GPSR Compliance

REDKEY USB LTD
GPSR COMPLIANCE POLICY
GENERAL PRODUCT SAFETY REGULATION (EU) 2023/988

Version: 9.0 (March 2026)
Effective Date: 11 March 2026
Previous Version: 8.0 (superseded in full)

OVERVIEW

This Policy sets out Redkey USB Ltd's compliance with the EU General Product Safety Regulation (GPSR) (EU) 2023/988. This Policy provides product safety and regulatory information required under GPSR for products sold by Redkey USB Ltd in the European Union.

This Policy forms part of our Terms of Service.

SECTION 1: REGULATORY FRAMEWORK

1.1 Purpose

The General Product Safety Regulation (GPSR) ensures that products placed on the EU market are safe. This Policy demonstrates our compliance with GPSR requirements and provides the information required under Articles 9 and 10 of the Regulation.

1.2 Scope

This Policy applies to all products sold by Redkey USB Ltd in the European Union including:
(a) electronics-based USB devices;
(b) electronics-based accessories; and
(c) paper-based products.

1.3 Applicable Legislation

Our products comply with the following EU regulations:
(a) General Product Safety Regulation (EU) 2023/988 (GPSR);
(b) Low Voltage Directive (LVD) 2014/35/EU;
(c) Electromagnetic Compatibility (EMC) Directive 2014/30/EU;
(d) Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU;
(e) REACH Regulation (EC) No 1907/2006 (Chemical Safety); and
(f) Waste Electrical and Electronic Equipment (WEEE) Directive 2012/19/EU.

SECTION 2: MANUFACTURER INFORMATION

2.1 Manufacturer Details

Manufacturer Name: Redkey USB Ltd
Company Registration Number: 11257207 (England and Wales)
Registered Office: 128 City Road, London, EC1V 2NX, United Kingdom

2.2 Contact Information

For general product questions, safety concerns, returns, or support:
Email: contact@redkeyusb.com
Website: https://redkeyusb.com/contact

2.3 Product Identification

All Redkey USB products are marked with:
(a) manufacturer name or trade mark;
(b) product model or serial number;
(c) CE marking (where applicable);
(d) WEEE symbol (for electronic products); and
(e) safety warnings and instructions (where applicable).

SECTION 3: EU AUTHORISED REPRESENTATIVE

3.1 Appointment

Redkey USB Ltd has appointed an EU Authorised Representative as required under GPSR for market surveillance authority contact.

3.2 Representative Details

Name: Easy Access System Europe OÜ
Registration Number: 16879218
Address: Mustamäe tee 50, 10621 Tallinn, Estonia
Contact: gpsr.requests@easproject.com
Telephone: +372 56 968 939

3.3 Purpose

The EU Authorised Representative is designated for:
(a) market surveillance authority communications;
(b) serious product safety matters; and
(c) regulatory compliance verification.

3.4 Customer Inquiries

Customers should contact Redkey USB Ltd directly for general inquiries. The EU Authorised Representative is intended for authority contact only.

SECTION 4: PRODUCT CATEGORIES

4.1 Electronics-Based USB Devices

Description: Electronic data storage and execution devices equipped with USB connectors, intended for use with personal computers and compatible digital systems.

Product Types:
(a) general-purpose USB flash drives for file storage and transfer;
(b) bootable USB devices pre-loaded with proprietary software; and
(c) Redkey USB data erasure devices containing secure wiping software.

Technical Specifications: printed circuit board (PCB) with non-volatile memory (NAND flash); USB controller and supporting circuitry; USB Type-A or Type-C connector; plastic or metal housing; and pre-configured executable code for bootable devices.

Applicable Standards: EN 55032 (electromagnetic compatibility of multimedia equipment); EN 55035 (electromagnetic compatibility - immunity); EN 60950-1 / EN 62368-1 (safety of electrical and electronic equipment); and EN 50581 (technical documentation for RoHS assessment).

