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Guide

GPSR Technical Documentation: What to Keep and for How Long

GPSR

The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024, and it changed what a consumer-facing business is expected to hold on file. At its core the GPSR requires that products are safe, that you have carried out a risk analysis, and that you keep technical documentation demonstrating the product conforms to the safety requirement. This guide explains what that documentation should contain, who has to keep it, and how long it needs to be available.

Why technical documentation exists

The GPSR is a safety backstop for consumer products. Rather than trusting a bare assertion that “this product is safe”, the Regulation asks you to be able to show your working. Technical documentation is that evidence trail: it records what the product is, what hazards it could present, how you assessed those hazards, and what you did to keep the product within the general safety requirement. If a market-surveillance authority asks, you should be able to hand over a file that answers the question “how do you know this is safe?”.

The risk analysis at the heart of the file

The single most important element is the risk analysis. This is a structured look at how the product could foreseeably be used, and misused, and what could go wrong. A workable risk analysis usually walks through a few clear steps.

  • Describe the product and its intended use, including the consumers likely to use it, such as children or older people.
  • Identify the hazards: mechanical, chemical, electrical, thermal, choking, flammability, and any others relevant to the product.
  • Assess the likelihood and severity of harm for each hazard, including reasonably foreseeable misuse.
  • Record the measures you took to remove or reduce each risk, such as design changes, warnings, or instructions.

The risk analysis is not a one-off tick-box. It is the reasoning that justifies every other claim in the file, so it should be legible to someone who has never seen the product before.

What the documentation should contain

Beyond the risk analysis, a technical documentation file for a consumer product typically gathers the evidence that supports it. Aim to include the following, adapted to the product.

  • A clear description and identification of the product, including model, batch, or serial references.
  • Photographs or drawings that let an authority recognise the exact product placed on the market.
  • The risk analysis and its conclusions.
  • Any test reports, certificates, or references to the standards you relied on to judge safety.
  • The warnings, safety information, and instructions supplied with the product.
  • Details of the manufacturer and of the responsible person established in the EU.

Keep the file proportionate. A simple, low-risk item does not need the same volume of evidence as a complex powered product, but the reasoning must always be there.

Who must keep it

The GPSR ties the documentation to a responsible person established in the European Union. For products sold into the EU, there must be an economic operator, such as the manufacturer, an authorised representative, an importer, or in some cases a fulfilment service provider, who can be contacted about safety and who ensures the technical documentation exists and is available. If you sell into the EU from outside it, identifying and naming this responsible person is one of the first practical steps to compliance.

Keeping it available for authorities

Holding the file is not enough on its own; it has to be available to market-surveillance authorities on request. In practice that means the responsible person keeps the technical documentation for a defined period after the product is placed on the market and can produce it, in a language the authority can work with, within a reasonable time. Store it so that you can retrieve the right version for the right batch, because a request may arrive long after a particular product first went on sale.

How this differs from CE marking

It is easy to assume that if a product carries CE marking, the safety question is settled. It is not. CE marking shows conformity with specific EU product legislation, such as toy safety or electrical and electromagnetic-compatibility rules, and comes with its own technical file. The GPSR sits underneath all of that as a general safety backstop for consumer products, whether or not they need CE marking. A CE-marked toy still falls within the spirit of general product safety; a product that needs no CE marking at all still needs to be safe and to have a risk analysis behind it.

Practical habits that pay off

  • Start the file when you start sourcing a product, not after a complaint arrives.
  • Version and date every document so you can prove what was true at the time of sale.
  • Link each product listing to its file, so a request can be answered quickly.
  • Review the risk analysis whenever you change a supplier, a component, or the product itself.

For the wider picture, see our complete GPSR guide and the background on the GPSR. If you are weighing GPSR against CE, read GPSR versus CE marking and the entry on CE marking. Our compliance tools can help you keep track of what you hold.

This article is educational and does not constitute legal advice.