Dandy Tech Inc. / Headlight Restore US
GPSR Risk Analysis, General Product Safety Regulation
General Product Safety Regulation (GPSR) Risk Analysis
Section 1 – Economic Operator Information
Manufacturer
• Name: Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
• Registered Trade Name / Trade Mark: Headlight Restore US
• 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
Authorised Representative
• Name: EaseCert LLC
• 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
Importer
• Name: Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
• Registered Trade Name / Trade Mark: Headlight Restore US
• 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
Responsible Person
• Name: EaseCert LLC
• 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
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Section 2 – General Product Description
Product Name
Headlight Restoration Wipes
Product Description
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.
Essential Characteristics of the Product for Assessing Its Safety
• Non-electrical, chemically active product
• Contains substances classified for skin and eye irritation under CLP Regulation
• Requires use in ventilated environments with appropriate protective measures (e.g., gloves)
• Not intended to alter the performance or functionality of the vehicle
• Requires clear labelling and safe disposal per REACH and waste legislation
• Outer sachets with child hazard warning and usage instructions; not resealable. No pressurized
components.
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)
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Section 3 – Applicable Legal Requirements &
Standards
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.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
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.
• 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.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Section 4 – Product Design Evaluation
Available Compliance Documents (as of August 2025):
Document 1: EU Declaration of Conformity – Headlight Restoration Wipes
Issuing Party:
Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
Document Type:
Declaration of Conformity (DoC)
Scope:
This Declaration of Conformity applies to the Headlight Restoration Wipes, a two-step non-electrical
cleaning and sealing kit for automotive plastic headlight lenses. The product includes:
• Step 1: Cleaning wipe containing butoxyethanol and dodecylbenzene sulfonic acid
• Step 2: Sealant wipe containing propan-2-ol and UV-curing resins
Relevant Conclusions:
• The product complies with Regulation (EU) 2023/988 – General Product Safety Regulation
(GPSR)
• Assessed for compliance with CLP Regulation (EC) No 1272/2008 and REACH Regulation
(EC) No 1907/2006, including Annex XVII restrictions and SVHC requirements
• Packaging waste is addressed per Regulation (EU) 2023/122
• Risk assessment completed based on Annex I of GPSR
• Analogy standards used for safety justification include:
o ISO 12100:2010 (risk assessment and design safety)
o EN 71-1:2014+A1:2018 (mechanical safety)
o OECD TG 404/405 (skin and eye irritation)
• Safety instructions include the use of gloves, ventilation during application, and keeping the
product away from children
• No CE marking is required or affixed
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Relevance to GPSR Compliance:
This Declaration confirms that the product meets all relevant general safety requirements under GPSR
(EU) 2023/988. It provides traceability (manufacturer identity and contact details), outlines applicable
chemical and packaging legislation, and confirms that labeling and handling instructions are included to
mitigate foreseeable chemical and physical hazards. The declaration also supports labeling claims such
as adult-use (18+), proper disposal, and safe application practices.
Document 2: SDS – Headlights Cleaning Wipes Step 1
(Product Code: 1.HDL.21208.17)
Issuing Party:
Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
Document Type:
Safety Data Sheet (SDS)
Date of Issue: 09 April 2025
Scope:
This SDS applies to Step 1 of the Headlight Restoration Wipes product, a non-woven fabric wipe
saturated with a cleaning solution. The wipe is used to remove surface oxidation and residue from
automotive plastic headlight lenses.
Relevant Conclusions:
• Hazard Classification (per CLP Regulation EC No. 1272/2008):
o Skin Irritant – Category 2 (H315): Causes skin irritation
o Eye Irritant – Category 2 (H319): Causes serious eye irritation
• Hazardous Ingredients:
o Butoxyethanol (10–25%) – irritant, acute toxicity
o Dodecylbenzene Sulfonic Acid (1–5%) – corrosive, aquatic chronic hazard
• First aid, handling, and PPE recommendations provided
• Non-flammable; decomposition may emit CO and CO₂
• Not classified as hazardous for transport
• Waste disposal must comply with Directive 2008/98/EC
• Environmental precautions: Avoid release into waterways; moderate aquatic toxicity noted
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Relevance to GPSR Compliance:
This document provides essential chemical hazard data required under Regulation (EU) 2023/988
(GPSR) and REACH for risk assessment and consumer safety labeling. It substantiates the need for:
• Clear on-label warnings about skin and eye contact
• Use instructions such as wearing gloves and ensuring proper ventilation
• Safe disposal instructions and environmental precautions
The SDS also supports GPSR Annex I requirements regarding foreseeable chemical risks and
mitigations. It underpins the traceability and responsible communication of chemical risks in line with EU
safety obligations.