Testing and Certification: EMC testing performed in accordance with Directive 2014/30/EU; Certificates: ATJC21082580004700E, ATJC21090980002700E, ATJC21091680004200E, ATJC21091680004300E; RoHS testing performed in accordance with Directive 2011/65/EU; Certificates: ATJC21082580004700R, ATJC21090980002700R, ATJC21091680004200R, ATJC21091680004300R; and FCC compliance testing (supporting EMC evidence); Certificates: ATJC21082580004700F, ATJC21090980002700F, ATJC21091680004200F, ATJC21091680004300F.

Public Page - Electronics-Based USB Devices

4.2 Electronics-Based Accessories

Description: Consumer electronic accessories designed to provide multi-format charging and data transfer capabilities for smartphones and compatible devices.

Product Types: multi-format charging cables (e.g., 4-in-1 cables); USB-C, Lightning, and Micro-USB connectors; and data transfer and charging capabilities.

Technical Specifications: insulated materials (TPE, PVC, or braided nylon); metal connector heads; internal conductive wiring; strain relief features; and low-voltage consumer use design.

Applicable Standards: EN 62368-1 (safety of electrical and electronic equipment); and EN 50581 (technical documentation for RoHS assessment).

Testing and Certification: product classification and intended low-voltage consumer use; and compliance with applicable safety directives.

Public Page - Electronics-Based Accessories

4.3 Paper-Based Products

Description: Printed adhesive labels made from paper-based materials for informational or compliance marking.

Product Types: "Data Wiped" stickers; bulk packs (100, 1000, or 5000 units); and adhesive labels for device or packaging marking.

Technical Specifications: paper-based materials; adhesive backing; and printed text and graphics.

Applicable Standards: REACH Regulation compliance for chemical safety; and General Product Safety Regulation.

Testing and Certification: material safety assessment; and chemical composition verification.

Public Page - Paper-Based Products

SECTION 5: PRODUCT SAFETY INFORMATION

5.1 Intended Use

Redkey USB products are designed for:
(a) secure data erasure from storage devices;
(b) file storage and transfer (general USB devices);
(c) device charging and data transfer (accessories); and
(d) compliance marking (paper-based products).

5.2 Safe Use Instructions

For Electronics-Based USB Devices: use only with compatible computer systems; do not expose to extreme temperatures; do not disassemble or modify; keep away from moisture and liquids; follow software instructions carefully; and be aware that data destruction is permanent and irreversible.

For Electronics-Based Accessories: use only with compatible devices; do not use if damaged; disconnect when not in use; and keep away from moisture and liquids.

5.3 Warnings

Data Destruction: Redkey USB data erasure devices permanently destroy data. This process is irreversible.

Power Interruption: Do not remove device during active data destruction.

Compatibility: Ensure device compatibility before use.

Backup: Back up any data you wish to preserve before using data erasure functions.

5.4 Age Restrictions

Products are not intended for children under 16 years of age without adult supervision.

SECTION 6: RISK ASSESSMENT

6.1 Risk Identification

We have conducted risk assessments for all product categories, identifying:
(a) electrical safety risks (short circuit, overheating);
(b) electromagnetic compatibility risks;
(c) chemical safety risks (hazardous substances);
(d) mechanical risks (physical damage); and
(e) data security risks (unintended data loss).

6.2 Risk Mitigation

We mitigate identified risks through:
(a) design and manufacturing controls;
(b) compliance testing and certification;
(c) clear user instructions and warnings;
(d) quality control procedures; and
(e) ongoing product monitoring.

6.3 Incident Reporting

If you experience a product safety incident:
(a) stop using the product immediately;
(b) contact us at contact@redkeyusb.com;
(c) provide details of the incident; and
(d) retain the product for investigation if requested.

