GPSR documentation for selling in Czechia
A GPSR documentation review should connect the exact product, safety evidence and information seen by the Czech customer. Identify missing evidence before launch and keep the manufacturer's technical duties separate from an advisory review.
Before selling a consumer product in Czechia, establish which safety rules apply, your role in the supply chain and whether the evidence actually describes the model being sold. A useful GPSR documentation review connects the product, risk analysis, supplier records, labels, Czech safety information and online offer. A folder of unrelated certificates does not make that connection.
The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024. It is relevant to foreign manufacturers, importers, distributors and online sellers, but their duties differ. Its scope is consumer products, including products reasonably likely to be used by consumers even if that was not the original intention. It is not a blanket regime for every exclusively professional B2B product. GPSR Articles 1–3 and 52
Kodo provides GPSR advice and documentation support for the Czech market. We do not act as a GPSR authorised representative or EU responsible person. Our service reviews and organises the agreed evidence; technical safety assessment, testing and any required legal appointment remain separate work.
Decide which rules apply before requesting documents
Begin with the actual product, intended users and reasonably foreseeable use. Record the model, variants, materials, functions, supply route and intended Czech sales channels.
GPSR has exclusions, including food, medicines and certain other categories. For products covered by specific EU safety legislation, it operates alongside that legislation according to Article 2. In particular, do not automatically apply all the GPSR manufacturer documentation duties to harmonised products: Article 2 excludes specified chapters and provisions, while other GPSR rules, including distance-sales requirements, can remain relevant.
A furniture supplier, toy importer and electrical-equipment seller therefore need different document requests. The Czech Ministry of Industry and Trade's GPSR guidance, especially question 3 explains this relationship; the binding scope rules are in GPSR Article 2.
For older stock, record when it was first placed on the EU market. Article 51 protects continued availability of products covered by the previous General Product Safety Directive that complied with it and were placed on the market before 13 December 2024. This is a product-specific transition, not an exemption for every new unit of an older model. GPSR transitional provision
Do not treat “B2B only” as sufficient evidence of exclusion. A household-type product supplied to a hotel or business can still involve consumer use. Conversely, a genuinely professional product with no reasonably foreseeable consumer use should not be labelled subject to GPSR merely because it is sold online. Document the assessment and resolve uncertain cases with appropriate expertise.
Identify the manufacturer, importer and distributor
The name on the supplier invoice does not always settle the role.
| Role | Core question for the documentation review |
|---|---|
| Manufacturer | Who makes or commissions the product and markets it under their name or trademark? |
| Own-brand seller | Does selling under your own name make you the manufacturer for the applicable duties? |
| EU importer | Who first places the product from a third country on the EU market? |
| Distributor | Who supplies it further, and which checks must they perform before doing so? |
| EU responsible person | Which eligible EU-established operator carries the relevant legal tasks? |
GPSR Articles 9–13 distinguish these duties. For example, where Article 9 applies, the manufacturer prepares the internal risk analysis and technical documentation. Article 11 requires the importer to check the manufacturer's specified obligations and retain a copy of the technical documentation. A distributor has its own verification and corrective-action duties under Article 12. Own-brand marketing or a substantial modification can change the role under Article 13. Economic-operator obligations
Identify the EU responsible-person arrangement separately, especially for a non-EU manufacturer. Article 16 requires an EU-established economic operator for the specified tasks; it does not mean every company must buy an external authorised representative. Check the applicable route and the actual operator before putting contact details on a label or listing.
An EPR or WEEE appointment does not establish that GPSR role. Kodo's details must not be used as the product's GPSR responsible person on the basis of a documentation review.
Build a file for the exact model and version
A practical file should make the connection between physical product and evidence easy to follow.
| File element | What to check |
|---|---|
| Product identity | Model, variants, photographs, batch or serial identification and supplier |
| Description and specification | Construction, materials, intended use, limitations and relevant characteristics |
| Applicable-rules assessment | GPSR scope, sector legislation and the basis for decisions |
| Risk-analysis evidence | Product-specific hazards, measures and supporting information, where required |
| Test reports and standards | Correct model, tested configuration, scope, dates and any limitations |
| Labels and packaging photographs | Actual identification, economic-operator details and relevant warnings |
| Instructions and safety information | Current version, relevant language and consistency with the product |
| Online offers | The information visible before purchase on each channel |
| Changes and follow-up | What changed, what needs review and who confirms it |
This table is a working structure, not a claim that every listed document is mandatory for every product. The applicable law and the risks determine what evidence is required.