Document 3: SDS – Headlights Cleaning Wipes Step 2
(Product Code: 1.HDL.21208.13)
Issuing Party:
Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
Document Type:
Safety Data Sheet (SDS)
Date of Issue: 09 April 2025
Scope:
This SDS applies to Step 2 of the Headlight Restoration Wipes product, which involves application of a
UV-curing sealant to protect and maintain clarity of automotive plastic headlight lenses. The wipe is pre-
saturated with a liquid solution containing a volatile organic compound (VOC).
Relevant Conclusions:
• Hazard Classification (per CLP Regulation EC No. 1272/2008):
o Eye Irritant – Category 2 (H319): Causes serious eye irritation
o STOT SE 3 (H336): May cause drowsiness or dizziness
o Flammable Liquid – Category 2 (H225): Contains low-level flammable content
• Key Ingredient:
o Propan-2-ol (1–5%) – a VOC with known irritant and narcotic effects
• First aid, ventilation, and personal protective measures outlined
• Not classified as hazardous for aquatic environments
• Not regulated for transport under ADR, IMDG, or IATA
• Environmental precautions: Avoid spills and drainage entry
• Waste disposal must comply with Directive 2008/98/EC
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Relevance to GPSR Compliance:
This SDS provides critical hazard classification and exposure control information in accordance with
Regulation (EU) 2023/988 (GPSR). It enables proper risk assessment under Annex I by identifying
chemical hazards and supporting:
• Safety labeling requirements (e.g. eye irritation, flammability)
• Consumer instructions (ventilation, protective equipment)
• Packaging and waste disposal practices compliant with EU waste law
• Confirmation of safe handling, storage, and foreseeable use limitations
The document substantiates the need for clear on-label warnings, and is integral to demonstrating that
the product's design, instructions, and risk controls are sufficient to protect consumer safety.
Document 4: GPSR Statement of Compliance – Headlight Restore Wipes
Issuing Party:
Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
Document Type:
Manufacturer Declaration / Statement of Compliance
Date of Issue:
10 May 2024
Scope:
This document confirms that the Headlight Restore Wipes, produced by Dandy Tech Inc, are
manufactured in accordance with applicable EU product safety regulations and industry standards. The
statement refers to the product’s alignment with the General Product Safety Regulation (EU) 2023/988,
specifically in preparation for its full applicability starting 13 December 2024.
Relevant Conclusions:
• Product is manufactured in compliance with Good Manufacturing Practices (GMP)
• Sampling and testing procedures follow Article 19 of Regulation (EC) No 1223/2009 (on cosmetic
safety — used here analogously for chemical wipes)
• Declares conformity with GPSR labeling requirements, including safety instructions and
consumer guidance
• States that internal procedures for product recall, monitoring, and traceability are in place
• Commits to providing additional technical and safety documentation upon request
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Relevance to GPSR Compliance:
This declaration directly supports compliance with Article 23 of Regulation (EU) 2023/988, which requires
documentation to demonstrate that a product meets the general safety requirement. It also aligns with
Annex I by confirming:
• Safe production processes
• Labeling that enables safe use by consumers
• Availability of safety data and conformity documentation for market surveillance authorities
The statement serves as a formal assurance of regulatory readiness and traceability, and supports the
product's legal placement on the EU market under the GPSR.
Document 5: Product Instructions – Headlight Restoration Wipes
Issuing Party:
Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
Document Type:
Instruction Leaflet / Technical Usage Guide
Scope:
This document provides user-facing instructions for the proper application of the Headlight Restoration
Wipes. It outlines the correct order of steps, precautions, and usage limits for a two-step wipe system
(cleaning and sealing) to restore clarity to plastic headlight lenses.
