GPSR COMPLIANCE CERTIFICATE

EASECERT LLC

Compliance & Certification Services

www.easecert.com

Certificate Number: EC-9881074

Issue Date: 08-Aug-2025

1. Certificate Holder

• Name: Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)

• Registered Trade Name / Trade Mark: Clear Lights tech Headlight Restore

• Full Postal Address: 6213 Newcastle Ave, Encino, CA 91316, United States

• Electronic Address (email & website): info@headlightrestore.us;

https://headlightrestore.us

• Telephone Number: +1 917-382-7123

• Primary Contact: Joseph Marco

2. Product Information

Product: Headlight Restoration Wipes

The product is a two-step cleaning and sealing kit designed for restoring the clarity of automotive plastic

headlight lenses. It consists of:

• One chemical cleaning wipe for removing oxidation and surface residue.

• One UV sealant wipe to apply a protective coating that prevents yellowing and restores optical

clarity.

The product is intended for cosmetic maintenance of vehicle headlights. It is supplied in sealed, single-

use sachets and is classified as a non-electrical consumer good. Instructions for safe handling and

application are included with the product packaging.

Product Raw Materials:

• Step 1 – Cleaning Wipe:

• Butoxyethanol (10–25%)

• Dodecylbenzene Sulfonic Acid (1–5%)

• Step 2 – Sealant Wipe:

• Propan-2-ol (1–5%)

• UV-curing resin solution

• Packaging Materials:

• Sealed flexible sachets; outer carton with printed warnings, traceability data, and safe

use instructions

Age Grading: 18+ (For adult use only)

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-37073. Compliance Requirements

Product Category

Automotive Accessories – Headlight Restoration Kits

This product is classified as a non-electrical consumer accessory intended for the exterior maintenance of

polycarbonate headlight lenses. It is used to improve the cosmetic clarity of headlights through manual

application of a cleaning wipe followed by a UV sealant wipe. The product does not alter the structural or

optical performance of the vehicle's lighting system.

Applicable Legal Requirements

The product has been assessed for safety and compliance under the following applicable EU legislation:

• Regulation (EU) 2023/988 – General Product Safety Regulation (GPSR)

Ensures general consumer product safety, traceability, risk assessment, and warnings under

Annex I.

• Regulation (EC) No 1272/2008 – Classification, Labelling and Packaging of Substances and

Mixtures (CLP)

Applied to classify and label chemical ingredients in both wipes. Hazard statements (e.g. H315,

H319, H225) are declared.

• Regulation (EC) No 1907/2006 – REACH Regulation (Annex XVII and SVHC)

Covers registration and restriction of hazardous chemicals, including butoxyethanol,

dodecylbenzene sulfonic acid, and propan-2-ol.

• Directive 2008/98/EC – Waste Framework Directive

Applicable to disposal of used wipes and packaging; reinforced by SDS statements and product

labeling.

• Regulation (EU) 2023/122 – Packaging and Packaging Waste

Governs the recyclability and composition of packaging materials.

EU Harmonised Standards Applied

There are currently no harmonised standards directly applicable to headlight restoration kits under

Regulation (EU) 2023/988. Therefore, conformity has been assessed using appropriate reference and

analogy standards as listed below.

Other Reference Standards Applied

• ISO 12100:2010 – Safety of Machinery – General principles for design – Risk assessment and

risk reduction

Applied by analogy to evaluate foreseeable risks during normal and improper use, especially with

respect to chemical application on plastic surfaces.

• EN 71-1:2014+A1:2018 – Safety of Toys – Mechanical and physical properties

Applied by analogy for evaluation of misuse scenarios and physical safety (e.g. risk of sachet

rupture or accidental exposure).

• OECD Test Guidelines TG 404 / TG 405 – Acute Dermal Irritation/Corrosion and Eye

Irritation/Corrosion

Referenced to support classification of chemical ingredients and the formulation’s toxicological

profile as presented in the Safety Data Sheets.

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-3707• ECHA Guidance for Downstream Users under REACH and CLP

Used for chemical hazard classification, label preparation, and exposure control as part of the

product’s Safety Data Sheets and technical documentation.

