Does GPSR apply to small businesses and sole traders?
Yes. Regulation (EU) 2023/988 contains no size threshold, minimum turnover, or volume of sales below which compliance is not required. The Commission's Guidelines C(2025) 7699 — published on 19 November 2025 — are explicit on this point: the GPSR's obligations are relevant for businesses of all sizes. A sole trader who sells ten handmade items per month to EU buyers through Etsy or their own website is subject to the same fundamental legal framework as a corporation that ships millions of units annually. The regulation is designed to protect consumers — and consumers can be harmed by unsafe products regardless of the size of the company that made them.
What the Guidelines C(2025) 7699 do acknowledge is the principle of proportionality in the documentation itself. The technical file must be sufficient to demonstrate that the product is safe, but its depth and detail should be proportional to the nature and risk level of the product. A low-risk product — a simple ceramic mug with no moving parts, no electrical components, and no potential choking hazards — requires a shorter and less elaborate technical file than a children's ride-on toy with electric motors and lithium batteries. Proportionality reduces the paperwork burden for simple products but does not eliminate the obligation: every in-scope product, however simple, needs a documented risk assessment, a technical file, and correct labelling.
For EU-based sole traders, the practical starting point is straightforward. You act as your own Responsible Person automatically — you don't need to hire or designate a separate service. You need to ensure your name, postal address, and email address appear on your product or its packaging; conduct and document a risk assessment proportionate to your product's risk level; compile a technical file you can produce on request; and include safety information in the language of each EU country where your buyers are located. The cost of achieving this with GPSRCheck is €49 per product — a fraction of what a traditional compliance consultancy charges and a small investment against the €100,000 fine that non-compliance can attract.
What the law says
Commission Guidelines C(2025) 7699 (19 November 2025): «The obligations of the GPSR are relevant for businesses of all sizes.» Article 9 of Regulation (EU) 2023/988 sets no size or volume threshold for the obligation to compile technical documentation. Article 16 requires an EU Responsible Person for every product — again, with no SME exemption.
Consequences of non-compliance
A sole trader without a technical file faces the same range of penalties as a corporation: fines of up to €100,000 per Member State, listing removal on Amazon and Etsy, and civil liability for product-related harm. The business structure — sole trader, partnership, limited company — does not affect the legal exposure.
GPSRCheck was built for independent sellers and small businesses — the complete GPSR technical file at a price that makes sense. €49 per product versus €400–2,000 from compliance consultancies. No subscription.
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