Relevant Conclusions:
• Clear, sequential application steps provided:
1. 2. 3. 4. Open and apply Step 1 (yellow wipe) to clean headlights.
Dry headlights with paper towel.
Repeat Step 1 with second wipe if needed.
Open and apply Step 2 (orange wipe) as protective coating.
• Explicit handling warnings:
o Do not touch the headlight surface for 30 minutes after application.
o Avoid washing the car or headlights for 24 hours.
o Ensure headlights are not hot before use.
• Reinforces no tools required and supports use by ordinary consumers
• Includes British flag icon to denote language of instructions (UK English)
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Relevance to GPSR Compliance:
This usage instruction supports the requirements of Article 19 and Annex I (2)(b) of Regulation (EU)
2023/988 – General Product Safety Regulation:
• Helps ensure the foreseeable and intended safe use of the product
• Reduces risk of improper application (e.g. overuse, mixing steps, surface contamination)
• Supports labeling clarity and risk communication, helping prevent flammability or chemical
contact accidents
• Aligns with identified hazards in the SDSs (e.g. skin/eye contact, flammability)
• Forms part of the required “relevant instructions and safety information” for safe consumer
use
Document 6: Retail Packaging – Headlight Restore Wipes by Clear Lights Tech
Issuing Party:
Clear Lights Tech (Distributed from Tazewell, California)
Document Type: Retail Packaging / Product Label
Scope:
This consumer-facing packaging label provides marketing, instructional, and regulatory information about
the Headlight Restore Wipes product. It highlights intended use, product claims, use steps, contact
information, and product website access.
Relevant Conclusions:
• Product marketed as Headlight Restore in 2 Minutes
• Clearly labeled 3-step system:
1. Clean – Wipe 1
2. 3. Dry – With paper towel
Coat – Wipe 2 with UV protection layer
• Claims:
o Finishing and coating with UV protection
o Designed for long-lasting headlight brightness
o Before and After images demonstrate performance claim
• Consumer support provided via:
o Email contact: clearlightstech@gmail.com
o Website: www.headlightrestore.us
• Video instruction QR code
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Relevance to GPSR Compliance:
This label supports Articles 9 and 19 of the GPSR and Annex I, as it includes key traceability and usage
elements:
• Clear identification of product purpose (restores plastic headlights)
• Name and address of economic operator (Clear Lights Tech, CA – serves as
manufacturer/importer)
• Instructions for safe and correct use, reducing risk from misuse
• Reference to UV-coating function, tied to performance and protective claims
• QR code and website for video instructions, enhancing clarity for consumers
• Visual “Before/After” images support informed expectations
This packaging label plays a central role in enabling safe, informed, and intended use of the product, in
alignment with GPSR requirements for traceability, safe instructions, and product transparency.
Document 7: Headlight Restore US – Step 1 Cleaning Wipe
Issuing Party:
Clear Lights Tech (USA)
Document Type:
Secondary Packaging / Sachet Label
Scope:
This sachet contains the first step of the headlight restoration process: a cleaning wipe to remove surface
oxidation and debris from vehicle headlights. Instructions and hazard warnings are printed directly on the
sachet.
Relevant Conclusions:
• Usage Instructions:
o “Unfold the cleaning wipe and clean one headlight thoroughly using the wipe provided.
Dry the headlight with a paper towel. The headlight will look slightly matte after wiping.”
• Hazard Warnings:
o Keep out of reach of children
o If swallowed, call a poison center
o May cause serious eye irritation
o Remove contact lenses if present
o Wash hands thoroughly after use
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
• Symbols Included:
o Health hazard pictogram (GHS07)
o “Do not flush” icon
o California Prop 65 cancer/reproductive harm warning
o “Plastic in product” symbol
Relevance to GPSR Compliance:
• Article 9 Compliance (Consumer Information):
• Warnings are clearly printed in plain language and positioned near the use instructions.