4. Risk Assessment & Safety Compliance

The Headlight Restoration Wipes by Dandy Tech Inc were evaluated across six hazard categories in

accordance with Annex I of Regulation (EU) 2023/988 – General Product Safety Regulation. The

assessment considered material composition, intended function, user interaction, environmental

exposure, and the supporting compliance documentation including SDS, declaration of conformity,

product instructions, and sachet labeling.

• Physical and Mechanical Hazards: No sharp edges or choking risks were identified. The wipes

are large, single-use, and age-graded for adult use. Risk of accidental eye contact is addressed

through clear labeling and safe-use instructions.

• Flammability / Thermal Hazards: Step 2 contains a flammable VOC (propan-2-ol). This risk is

mitigated through on-label GHS symbols, ventilation guidance, and instructions to avoid ignition

sources and hot surfaces during application.

• Chemical Hazards: The cleaning and sealing wipes contain substances classified as irritants

under the CLP Regulation. Warnings are present on all sachets and reinforced in the user leaflet.

Protective measures such as glove use and ventilation are advised. Safe disposal is emphasized

to prevent environmental harm.

• Electrical Hazards: Not applicable. The product contains no electrical or powered components.

• Hygiene Hazards: The wipes are single-use and include clear warnings against reuse.

Handwashing is advised to prevent cross-contamination or unintentional exposure to residual

chemicals.

• Radiation Hazards: Not applicable. The product does not emit radiation and does not rely on UV

devices for curing.

Conclusion:

All foreseeable hazards associated with the Headlight Restoration Wipes have been identified and

addressed through design choices, precautionary labeling, and consumer-facing instructions. Residual

risks—primarily related to skin/eye irritation or improper handling—are mitigated to a level considered

acceptable under normal and reasonably foreseeable conditions of use.The product is considered safe

for adult consumers when used in accordance with its labeling and instructions.

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-37075. Traceability & Technical Documentation

To ensure compliance with the General Product Safety Regulation (EU) 2023/988, the following

documentation is maintained by the manufacturer and the designated EU Responsible Person and is

made available to Market Surveillance Authorities upon request, in accordance with Articles 9 and 23

of the Regulation. Maintained Documentation Includes:

• General Product Description

o Product name, variants, and intended use

o Description of materials and construction

o Photographs of the product and packaging

• Risk Assessment

o Comprehensive hazard identification and mitigation strategies

o Classification of risks (critical, major, minor, manufacturing)

o Corresponding control measures and labeling requirements

• Labeling & Packaging Files

o Multilingual label artwork

o Location and format of safety warnings

o Traceability markings (batch/LOT codes)

• Instructions for Use

o Multilingual instructions for safe product use, storage, and disposal

o Recommended guidelines and precautions

• Declaration of Conformity

o Signed declaration confirming compliance with EU 2023/988

o Manufacturer and EU Responsible Person contact details

• Test Reports and Certificates

o Confirm that the assessed products meet all applicable EU product safety and chemical

compliance obligations

The above documentation is maintained for a minimum period of 10 years after the product is placed

on the EU market, as required by Article 23 of Regulation (EU) 2023/988.

6. EU Responsible Person Information

• Name: EaseCert

• Registered Trade Name / Trade Mark: EaseCert | GPSR Compliance

• Full Postal Address: Waldstr. 33, 54413 Damflos, Germany

• Electronic Address (email & website): compliance@easecert.com; www.easecert.com

• Telephone Number: +49 170 5738 555

• Primary Contact: Christian Wollscheid / Compliance Specialist

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-37077. Certification Statement

Based on the submitted documentation and assessment of the product’s composition, construction,

intended use, and labeling, the above-listed product categories are considered safe under normal or

reasonably foreseeable conditions of use in accordance with Regulation (EU) 2023/988 (GPSR). This

certificate confirms that the products meet all applicable general safety requirements for placement on the

EU market.

Authorized by: EaseCert | GPSR Compliance, August 08, 2025

Legal Disclaimer: This document is intended as guidance only and is based on the manufacturer's input.

