have to meet
An EU contact for each product
Consumer products and most CE-marked products need an economic operator established in the EU, named on the product, packaging, parcel or an accompanying document.
EU Authorized RepresentationDocuments that hold up
For CE-marked products, you draw up the technical documentation and the EU Declaration of Conformity. Other consumer products need technical documentation under the GPSR.
Product Compliance & DocumentationLabels and instructions per market
Under the GPSR, products carry a type, batch or serial number, your name, postal and electronic address, and instructions in the language each country sets.
Labels, Manuals & Product InformationRegistration for packaging and waste
Packaging, batteries and electrical equipment can require producer registration in each EU country where they are first supplied.
Packaging, EPR & Sustainability
What we do within the agreed scope
We work within the agreed scope and mandate: our report is not a certificate, and responsibility for your products and their Declaration of Conformity stays with you.
Talk to our teamProducts and markets mapped
We list your products and target markets and show which rules apply to each, in the EU and, where you sell there, the UK.
Documents reviewed
We review Declarations of Conformity, technical files, test reports and certificates, and note what is missing or out of date.
Labels and packaging checked
We check labels, packaging and instructions for the required details and languages in each target market.
EU contact and registrations checked
We check that each product has an EU economic operator and that your registrations for packaging, batteries and electrical equipment cover each market.
Gaps and priorities in writing
You get a written overview of gaps, ranked by priority. Where tests or certificates are missing, we can coordinate them with you.
What we need from you
- Product list with target markets
- Declarations of Conformity, where available
- Technical files and test reports
- Notified body certificates, if any
- Labels, packaging artwork and manuals
- Your sales channels and partners
How the assessment works
01
Agree the scope
In a first call, we go through your products, markets and sales channels and agree what we assess.
02
Share your documents
You send us your product list, technical files, labels and manuals.
03
Review against the rules
We check each product against the rules of your target markets and note every gap.
04
Report and next steps
You get the written overview, and we go through the priorities with you in a call.
Questions about the gap assessment
Is your report a certificate of conformity?
No. Our report documents the review of your products and files. It does not replace your Declaration of Conformity or any certificate a notified body must issue for your product.
Do CE-marked products also need GPSR technical documentation?
No. They need the technical documentation their own product act requires, usually together with an EU Declaration of Conformity. Article 9 GPSR does not apply to them (Article 2(1) GPSR).
What does the assessment cover?
Your products, their documents, labels and instructions, and the markets you sell in or plan to enter. We agree the exact scope with you before we start, for example your whole portfolio or one product line.
What happens after the assessment?
You decide what to do with the result. You can close the gaps yourself or with us: through our Compliance services for documents and labels, or our Representation services if you need an EU contact.
Insights on this topic
GPSR language requirements by EU country
GPSR language requirements by EU country: who sets the language, what national law demands in seven member states and what your online listing needs.
Find out where your products stand
Send us your product list, and we will tell you what an assessment would cover.
Get in touch with our team of experts
Tell us what you manufacture and where you want to sell. We identify the requirements for EU and UK market access and come back to you with the next steps.