• Hazard pictograms visually reinforce chemical safety.
• Disposal instruction (“Do not flush”) supports environmental safety.
• Annex I, Part A Risk Identification:
• Eye irritation and ingestion hazards are identified and mitigated via clear instructions.
• Cleaning use and drying requirement help prevent misuse (e.g. skipping protective step).
• Supports chemical risk labeling under REACH/CLP by analogy.
Document 8: Headlight Restore US – Step 2 Protection Layer Wipe
Issuing Party:
Clear Lights Tech (USA)
Document Type:
Secondary Packaging / Sachet Label
Scope:
This sachet contains the second-stage UV sealant wipe used to coat and protect the cleaned headlight
surface. It includes detailed application instructions and multiple hazard warnings.
Relevant Conclusions:
• Usage Instructions:
o “Do not unfold the wipe.”
o “Wipe both headlights thoroughly.”
o “Do not touch headlights or expose to water for 30 minutes.”
o “Do not wash car for 24 hours.”
o “Headlights may be turned on to speed up drying.”
• Hazard Warnings:
o “Keep out of reach of children.”
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
o “If swallowed, call a poison center.”
o “May cause serious eye irritation.”
o “Remove contact lenses if present.”
o “Wash hands thoroughly after use.”
• Symbols Included:
o Health hazard pictogram (GHS07)
o “Do not flush” icon
o California Prop 65 cancer/reproductive harm warning
o “Plastic in product” symbol
Relevance to GPSR Compliance:
• Article 9 Compliance:
• Hazard and safety information are clearly presented in direct relation to product use.
• Detailed aftercare guidance helps mitigate risks of premature UV exposure, smearing, or
misuse.
• Annex I Alignment:
• Identifies foreseeable misuse scenarios (touching, wetting, washing).
• Prevents chemical exposure risk through precautionary handling instructions.
• Supports chemical and environmental risk communication per CLP and GPSR Annex I
(by analogy).
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Risk Evaluation & Hazard Mitigation
This section evaluates the Headlight Restoration Wipes against six primary hazard categories defined
under Annex I of Regulation (EU) 2023/988. The product is a two-step, single-use wipe system
designed for manual restoration of plastic automotive headlight lenses. Step 1 provides cleaning and
oxidation removal, while Step 2 applies a UV-curing sealant.
Hazard identification and mitigation are based on the product's design, chemical composition, foreseeable
use conditions, and supporting compliance documentation.
Each category includes a hazard table with:
• Hazard: Description of the potential source of harm
• Tests/Processes Used: Methods used to assess and evaluate risk
• Mitigating Factors: Measures implemented to prevent or minimize risk
• Matching Compliance Documents: Technical documentation supporting risk control
• Relevant Standards/Guidelines: Legal or normative framework used
Physical and Mechanical Hazards
Hazard Tests /
Processes Used
Mitigating Factors Matching
Compliance
Document
Relevant
Standards /
Guidelines
Choking or
ingestion
hazard
(sachet or
wipe)
Visual inspection;
risk assessment
per Annex I; size
and shape
analysis
Product is age-graded for
adult use only (18+); wipe
dimensions exceed
choking hazard
thresholds; not intended
for use by children
EU Declaration of
Conformity –
Headlight
Restoration
Wipes
GPSR Annex
I; EN 71-1 (by
analogy)
Accidental
eye contact
with chemical
due to wipe
splash or
improper use
Risk assessment
based on intended
use; reviewed
SDSs and
instruction leaflet
Instructions emphasize
gentle wiping, avoiding
eye contact; warnings
and GHS pictograms
printed on sachets
SDS – Step 1
and Step 2;
Product
Instructions
Leaflet; Sachet
Labels
ISO
12100:2010;
OECD TG 405
(by analogy)
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Flammability / Thermal Hazards
Hazard Tests /
Processes
Used
Mitigating Factors Matching
Compliance
Document
Relevant
Standards /
Guidelines
Flammable
vapors from Step
2 sealant wipe
(contains propan-
2-ol)
SDS review;
hazard
classification
under CLP
(Flammable
Liquid Cat. 2,
H225)
Warnings on sachet
and leaflet advise use
in ventilated areas,
away from open flames;
flammable symbol
present; product is age-
graded 18+
SDS – Step 2
(1.HDL.21208.