It is not intended as legal advice, nor does it replace or supersede a manufacturer's obligations to comply

with all applicable GPSR requirements. The manufacturer or importer of every consumer product is

ultimately responsible for the compliance of every consumer product sold in the European Union with

applicable GPSR requirements. This GPSR guidance provided by EaseCert has been prepared for general

informational purposes only to assist in complying with GPSR requirements. If the manufacturer's

responses do not accurately reflect the applicable facts and circumstances, the information conveyed by

EaseCert may not be complete or accurate. The information provided by EaseCert is not legal advice. The

manufacturer will not rely or act upon information provided by EaseCert as representing legal advice or

conclusions of any regulatory authority or enforcement body. The information provided is not promised or

guaranteed to reflect the most current legal, enforcement, compliance, or other developments. No

information conveyed by EaseCert or otherwise on its website or in its materials should be used as a

substitute for advice from competent legal counsel regarding legal requirements. No documents or other

information generated or conveyed by EaseCert (including certifications, conclusions, references, or

recommendations) are binding on any regulatory authority or enforcement body, nor do any such

documents or information have any legal effect. This certificate is issued by EaseCert LLC and does not

exempt the manufacturer/importer from fulfilling their legal obligations under EU regulations.

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-3707All services are subject to the following Terms and Conditions:

1. Verification Services. EaseCert LLC (“we,” “us,” or “our”) will provide consulting, verification,

registration, assessment, representation, and related services (collectively, the “Services”) as described in

your order, scope of work, project proposal, quotation, or order acknowledgment (each, a “Quotation”).

Our Services assess whether your products conform to the requirements, specifications, and/or protocols

that you define (“Your Requirements”). We do not evaluate the overall safety of the product or the broader

production batch from which it was drawn. Our Services do not include assessments against independent

safety standards, and neither we nor our affiliates assume responsibility for conducting such evaluations.

2. Retailer Programs. If you request Services related to compliance with a retailer, carrier, or other third-

party program (“Retailer”), you authorize us to share relevant information, materials, and deliverables with

the Retailer as necessary to fulfill the Service. The ownership of any deliverables produced under such

programs will be governed by the Retailer’s program terms, which will take precedence over any

conflicting terms in these Terms and Conditions.

3. Payment Terms. You agree to pay all fees and expenses associated with the Services in accordance

with our current pricing or as outlined in the applicable Quotation. These costs include, but are not limited

to, taxes, wire or transfer fees, duties, and other applicable charges. You will indemnify us against any

liabilities arising from failure to make timely payments. Payments not received by the due date will be

subject to interest at a rate of 1% per month (12% annually) or the maximum rate permitted by law,

whichever is lower. In the event of nonpayment, you agree to cover any reasonable costs associated with

collection, including attorneys’ fees, if applicable.

4. Your Requirements. You are solely responsible for defining and selecting Your Requirements for the

Services. While we may provide recommendations or guidance in developing these requirements, you

must review and approve them before we proceed with the Services. We assume no liability for the

adequacy, sufficiency, or accuracy of Your Requirements.

5. Estimated Schedule and Price. Any timeframes or pricing stated in the Quotation are estimates and

are subject to change based on project specifics. If adjustments are necessary, we will provide

reasonable notice. We are not liable for delays caused by unforeseen circumstances, third-party actions,

or changes in project scope.

6. On-Site Investigations. If the Services require on-site work at your facilities or those of a third party as

designated by you, you must ensure our representatives have safe, secure, and unrestricted access to

perform the Services. Our access must not be subject to signing any additional agreements, waivers, or

releases imposed by you or a third party. If circumstances beyond our control prevent us from completing

the Services as planned, we will not be liable for nonperformance. You may be charged for expenses

incurred and Services performed up to that point.

7. Deliverables. Upon completion of the Services, we will provide a document outlining:

(i) Your instructions and accepted request for Services; (ii) Your Requirements as applied; (iii) Services

performed; and (iv) Results obtained. We are not obligated to document, investigate, or report on any

facts, conditions, or findings that fall outside the explicit scope of your instructions.

