GPSR Blocker Diagnosis

Case GR-2026-0007 · Prepared for: [CLIENT NAME REDACTED] · Platform: Amazon.de · Delivered: within 24h of intake

1. What you told me

Input	Your submission
Platform / marketplace	Amazon.de (also selling .fr and .it)
Error code or current status	`Error 5995` on bulk upload; individual ASINs show “Your submission is under review”
SKU count affected	34 SKUs, 6 product types
Already submitted	Suppliers' CE test reports + the supplier's own Declaration of Conformity (PDF, in the supplier's name)
Responsible Person appointed	Yes — a German forwarding address bought through a service, named on the product label
Duration stuck	5 weeks, 3 resubmissions

2. Diagnosis

Primary R1 — You are not the registered Brand Owner, so bulk edits are hard-blocked

This is the reason nothing you submit is moving. Error 5995 is not a document-validation error — it is a permission error. Amazon restricts bulk safety and manufacturer edits to the account holding the registered Brand Owner role for that ASIN. Your account is a reseller on these ASINs, so the bulk path is closed to you regardless of how good the documents are.

The reason you also see “under review” and not a clean rejection is that your resubmissions are going in through a route that queues the file but can never satisfy the brand-role check. That is what produces the loop other sellers describe as “submit, wait 7 days, back to required”.

Contributing R2 — The Declaration of Conformity is in the wrong name

You are submitting the supplier's DoC. But your own brand is on the product, which makes you the manufacturer for the purposes of the declaration — so a DoC that does not name you does not satisfy the check, even though it is a genuine, valid document.

The supplier's safety forms are not evidence for your listing. What is being checked is whether the responsible economic operator chain is clearly defined and named by you.

Contributing R5 — The Responsible Person appointment may not qualify

A purchased forwarding address is frequently insufficient. The named person must be an EU-established economic operator who accepts the legal responsibility, with a physical address and contact details a consumer can actually reach — and those details must appear on the product, its packaging, or an accompanying document.

Action required from you: confirm with your provider, in writing, that they are acting as the responsible person accepting obligations under Regulation (EU) 2023/988 — not merely providing a mailing address. If they will not put that in writing, the appointment will not survive scrutiny and should be replaced.

Checked, no issue R4 — Test laboratory status

I checked the labs named on the report you supplied against Amazon's Suspended Validation Labs list. Neither appears on it. Your test reports are usable — keep them, you will need them in step 3 below.

The single most important sentence in this report: stop resubmitting. Every additional submission through the route you have been using consumes a review cycle and adds nothing, because no document can clear a brand-role permission block.

3. Fix sequence

Do these in order. Steps 1 and 2 are the ones that unblock you; step 3 makes the file pass once you are through.

Step 1 — Switch from the bulk path to Manage Your Compliance (do this first)

Seller Central → Performance → Account Health
Scroll to the bottom right, open the Manage Your Compliance widget
Click Product Compliance Requests
Find each affected ASIN. In the Next Steps column click Provide Documents or Submit Compliance Information
File against the specific ASIN — do not attempt a catalogue-wide push. MYC lets you act at SKU level, which is the whole point when you don't hold the brand role

Do not change the product category to “Handmade” to work around this. It removes the ASIN from the All Departments search index, kills organic traffic and PPC immediately, and cannot be reverted in bulk.

Step 2 — Deal with the 34 SKUs in batches of 5

MYC is per-ASIN and will time out if you try all thirty-four. Work in batches of five, submit, note the date, and wait for a status change before moving on. Record each batch in a sheet with: ASIN, date submitted, status, days elapsed. You will need this if you have to escalate.

Step 3 — Replace the document set

File these three, in this order, for each ASIN. Use the versions below, adapted to your company details.

3a. Your own EU Declaration of Conformity

This is a self-declaration — no lab and no consultant has to sign it. It must name you as the manufacturer and be based on the test reports you already hold.

EU DECLARATION OF CONFORMITY

1. Product / model:            [PRODUCT TYPE], model [MODEL NUMBER]
   Batch / serial identifier:  [BATCH OR SERIAL]

2. Name and address of manufacturer:
   [YOUR COMPANY LEGAL NAME]
   [FULL POSTAL ADDRESS]
   [COUNTRY]  —  [CONTACT EMAIL]

3. This declaration of conformity is issued under the sole responsibility
   of the manufacturer.

4. Object of the declaration:
   [DESCRIPTION: what the product is, what it is used for, how it is used]

5. The object of the declaration described above is in conformity with the
   relevant Union harmonisation legislation:
   - Regulation (EU) 2023/988  General Product Safety Regulation
   - [ADD APPLICABLE, e.g. Directive 2014/30/EU (EMC), 2011/65/EU (RoHS),
     Regulation (EU) 2023/1542 (batteries)  — only those that apply]

6. References to the relevant standards used:
   - [EN STANDARD]                e.g. EN 55032 / EN 55035 (EMC)
   - [EN STANDARD]
   (Taken from the test reports on file for the model above.)