13); Sachet
Label – Step 2;
Product
Instructions
Leaflet
CLP Regulation
(EC) No.
1272/2008;
GPSR Annex I
Heat sensitivity of
applied sealant
(e.g. touching hot
headlights)
Instruction
review; product
usage
assessment
Label clearly warns not
to apply on hot
surfaces; recommends
headlights be off and
cool before use
Product
Instructions
Leaflet; Retail
Packaging
ISO 12100:2010;
GPSR Annex I
Chemical Hazards
Hazard Tests /
Processes
Used
Mitigating Factors Matching
Compliance
Document
Relevant
Standards /
Guidelines
Skin and eye
irritation (Step 2:
propan-2-ol)
SDS review;
hazard
classification
under H319
Clear label warnings
and use instructions;
avoidance of skin/eye
contact emphasized
SDS – Step 2
(1.HDL.21208.13);
Sachet Label –
Step 2
CLP
Regulation;
OECD TG
404/405
Narcotic effects
/ dizziness from
inhalation of
Step 2 VOCs
SDS
classification
under STOT
SE 3 (H336)
Use instructions
emphasize adequate
ventilation; not to be
used in enclosed or
poorly ventilated areas
SDS – Step 2;
Product
Instructions Leaflet
CLP
Regulation;
GPSR Annex I
Improper
disposal (flush
or drain) of
chemical
residues
SDS + label
review; risk
assessment of
environmental
release
All sachets clearly state
“DO NOT FLUSH”;
warning pictograms
included; disposal info
aligns with Waste
Framework Directive
SDS – Step 1 & 2;
Sachet Labels;
Declaration of
Conformity
Directive
2008/98/EC;
GPSR Annex I
Long-term
environmental
risk from aquatic
toxicity (Step 1)
SDS indicates
moderate
aquatic hazard
(dodecylbenze
ne sulfonic
acid)
Environmental
warnings included;
proper disposal
emphasized to avoid
water system
contamination
SDS – Step 1 REACH
Annex XVII;
Directive
2008/98/EC
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Electrical Hazards
Hazard Tests /
Processes
Used
Mitigating
Factors
Matching
Compliance
Document
Relevant
Standards /
Guidelines
None – The product is
manually operated and
contains no powered or
electrical components. No
electrical hazard applies.
Product design
inspection;
technical
documentation
review
Not
applicable
EU Declaration of
Conformity –
Headlight
Restoration Wipes
Not applicable
Hygiene Hazards
Hazard Tests /
Processes
Used
Mitigating Factors Matching
Compliance
Document
Relevant
Standards /
Guidelines
Contamination
from reuse of
chemical
wipes
Usage
analysis; risk
assessment
Product is single-use
only; labeling states "DO
NOT REUSE"; sachet is
disposable with clear
instructions
Instruction Leaflet;
Sachet Labels
GPSR Annex I;
ISO
12100:2010
Cross-
contamination
risk during
handling
Handling
instructions
reviewed
Instructions advise use of
paper towel between
steps and washing hands
after use; PPE
recommended
Product
Instructions Leaflet;
SDS – Step 1 & 2
CLP
Regulation;
GPSR Annex I
Hand-to-mouth
or eye contact
after
application
Risk identified
in SDS;
foreseeable
misuse
assessment
Instructions emphasize
washing hands
thoroughly; GHS
pictograms reinforce risk
SDS – Step 1 & 2;
Sachet Labels
REACH; CLP;
ISO
12100:2010
Radiation Hazards
Hazard Tests /
Processes Used
Mitigating
Factors
Matching
Compliance
Document
Relevant
Standards /
Guidelines
None – The product does
not emit radiation and
contains no UV-emitting
components. The sealant
chemically cures under
ambient light.
