What Testing Does GPSR Require? European Standards, Test Reports and Presumption of Conformity

Short answer: no mandatory testing, but you need evidence

GPSR Article 5 allows only safe products on the market. Article 9(2) requires the manufacturer to carry out an internal risk analysis before placing a product on the market and, where relevant, to document the solutions adopted to eliminate or mitigate risks, “including the outcome of any reports related to tests conducted by the manufacturer or by another party on their behalf”. Nothing says the tests must be done by a third-party lab, or by a lab in the EU.

That does not mean you can skip testing. When an authority checks your product, a marketplace reviews it or a consumer complains, you need evidence that it is safe. For products with real risks (children's products, anything that heats up or bears weight, materials touching skin or the mouth), a test report on the exact model you sell is the most direct and widely accepted evidence. A low-risk product such as a plain cotton towel may be supported by material declarations, simple in-house checks and a sound risk analysis.

To decide what to test, start from the risk analysis (see how to do a GPSR risk assessment). The controls that need data to prove them are your test plan.

Article 7 presumption: which standards count

Implementing Decision (EU) 2026/901 (adopted 17 April 2026, published and in force 27 April 2026) brings the standards supporting the GPSR into one list in Annex I, with 76 entries, and repeals Implementing Decision (EU) 2019/1698. Examples of what it covers:

• childcare: cots and folding cots, cribs, soothers, drinking equipment, changing units, baby carriers, high chairs, cycle child seats, bathing aids;
• children's clothing: EN 14682:2014 on cords and drawstrings;
• bicycles: the EN ISO 4210 series, EN ISO 8098:2014 for young children's bicycles, luggage carriers;
• sport and fitness: gymnastic equipment, stationary training equipment (EN ISO 20957 series and parts of EN 957), floating leisure articles (EN ISO 25649 series), roller skates;
• other: lighters, internal blinds (strangulation), child-resistant locks for windows and balcony doors, decorative oil lamps, consumer laser products, and only the sound-exposure clauses of EN IEC 62368-1.

Four older editions in Annex II (for example EN 14988:2017+A1:2020 for high chairs) remain usable until their references are withdrawn on 27 October 2027. Always check exact numbers and editions in the OJ text.

Two cautions. The presumption covers only the risks the standard addresses, and Article 7(3) lets authorities act if there is evidence the product is dangerous. And most product types (homeware, jewellery, pet products, most small kitchen items) are not on the list; then you use Article 8 and pick other European or ISO/IEC standards. The national standards in Article 8(1)(f) are those of the member state of sale; Chinese GB or US standards are not among the listed elements and are supporting material at best.

CE products: harmonised standards are a separate system

For toys, electrical and radio equipment, machinery and other CE products, the presumption comes from harmonised standards under the sector law. For example, Article 12 of the Low Voltage Directive 2014/35/EU presumes conformity with the safety objectives for equipment meeting harmonised standards referenced in the OJ, for the aspects they cover. References are published law by law through Commission implementing decisions (Blue Guide, section 4.1.2).

See how to write an EU declaration of conformity and GPSR vs CE marking.

What a credible test report contains

No law prescribes a report format. These are the points authorities, Responsible Persons and marketplaces typically check:

Why accreditation matters: GPSR Article 23(1) extends Article 11(1)–(7) of Regulation (EU) 2019/1020 to GPSR products, and Article 11(5) says that where operators present test reports or certificates from an accredited conformity assessment body, authorities shall take due account of them. Accreditation is not mandatory, but it gives the report weight.

Know the limits too: a report proves only that the sample passed the listed tests. Series consistency comes from the production procedures required by Article 9(4), such as incoming and pre-shipment inspection. If one report covers several models in a range, explain in the technical file why their safety-relevant features are the same.

Test report, certificate and declaration of conformity are different

A GPSR-only product has no DoC and must not carry the CE marking (Article 30(2) of Regulation (EC) No 765/2008).

When a marketplace asks for test reports

Test reports are not part of the information that Article 19 requires in online offers. Marketplaces such as Amazon or Temu may still ask sellers to upload test reports, declarations of conformity or other documents under their category policies, at an authority's request or during spot checks. What they ask for, in what format and by when is set in their seller notices and help pages, varies by marketplace, category and time, and we do not repeat rules they have not published.

To prepare:

• name files with ASIN/SKU, model and document type to avoid wrong uploads;
• make sure brand and model on the report match the listing and the product label, and add a short note when one report covers several SKUs;
• if English or a local language is needed, add a translation rather than altering the original;
• never edit model numbers, dates or lab details on a report and never use someone else's report: that is false information.

For appeal structure see Amazon GPSR appeal; Temu sellers can also read Temu GPSR requirements.