SECTION 7: TECHNICAL DOCUMENTATION

7.1 Technical File

We maintain technical documentation for each product category including:
(a) product design and manufacturing specifications;
(b) risk assessment reports;
(c) test reports and certificates;
(d) user instructions and safety information; and
(e) Declaration of Conformity.

7.2 Declaration of Conformity

Declarations of Conformity are available upon request from contact@redkeyusb.com.

7.3 Certificate Availability

Test certificates and reports referenced in this Policy are available for inspection by market surveillance authorities upon request.

SECTION 8: MARKET SURVEILLANCE

8.1 Cooperation with Authorities

We cooperate fully with market surveillance authorities in EU Member States to ensure ongoing compliance with GPSR and other applicable regulations.

8.2 Information Provision

We provide authorities with:
(a) technical documentation;
(b) test reports and certificates;
(c) risk assessment information; and
(d) incident reports (where applicable).

8.3 Corrective Actions

If a product safety issue is identified:
(a) we will investigate promptly;
(b) we will implement corrective actions as required;
(c) we will notify affected customers where necessary; and
(d) we will report to authorities as required by law.

SECTION 9: PRODUCT RECALL PROCEDURE

9.1 Recall Triggers

We will initiate a product recall if:
(a) we become aware that a product poses a serious risk to the health or safety of consumers;
(b) a market surveillance authority orders a recall; or
(c) we determine that a recall is necessary to comply with our obligations under GPSR.

9.2 Recall Procedure

In the event of a recall:
(a) we will immediately stop distribution of the affected product;
(b) we will notify the relevant market surveillance authorities within the timeframe required by GPSR;
(c) we will publish a recall notice on our Website and through other appropriate channels;
(d) we will contact affected customers directly where we have contact information; and
(e) we will provide remedy options including repair, replacement, or refund.

9.3 Customer Action

If you become aware of a safety issue or are notified of a recall:
(a) stop using the product immediately;
(b) follow the instructions in the recall notice;
(c) contact us at contact@redkeyusb.com for further guidance; and
(d) return the product as instructed for remedy.

SECTION 10: PRODUCT TRACEABILITY

10.1 Batch Identification

Products are marked with:
(a) serial numbers for individual device identification;
(b) batch codes where applicable; and
(c) manufacturing date information.

10.2 Supply Chain Records

We maintain records of:
(a) component suppliers;
(b) manufacturing batches;
(c) distribution channels; and
(d) customer sales (where registered).

SECTION 11: WEEE AND ENVIRONMENTAL COMPLIANCE

11.1 WEEE Directive

Electronic products are marked with the WEEE symbol indicating:
(a) separate collection requirement;
(b) no disposal with household waste; and
(c) recycling and recovery obligations.

11.2 Battery Compliance

Products containing batteries comply with:
(a) Battery Directive 2006/66/EC;
(b) registration and reporting requirements; and
(c) safe handling and disposal instructions.

11.3 Packaging Compliance

Packaging materials comply with:
(a) Packaging and Packaging Waste Directive 94/62/EC;
(b) recycling and recovery requirements; and
(c) essential requirements for packaging safety.

SECTION 12: CHANGES TO THIS POLICY

We may update this Policy to reflect:
(a) changes in applicable legislation;
(b) new product introductions;
(c) updated testing or certification; or
(d) changes to our EU Authorised Representative.

The latest version is available at https://redkeyusb.com/pages/gpsr-compliance

SECTION 13: CONTACT INFORMATION

For product safety questions, compliance inquiries, or technical documentation:

Redkey USB Ltd
Email: contact@redkeyusb.com
Website: https://redkeyusb.com/contact

For market surveillance authority contact:
Easy Access System Europe OÜ
gpsr.requests@easproject.com
+372 56 968 939

This GPSR Compliance Policy forms part of our Terms of Service.

Document Version: 9.0 (March 2026)
Last Updated: 11 March 2026
Next Review Date: March 2027

Copyright (c) Redkey USB Ltd. All rights reserved.