Product material
review; chemical
curing process
evaluation
Not applicable SDS – Step 2;
EU Declaration
of Conformity
Not
applicable
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Summary
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.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Section 5 – Risk Classification
This section outlines the identified risks associated with the product, grouped into four categories based
on severity, and describes the control measures taken to mitigate those risks. Each risk includes
references to matching documentation and the exact warning that must be displayed on the product label
in order to comply with Regulation (EU) 2023/988.
Summary of Risk Categorization
1. 2. 3. 4. Critical Risks – Life-threatening hazards requiring strict control (e.g., choking, airway
obstruction, toxic chemical exposure).
Major Risks – Severe injuries or fire hazards mitigated through compliance and
testing (e.g., structural failure, sharp edges, high flammability).
Minor Risks – Low-severity concerns managed through design and labeling (e.g., mild skin
irritation, minor pinching hazards, dust accumulation).
Manufacturing Concerns – Production-related risks mitigated by quality control
measures (e.g., foreign objects, material inconsistencies)
Critical Risks (Life-threatening hazards requiring strict control measures)
Hazard/Risk Mitigation Measures Matching Compliance
Document(s)
Warning Required
on Labelling
None
identified
All foreseeable hazards are
controlled below critical level.
No life-threatening risk present
under normal or foreseeable
misuse.
EU Declaration of
Conformity; SDS – Step 1
& 2; GPSR Statement of
Compliance
N/A
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Major Risk (Significant injury/damage risks mitigated by testing & compliance)
Hazard/Risk Mitigation Measures Matching
Compliance
Document(s)
Warning Required on
Labelling
Misuse by
children
(chemical
exposure)
Product is labeled "18+";
packaging includes child
hazard icon; no toy-like
features
EU Declaration of
Conformity; SDS –
Step 1 & Step 2
⚠ WARNING: Keep out of
reach of children. For
adult use only.
Skin irritation
(Butoxyethanol,
Dodecylbenzen
e Sulfonic Acid)
Clear labeling with glove
instructions and first-aid
measures; use of gloves and
immediate washing after
exposure advised
Label includes glove
use instruction and
skin contact warning;
clear washing advice
provided
⚠ WARNING: Use with
gloves. Wash hands
thoroughly after use.
Eye irritation Consumer instructions
include eye contact warnings
and emergency guidance
SDS – Step 1 & Step
2
⚠ WARNING: Avoid
contact with eyes. Rinse
cautiously with water if
contact occurs.
Inhalation
exposure to
VOCs
Instructions require well-
ventilated area; short
application time reduces
exposure
SDS – Headlights
Cleaning Wipes Step
2
⚠ WARNING: Use in a
well-ventilated area. May
cause drowsiness or
dizziness.
Flammable
vapors from
Step 2 (Propan-
2-ol)
Flammable content <5%;
single-use sachet limits risk;
labeling includes ignition
source warning
SDS – Headlights
Cleaning Wipes Step
2
⚠ WARNING: Keep away
from heat, sparks, open
flames, and hot surfaces.
No smoking.
Minor Risks (Low-severity risks addressed through design & labeling
Hazard/Risk Mitigation Measures Matching
Compliance
Document(s)
Warning Required on
Labelling
Contamination from
improper re-use
Label states single-use
only; sachets are sealed;
no reapplication
GPSR Statement
of Compliance;
DoC
⚠ WARNING: Do not reuse.
For single-use application
only.
Aquatic toxicity –
Step 1 ingredients
Environmental disposal
precautions on label;
avoids drain release
SDS – Step 1 ⚠ WARNING: Do not pour
down the drain or into
waterways. Dispose of as
hazardous waste in
accordance with local
regulations.
Heat sensitivity –
applying sealant to
hot headlights
Instructions state
headlights must be cool
before use
Product
Instructions
Leaflet; Retail
Packaging
WARNING: Do not apply to
hot surfaces. Ensure
headlights are cool before
use.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Manufacturing Concerns (Risks mitigated by quality control measures)
Hazard/Risk Mitigation Measures Matching
Compliance
Document(s)
Warning Required on
Labelling
Potential exposure
due to defective
packaging or
improper seal
Manufacturer follows
GMP; sachets are sealed;
batch testing and recalls in
place
GPSR Statement of
Compliance
N/A – No consumer
warning required.