For a large catalogue, separate commercial variants from technically different models. Colour alone may not change the safety evidence, while a different mechanism, material or intended user can. If one assessment covers a family, record the basis and its limits.
Ask suppliers specific questions. “Please send your GPSR certificate” often produces an unrelated document. A better request identifies the model, asks for the applicable risk and technical records, confirms the tested configuration and requests current label and instruction versions.
Understand what a risk analysis must achieve
Where GPSR Article 9 applies, the manufacturer must carry out an internal risk analysis before placing the product on the market and prepare technical documentation. The documentation must include a product description and safety-relevant characteristics, with further analysis, adopted solutions, test evidence and standards information as appropriate to the risks. Article 9(2)
Article 6 requires attention to factors such as design, composition, interactions with other products, instructions, presentation, foreseeable use and vulnerable users. A copied statement that a product is “low risk” does not explain how those factors were considered.
An illustrative example is a freestanding storage cabinet marketed for homes. A review might identify the need to examine stability, accessible edges, assembly and foreseeable interaction with children. The reviewer can then ask whether the supplier's assessment, tests and instructions address those points for the actual model.
| Illustrative finding | Evidence or action needed |
|---|---|
| Supplied report identifies a different cabinet size | Establish whether it covers the marketed model and obtain supporting evidence |
| Assembly instructions refer to anchoring parts absent from the supplied kit | Confirm the product configuration and resolve the inconsistency |
| Czech text omits a safety instruction present in the approved source | Prepare and approve a corrected translation |
These are possible review findings, not technical conclusions that a particular cabinet is safe or unsafe. An unresolved safety question requires competent assessment; adding a warning or translating a manual cannot substitute for resolving an unsafe design.
Kodo can organise the inputs, identify missing evidence and prepare questions for the manufacturer. Developing or approving a technical risk assessment, quantitative risk calculations or testing requires a separately accepted scope and suitable expertise. It is not included automatically in a documentation review.
Match physical information with the online offer
For distance sales, Article 19 requires the offer to show clearly and visibly the manufacturer's identity and postal and electronic contact details, the relevant EU responsible-person details when the manufacturer is outside the EU, product identification including an image, and the required warning or safety information. GPSR Article 19
Check the live product page and marketplace offer, not just the administration form. Review desktop and mobile layouts and each variant. Required information should not disappear when a customer selects a different size or when a marketplace feed overwrites the description.
Physical marking and accompanying-document requirements need their own check against the relevant provisions. Online publication alone is not a substitute for everything required with the product. GPSR Article 21 permits additional digital information; it should not be read as a universal permission to replace required physical information with a QR code.
Compare the exact names, addresses, identifiers and warnings across the product, packaging, instructions, technical file and online listing. Record the source and approval of each proposed correction. Do not invent an EU contact or replace a model identifier merely to satisfy a marketplace field.
Prepare the Czech information that is actually required
In the Czech Republic, Section 8 of Act No. 387/2024 Coll. requires Czech instructions and safety information under the relevant GPSR provisions, and Czech warnings and safety information in distance-sales offers. Official Czech language requirements
Where the regulation permits safe use without instructions and safety information, assess that exception for the product; do not assume every simple-looking item qualifies. Translate confirmed source material and preserve its safety meaning. Have technical content checked by the manufacturer or appropriate specialist where needed.
The customer-facing language duty does not mean that every supplier document automatically needs a full Czech translation for every purpose. Determine the document's use and any authority request separately. An e-shop summary is also not a substitute for a required instruction manual supplied with the product.
Keep CE marking and GPSR evidence distinct
GPSR does not create a general CE-marking requirement. CE marking is used for products covered by the EU legislation requiring it; it should not be applied to other products just to make them look compliant. The EU's CE guidance explains that distinction.
For products subject to CE-related rules, review the relevant declaration, technical evidence and sector requirements. For other consumer products, the absence of a CE mark is not by itself the GPSR problem to solve. Neither a CE logo nor a commercial certificate eliminates the need to identify the correct product, role and applicable safety duties.
Kodo's review does not issue an official certification, approve a product for sale or guarantee compliance. It records the checks performed and the evidence or action still needed.