7. Name and address of the person authorised to compile the technical file /
   EU responsible person:
   [RESPONSIBLE PERSON LEGAL NAME]
   [EU PHYSICAL ADDRESS]
   [CONSUMER-REACHABLE EMAIL]

8. Signed for and on behalf of:  [YOUR COMPANY LEGAL NAME]
   Place and date of issue:      [CITY], [DATE]
   Name, function, signature:    [NAME], [ROLE]

3b. Internal risk analysis (Art. 9.2.a)

This is the document most sellers never produce, and its absence is why files pass format checks and still fail. It does not need to be long. For each product type answer the hazard questions honestly and state what you did about each:

Hazard area	Your product	Measure taken
Electrical safety / heat	Mains-connected, LED driver	Test report [REF] to EN 55032/55035; CE-marked driver; thermal cut-out
Materials in contact with user	ABS housing, no skin contact beyond handling	RoHS declaration [REF]; REACH compliance statement from supplier
Small parts / entrapment	No detachable parts under 3 cm	Assembly fixed; pull test [REF]
Ingress / liquids	Indoor dry use only	IP rating declared: IP20; warning in label text
Battery	None	Not applicable
Misuse / foreseeable wrong use	Covered outdoor or with damaged cable	Warning statements below; instruction sheet
Vulnerable users / children appeal	Not child-directed	Warning statement; no decorative food-like appearance
Residual risk	Low — all identified hazards mitigated by the measures above, verified by [TEST REFS]

3c. Label and warning text

[MANUFACTURER LEGAL NAME]
[FULL POSTAL ADDRESS]
[CONTACT EMAIL]

EU RESPONSIBLE PERSON: [LEGAL NAME], [EU ADDRESS], [EMAIL]

EN  WARNING: For indoor use only. Do not use with a damaged cable
    or plug. Do not cover. Not a toy — keep away from children.
DE  WARNUNG: Nur für den Innenbereich. Nicht mit beschädigtem Kabel
    oder Stecker verwenden. Nicht abdecken. Kein Spielzeug —
    von Kindern fernhalten.
FR  AVERTISSEMENT: Usage intérieur uniquement. Ne pas utiliser avec un
    câble ou une fiche endommagé(s). Ne pas couvrir. Ne pas laisser
    à la portée des enfants.

Model / Modell / Modèle: [MODEL]
Batch / Charge / Lot:     [BATCH]
EAN: [EAN]

Warning text must appear in the official language of each country of sale. Because you sell in .de, .fr and .it, all three are required for those marketplaces — a single English block is not sufficient. Add the Italian block before you file for .it.

4. Escalation script

Only use this after Step 1 and 2 are done and a submission has been in review for more than 7 days. Paste as-is, filling the brackets. It gives support a specific technical finding rather than a complaint, which is what moves cases out of the loop.

Subject: GPSR submission blocked by brand-role permission error — case set [BATCH REFERENCE]

I am submitting GPSR compliance information for [N] ASINs via Manage Your
Compliance (Product Compliance Requests) on seller account [SELLER ID].

Attempting a catalogue update returns Error 5995. I understand this error
relates to brand-name permissions and that my account is not the registered
Brand Owner on these ASINs. I am therefore filing at SKU level through MYC,
not via a catalogue push.

Submissions for the following ASINs have been in "under review" status for
[D] days, with no change and no rejection reason provided:
[LIST ASINs AND SUBMISSION DATES]

For each ASIN I have provided:
  1. EU Declaration of Conformity in my name as manufacturer
  2. Internal risk analysis under Article 9.2.a
  3. Test reports from [LAB NAME], not on the Suspended Validation Labs list
  4. EU Responsible Person declaration: [RP LEGAL NAME], [EU ADDRESS]

Please confirm either (a) which specific document is deficient and why, or
(b) that the submissions meet requirements and will be processed.

I have held stock in FBA for these ASINs since [DATE]. Please treat this as
time-sensitive.

[YOUR NAME] — [SELLER ID] — [EMAIL]

5. Stock countdown

Sellers report roughly 30 days from deactivation before FBA stock is scheduled for automatic destruction. Working from your deactivation date:

Milestone	Date (from your case)	Action
Deactivation	Day 0	Stop resubmitting the old file set
Step 1 & 2 complete	Days 1–3	File all ASINs through MYC in batches of 5
First status check	Day 10	If still “under review” and no reason given, send the escalation script
Decide on removal order	Day 18	If still unresolved, request a removal order rather than lose the stock
Destruction risk window	Day 30	Hard deadline

Day 18 is the decision point. Removal and shipping costs money and hurts, but it is a fraction of losing the inventory. Do not wait until day 28 to price it.

6. What to expect, honestly

Step 1 is the fix. The brand-role route change is what unblocks submission; the documents are what make it pass.
Expect the first batch to move faster than the rest. Once one ASIN clears, the pattern usually repeats.
Timelines are theirs, not mine. Review has taken weeks for other sellers. If a submission sits past 7 days with no reason, escalate — don't resubmit.
If Step 1 doesn't change anything within 10 days, reply to this report and I'll go one more round with you. That's included.

This is the report you get for your own case.

Blocker classification, fix sequence, corrected documents, escalation script and stock countdown — 24 hours after you send me your error message.

Get my diagnosis — €12

GPSRRescue — blocker diagnosis and document preparation for sellers facing EU GPSR (Regulation (EU) 2023/988) enforcement.

This sample is illustrative. Client identity, product, ASINs, laboratory names, dates and document references have been changed. It is not legal advice, not certification, and not a guarantee of marketplace reinstatement. Marketplace decisions remain with the marketplace. Not affiliated with or endorsed by Amazon or Etsy.

Contact: [email protected]