Residual chemical
exposure due to
inconsistent wipe
saturation
Internal batch QC;
formulation is standardised
with documented limits
SDS – Step 1 & 2;
GPSR Statement of
Compliance
N/A – No consumer
warning required.
Improper curing of
sealant layer
Instructions state to avoid
touching/washing
headlights for 30 minutes
and avoid car wash for 24
hours
Product Instructions
Leaflet
⚠ WARNING: Do not
touch or wash headlights
for 30 minutes after
application. Do not wash
car for 24 hours.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Summary of the Risk Control Strategy
The Headlight Restoration Wipes by Dandy Tech Inc have been assessed for all foreseeable hazards
under Regulation (EU) 2023/988. No critical (life-threatening) risks were identified. The most significant
hazards relate to chemical irritation, inhalation of flammable vapors, and misuse by children. These
risks have been mitigated through a combination of material selection, restricted age grading, controlled
packaging, and legally compliant labeling.
Design-level controls include:
• Single-use sachets to limit exposure and prevent improper reuse
• Clearly defined application sequence and aftercare instructions
• Low-volume formulation with reduced concentration of hazardous substances
• Child-inaccessible packaging and non-toy-like presentation to discourage misuse
Manufacturing-level controls are established through:
• Good Manufacturing Practice (GMP) protocols
• Sealed, batch-tested sachets to ensure chemical stability and consistency
• Internal monitoring procedures to manage recalls and ensure traceability
Labeling and instruction-based controls address user behavior:
• All warnings and symbols are compliant with Article 9 and Annex I of Regulation (EU) 2023/988
• Sachet and packaging labels include warnings for skin and eye irritation, flammability, VOC
inhalation, and disposal
• An instruction leaflet provides step-by-step usage guidance, safety precautions, and aftercare
• The product is clearly marked as not for use by children, with 18+ labeling and a child hazard
icon
Each hazard has been matched with a corresponding mitigation measure, supporting document, and an
exact on-label warning as required. The risk classification shows that no uncontrolled or unlabelled
hazard remains.
Conclusion:
All foreseeable hazards have been appropriately mitigated through product design, material control,
usage restrictions, and compliant consumer warnings. Residual risks are considered low and
acceptable when the product is used as intended. The product meets the general safety requirement
under Regulation (EU) 2023/988 and is suitable for placement on the EU market.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Section 6 – EU Labelling Requirements
In compliance with Article 9 of Regulation (EU) 2023/988, the following information must appear on the
product, packaging, or enclosed documentation:
1. Mandatory Labelling Requirements (GPSR)
• Manufacturer’s Name and Address
Dandy Tech Inc (DBA Clear Lights Tech / Headlight Restore US)
6213 Newcastle Ave,
Encino, CA 91316,
United States
Email: info@headlightrestore.us
Website: https://headlightrestore.us
Phone: +1 917-382-7123
• EU Responsible Person (Authorised Representative)
EaseCert | GPSR Compliance
Waldstr. 33,
54413 Damflos,
Germany
Email: compliance@easecert.com
Website: www.easecert.com
Phone: +49 170 5738 555
• Product Identification
Product name: Headlight Restoration Wipes
Model Number: 1.HDL.21208 (2-Step Kit)
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
• Traceability Format
The manufacturer, product name, batch number, and warnings appear on:
• Each individual sachet
• The outer retail box
• The enclosed instruction leaflet
• Age Warning
⚠ WARNING: Keep out of reach of children. For adult use only (18+).
• CE Marking
Not applicable
2. General Required Markings
• Recycling and Disposal Symbols
♳ PP – Sachets (Polypropylene film)
♻ General recycling symbol – Outer carton (paperboard)
Do Not Reuse symbol (ISO 7000-1135): Indicates that the wipes are single-use only. Prevents improper
storage and reuse that could lead to safety issues.
• Material and Handling Icons
• Ventilation required
• Flammable content (Step 2)
• Keep dry
• Do Not Reuse
• Country of Origin
Made in USA
• Language Requirements
All mandatory safety information and warnings must be printed in the official language(s) of each EU
Member State where the product is sold. At minimum: English, French, German, Spanish, and Italian.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
3: Product-Specific Markings and Warnings
• ⚠ WARNING: Keep out of reach of children. For adult use only.