Retain evidence and respond when information changes
Documentation needs an owner after launch. Where the cited provisions apply, Article 9(3) requires the manufacturer to keep technical documentation available for ten years after placing the product on the market; Article 11(6) sets the importer's corresponding retention duty for a copy. Record the legal retention basis rather than assuming every business record has the same period. GPSR documentation retention
Revisit the file when a supplier, material, model, label or safety instruction changes. Keep older versions linked to the products and batches they describe.
Agree how complaints and safety incidents reach the responsible team. Article 20 concerns notification of specified safety-related accidents through the Safety Business Gateway; Articles 9, 11 and 12 also address action on dangerous products. A supplier correspondence thread should not become a reason to delay a necessary corrective measure. GPSR safety and notification duties
Commission a review with clear outputs
Start with a defined product group, your supply-chain role, the intended market and one representative document set. Agree whether the work covers document completeness, consistency, labels, Czech information, online offers or preparation of missing records.
A useful handover contains:
- a model and document inventory;
- a findings list linked to the file, label or product page reviewed;
- priorities and named owners for missing evidence or corrections;
- approved or draft information updates, clearly distinguished;
- open technical or legal questions requiring further work;
- the review scope, date and limits, including any sampling.
For a larger business, this creates a manageable handover between sourcing, product management, compliance, Czech customer support and the e-commerce team. An advisory audit is a review commissioned by the company. It is not an inspection by a market-surveillance authority or an endorsement of unreviewed models.
How Kodo supports the work
Within an agreed assignment, Kodo reviews supplied product documentation and listings, organises model-level records, identifies gaps, drafts supplier requests and prepares Czech product information from confirmed sources. We can also scope the implementation of approved changes on your website.
Your company and manufacturer provide accurate source documents and confirm factual and technical information. Your team maintains the products and implements approved changes. Technical assessment, testing and certification are separate assignments; Kodo does not assume a GPSR authorised-representative or responsible-person role.
You can use the client portal to share attachments and keep GPSR questions and replies with the support conversation. Account registration is free and non-binding; Kodo reviews access before activating relevant working areas. Basic orientation about the portal, required inputs and next steps is free. Detailed analyses, documentation audits, translations and preparation of deliverables are paid services quoted by scope.
For an initial proposal, send your product-page link, establishment country, supply-chain role, approximate model count and sample supplier documents. Request a GPSR documentation review. If you also need packaging EPR or WEEE support, the work can be coordinated while keeping each legal role and agreement separate.
The main conclusion
Start with the applicable rules, your legal role and one complete model-level evidence trail. Resolve missing safety evidence with the manufacturer or appropriate specialist, then align the product, Czech information and online offer. Keep the review current as products change.
Frequently asked questions
Does GPSR cover every product sold to a business?
Can we use one generic risk assessment for all models?
Does a CE certificate replace GPSR documentation?
Can Kodo act as our EU responsible person?
Does the review include a technical risk assessment?
Must the online safety information be in Czech?
Can we start with a small sample and a free portal account?
How Kodo can help
Kodo helps foreign manufacturers, importers and sellers prepare product records and Czech-market information through agreed GPSR advisory and documentation work. We identify gaps, organise supplier evidence and prepare information updates. This service does not appoint Kodo as a GPSR authorised representative or EU responsible person.
For legal, tax, regulatory, certification and investment-incentive matters, companies should work with qualified specialists and the responsible authorities.
Related reading
- International certification and European supply chains
- Selling to Czechia: PPWR and EPR before the first parcel
- Kodo adds WEEE and batteries to its Czech EPR portal
Sources and verification
Checked 19 October 2026: Regulation (EU) 2023/988, consolidated text of 29 May 2026, particularly Articles 1–3, 6, 9–13, 16, 19–21 and 52; and Czech Act No. 387/2024 Coll., e-Sbírka version effective from 1 July 2025, particularly Section 8. The MPO FAQ and EU CE guidance linked above provide official practical guidance; the legislation determines the applicable duties. Product-specific standards, testing and technical conclusions are outside this general article.
- GPSR Articles 1–3 and 52
- Czech Ministry of Industry and Trade's GPSR guidance, especially question 3
- Official Czech language requirements
- EU's CE guidance
This article provides general information, not a determination that a particular product is safe or compliant. Review the actual product, legal role and evidence before deciding whether it can be supplied.