GPSR Service Policy & Terms

IXXO EU Representative Service Policy & Terms (GPSR Compliance)

(in accordance with Regulation (EU) 2023/988 — General Product Safety Regulation)

1. Definition of “Item”

For the EU General Product Safety Regulation (GPSR), an item is defined as each distinct product type or model (SKU) placed on the EU market.

Each unique design, variant, or model counts as a separate item.
Broad terms such as “jewellery” or “collection” are not considered one item.

Example:
If you sell rings, pendants, and cufflinks, these count as three items, even if they belong to the same product line.

2. Fee Calculation Principles

IXXO’s annual EU Representative service fees are calculated based on three main factors:

Number of product types/SKUs under representation;
Risk level of the product type, determined by the material, design, and intended use;
Expected annual sales volume in the EU market.

This structure follows standard practices among recognised EU GPSR Representative service providers to ensure each product type is properly covered and documented for market surveillance.

3. Risk-Based Product Categorisation (Jewellery Examples)

Risk Level	Description	Examples	Typical Requirements
Low Risk	Jewellery made from tested and compliant materials with minimal hazard potential	Gold/silver rings, solid bracelets, pendants	REACH compliance, EN 1811 nickel release test, product labelling
Medium Risk	Items with small detachable parts or mixed materials	Magnetic clasp necklaces, charm bracelets, earrings	Risk assessment, EN 1811 + EN 71-3, where applicable, age warning
High Risk	Products for or accessible to children, or with small parts that pose choking hazards	Children’s jewellery, low-cost costume jewellery, sets with small beads	Full safety file, hazard testing, labelling for age group, traceability records

4. Annual Representation Fee Table (Example)

(Fees are indicative and may vary depending on documentation quality, risk level, and portfolio size.)

Tier	Number of Product Types (SKUs)	Risk Category	Annual Fee (EUR)	Includes
Tier 1	1–5 SKUs	Low Risk	€ / year	Basic documentation review, registration, and representation
Tier 2	6–20 SKUs	Low–Medium Risk	€ / year	Technical file review, annual compliance verification, and authority communication
Tier 3	21–50 SKUs	Mixed Risk	€ / year	Extended documentation management, batch risk evaluation, and support
Tier 4	51+ SKUs	Mixed / High Risk	from € / year	Full documentation maintenance, market surveillance handling, and recall support

Optional Add-Ons:

Risk Assessment Support: €—- per product
Technical Documentation File Creation (per SKU): €—-
Annual Label Review: €—- per label version

All fees are exclusive of VAT and subject to annual renewal.

5. Scope of IXXO’s EU Representative Service

As your appointed EU Representative under Article 16 of the GPSR, IXXO will:

Act as the official contact for EU market surveillance authorities;
Maintain technical documentation for each declared item.
Handle communications and corrective actions with authorities when needed;
Support you in risk assessments, label verification, and traceability compliance;
Provide an annual compliance summary report confirming your obligations are met.

6. Documentation Required from the Manufacturer

Before the product is placed on the EU market, the following documentation must be provided to IXXO:

Complete product list with SKUs and descriptions;
Risk assessment and relevant test reports (e.g., EN 1811, REACH, EN 71-3);
Labelling and packaging samples;
Manufacturer and importer details;
Instructions for use and age warnings (if applicable).

7. Summary

Each distinct product/SKU = one item for GPSR purposes.
Fees are based on the number of SKUs, risk level, and sales volume.
Jewellery products must be classified under a risk-based framework according to material safety, design, and target user.
IXXO acts as your official EU Representative, ensuring complete GPSR compliance and readiness for market inspections.

Disclaimer:
This document is provided for general informational purposes and does not constitute legal advice. Each manufacturer remains responsible for ensuring product compliance with all applicable EU regulations.

IXXO Compliance Department