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-37078. Our Findings. We do not guarantee that our findings, conclusions, or opinions will be accepted by

third parties, including regulators, authorities, or other entities. Our Services are limited to the scope

defined in the Quotation and do not constitute an endorsement or certification of overall product

compliance or marketability.

9. Use of Names and Marks. Unless expressly authorized in writing by us, you may not use our name,

trademarks, abbreviations, symbols, or those of our affiliates, subsidiaries, or parent company on any

products, packaging, advertising, promotional materials, or other communications. Unauthorized use may

result in legal action.

10. Cancellation and Refunds.

• (i) Once a service has been fully provided—including consultations, documentation, assessments, or

certifications—no refunds will be issued. Our Services involve expert analysis and compliance

evaluations that cannot be reversed or returned.

• (ii) If a refund request is made before work has begun, a refund may be issued minus administrative

fees. If work has already started (e.g., documentation review, risk assessment, or certification process),

no refund will be provided.

• (iii) If you are dissatisfied with a delivered service, you must contact us at info@easecert.com within 7

days of delivery. We will review your concerns and, if applicable, provide reasonable revisions or

clarifications.

11. No Warranty. We provide no express or implied warranties, including but not limited to:

• (i) Implied warranties of merchantability or fitness for a particular purpose.

• (ii) Non-infringement of third-party rights.

• (iii) Uninterrupted, timely, secure, or error-free operation of any web-based services.

12. Your Information. You represent and warrant that all information and data you provide to us (“Your

Information”) is complete, accurate, and may be relied upon for the provision of Services. You also

confirm that Your Information is either owned by you or properly licensed and does not infringe any third-

party intellectual property rights. We are not liable for any deficiencies in the Services resulting from

incomplete or inaccurate information provided by you.

13. Ownership of Work Product. You will own the compliance documents and other deliverables

provided under the Quotation. We may retain copies for archival purposes and to fulfill future document

requests from you or third parties as required.

14. Web Services. If we provide website tools or online service portals (“Web Services”), they are offered

as a convenience on an “as-is” and “as-available” basis. You acknowledge that: (i) We do not guarantee

security or protection against unauthorized access to data transmitted over our networks, the internet, or

wireless connections. (ii) Data stored by us, our affiliates, or service providers may be altered, lost, or

deleted. (iii) If you require secure communication, you are responsible for using an encrypted connection.

(iv) Your use of Web Services is at your sole risk and subject to any applicable terms of use. Web

Services are included in the definition of Services above.

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-370715. Confidentiality. We will not disclose any confidential information (“Confidential Information”) obtained

from you to third parties, except to our subsidiaries, affiliates, or subcontractors, without your prior written

consent. Confidential Information does not include information that: (a) was already known to us, (b) is

publicly available, (c) is lawfully obtained from other sources without breaching these Terms and

Conditions, (d) must be disclosed to perform the Services, (e) is required by law, government order, or an

accreditation authority, or (f) relates to a product bearing an EaseCert label that should be disclosed to us

or our affiliates under another agreement with you.

16. Samples. If product examination is required, you will send the necessary products to us at your

expense. Upon completion of our consulting services, the products will be destroyed unless you make

prior arrangements for their return, which will also be at your expense.

17. Limitation of Liability. Our liability for any claims of loss, damage, or expenses—regardless of the

nature of the claim, including breach of contract or failure to exercise due care—will in no case exceed

the fees paid for the specific Services in question. Under no circumstances will we be liable for indirect,

consequential, incidental, special, exemplary, or punitive damages, including but not limited to lost profits,

goodwill, data, business opportunities, or production; contract cancellations; or other intangible losses,

even if we have been advised of such possibilities. Any claim for loss, damage, or expense must be filed

under Section 25 (Disputes) within twelve months from the date of service completion or, in the case of

alleged non-performance, within twelve months of the date the service should have been completed.

18. Indemnification. You agree to defend, indemnify, and hold harmless EaseCert, including its officers,

directors, employees, agents, and subcontractors, from any third-party claims, losses, damages, or

expenses arising from these Terms and Conditions, including any Services or Web Services provided.