• ⚠ WARNING: Use with gloves. Wash hands thoroughly after use.
• ⚠ WARNING: Avoid contact with eyes. Rinse cautiously with water if contact occurs.
• ⚠ WARNING: Use in a well-ventilated area. May cause drowsiness or dizziness.
• ⚠ WARNING: Keep away from heat, sparks, open flames, and hot surfaces. No smoking.
• ⚠ WARNING: Do not reuse. For single-use application only.
• ⚠ WARNING: Do not pour down the drain or into waterways. Dispose of as hazardous waste in
accordance with local regulations.
• ⚠ WARNING: Do not apply to hot surfaces. Ensure headlights are cool before use.
• ⚠ WARNING: Do not touch or wash headlights for 30 minutes after application. Do not wash car
for 24 hours
4: GPSR Compliance – Hierarchy for Markings
Markings must be placed in the following order of preference:
1. 2. 3. On the Product (e.g., printed labels, engravings).
On the Packaging (e.g., via sticker or printed).
In an Accompanying Document (if neither product nor packaging can accommodate the
required information).
Durability: Markings must remain clear and legible throughout the product's use and handling.
When the product cannot bear all required markings (e.g. due to size or shape), information may appear
on the packaging or documentation, but safety-related warnings must remain visible at the point of sale.
For multi-language markets, labeling must be localized accordingly. Dual or multilingual labeling is
acceptable, provided it is clear and legible.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
Section 7 – Conclusion
The GPSR Risk Analysis for the Headlight Restoration Wipes has been completed and reviewed in
accordance with the requirements of Regulation (EU) 2023/988 – General Product Safety Regulation.
This assessment confirms that the product has been evaluated for all foreseeable risks, including
chemical exposure, flammability, misuse, hygiene concerns, and environmental impact.
Supporting documentation includes the Declaration of Conformity, Safety Data Sheets, Statement of
Compliance, technical usage instructions, product labels, and packaging materials. These documents
collectively demonstrate that the product has been manufactured using appropriate safety controls and
that consumer risks have been clearly communicated through compliant labeling and handling
instructions.
All hazards have been classified and addressed with corresponding mitigation measures. The product
includes appropriate warnings and meets the traceability, labeling, and safety information obligations
under Article 9 and Annex I of Regulation (EU) 2023/988.
Based on the results of this assessment, the product is considered safe under normal and reasonably
foreseeable conditions of use, and compliant with the applicable requirements of EU product safety
legislation.
Created by: EaseCert | GPSR Compliance
Date: 8 August 2025
Legal Disclaimer: EaseCert’s documents are intended as guidance only and are based on the
manufacturer's input. They are not legal advice and do not replace or supersede a manufacturer's
obligations to comply with all applicable GPSR requirements. The manufacturer or importer is ultimately
responsible for ensuring compliance with GPSR requirements for products sold in the European Union. The
guidance provided by EaseCert is for general informational purposes only to assist with GPSR compliance.
If the manufacturer's responses do not accurately reflect the applicable facts and circumstances, the
information provided by EaseCert may be incomplete or inaccurate. EaseCert does not provide legal
advice. Manufacturers should not rely on EaseCert’s information as legal conclusions or as guidance from
any regulatory authority or enforcement body. The information provided is not guaranteed to reflect the
most current legal, enforcement, compliance, or regulatory developments. No information conveyed by
EaseCert - whether through its website, documents, or other materials - should be used as a substitute for
legal counsel regarding regulatory requirements. No documents or information generated by EaseCert
(including certifications, assessments, conclusions, references, or recommendations) are binding on any
regulatory authority or enforcement body, nor do they carry any legal effect.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
All 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
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
(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.
8. 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.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
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.
15. 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.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
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.
25. 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.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025General Product Safety Regulation (GPSR) Risk Analysis
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.
EU/2023/988 General Product Safety Regulation | Risk Analysis | August 2025