19. Waiver. Failure by either party to enforce any provision of these Terms and Conditions does not

waive the right to enforce that provision in the future.

20. No Third-Party Beneficiaries. These Terms and Conditions are solely between the contracting

parties and do not create rights for any third party.

21. No Assignment. Neither party may assign its rights or obligations under these Terms and Conditions

without prior written consent from the other party. However, we may assign our rights and obligations to

any of our affiliates or subsidiaries upon written notice to you.

22. Subcontracting. We may engage subcontractors for certain consulting or other Services. All

subcontractors will meet our qualification requirements and comply with our standards for confidentiality,

conflict of interest, and ethical conduct.

23. Termination and Notice. These Terms and Conditions remain in effect until terminated by either

party with thirty (30) days’ written notice. In the event of your breach of these Terms and Conditions,

termination may be immediate upon written notice. You remain responsible for any fees and expenses

incurred by us before termination. Notice may be delivered by hand, courier, mail, facsimile, or email to

the recipient’s designated principal place of business. Notices to us must be sent to: EaseCert LLC, 650

West 42nd Street, New York, NY 10036, USA. Notice is effective upon receipt.

24. Governing Law. These Terms and Conditions are governed by the laws of the State of New York,

USA. Choice of law principles that would apply the laws of another jurisdiction are excluded.

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-370725. Disputes. Any dispute related to these Terms and Conditions or the Services - except for

nonpayment of fees—will be resolved through confidential, binding arbitration. The arbitration panel will

be formed as follows:

• The parties will request a list of ten (10) arbitrators from the American Arbitration Association (AAA),

experienced in large, complex commercial disputes.

• Each party will select one arbitrator from the list.

• The selected arbitrators will choose a third arbitrator from the same list, who will act as chair of the

panel.

• The decision of the majority of the panel will be final and binding.

The arbitrators cannot modify these Terms and Conditions, award incidental, consequential, or punitive

damages (including loss of use, unjust enrichment, or lost profits), or exceed the remedies provided in the

limitation of liability clause. Judgment on the arbitration award may be entered by a court of competent

jurisdiction. Arbitration is the final remedy for disputes arising under these Terms and Conditions, except

that either party may seek a court order for injunctive relief to prevent misuse of trademarks, confidential

information, or intellectual property infringement. Arbitration proceedings will be conducted in English.

26. Severability. If any provision of these Terms and Conditions is found invalid, void, or unenforceable,

the remaining provisions will remain in effect to the fullest extent permitted by law.

27. Modifications. These Terms and Conditions constitute the entire agreement between the parties and

supersede all prior communications, representations, or agreements on the subject matter. No additional

or conflicting terms in your purchase orders, invoices, emails, or other documents will apply unless

explicitly accepted by us in writing. Performance does not constitute acceptance of such modifications.

28. Order of Precedence. These Terms and Conditions take precedence over any conflicting terms in a

Quotation, except for conflicts with Section 3 (Payment Terms), Section 5 (Estimated Schedule and

Price), and Section 10 (Cancellation Fees).

29. Electronic Signature. These Terms and Conditions may be executed and delivered via facsimile,

website, PDF, or other electronic means. Our electronic, digital, or hard copies of these Terms and

Conditions, your acceptance, and any Quotations signed or otherwise accepted by you will be considered

valid, complete, authentic, and enforceable. You agree not to dispute the admissibility or enforceability of

such copies in any legal proceeding.

30. Force Majeure. Neither party is liable for any failure or delay in performance due to circumstances

beyond reasonable control, including fire, flood, earthquakes, governmental actions, epidemics, acts of

God, war, terrorism, riots, civil disorder, or similar events. The affected party must: (i) prove that

reasonable precautions could not have prevented the delay; (ii) demonstrate that the delay cannot be

reasonably circumvented; and (iii) promptly notify the other party of the cause of the delay.

EaseCert LLC | 650 West 42nd Street, New York, NY 10036, USA | info@easecert.com | +1 (718) 730-3707