What documents must a Responsible Person keep on file?

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Jason van de Zande

A GPSR responsible person must be able to provide market surveillance authorities with the key product safety and traceability documents for the consumer products it covers. In practice, that means keeping clear identification details, product identifiers and supply chain traceability records, safety information and instructions, and evidence that the product is safe under reasonably foreseeable use. The exact file depends on the product and any other applicable EU laws.

What documents must a GPSR Responsible Person keep on file?

Under the General Product Safety Regulation (EU) 2023/988 (GPSR), the responsible person is an EU-established economic operator that supports compliance and cooperates with authorities. It must be able to provide, on request, the information and documentation needed to demonstrate product safety and compliance, with the exact contents depending on the product and any applicable harmonisation legislation.

  • Identification and contact details: the responsible person’s name, postal address, and electronic contact details, plus the manufacturer’s identification details as shown on the product or packaging.
  • Product identification and traceability: model, type, batch or serial number, product photos, label artwork, and records that help trace suppliers and the economic operators to whom the product was supplied.
  • Safety information and instructions: user instructions, warnings, and any safety information required for safe use, in the language(s) required for the target EU markets.
  • Risk assessment and safety evidence: the manufacturer’s internal risk analysis, test reports or other evidence supporting safety, and records of complaints, known accidents, and corrective measures, where relevant.
  • Technical documentation under other EU rules: where CE marking or other harmonisation legislation applies, keep the relevant technical file elements required by that legislation (for example, design information, standards applied, and conformity assessment outputs).

Actionable tip: keep a one-page “product identifier map” that links every marketplace listing identifier to the exact model number used on labels, manuals, and test reports, since mismatches are a common reason for document rejections.

How long must Responsible Person documentation be retained and in what format?

Documentation should be retained for the period required by the GPSR and any product-specific EU legislation, and it must be available promptly to authorities in a language they can understand. There is no single universal retention period across all products, so you must check the rules that apply to your product category and your role in the supply chain.

Common retention expectations found across EU product rules include:

  • Longer retention for technical documentation and safety evidence, often specified as up to 10 years under certain harmonised product legislation.
  • Traceability records may have different, sometimes shorter, legally specified retention periods in some frameworks.

Practical format guidance:

  • Use secure digital storage with a clear folder structure per product and per model.
  • Apply version control for labels, manuals, and test reports, and archive superseded versions.
  • Store documents so they are accessible in the EU and can be exported quickly as a complete package.
  • Maintain language-ready copies of instructions and warnings for each target Member State, where required.

What happens if the Responsible Person cannot provide the required documents?

If the responsible person cannot provide the required documentation, authorities can treat the product as potentially non-compliant and escalate enforcement. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), market surveillance authorities can request information, set deadlines, and require corrective actions. Outcomes depend on the product, the risk, and national enforcement practice.

  • Requests for information and formal deadlines to supply missing documents.
  • Orders to bring documentation, labelling, or instructions into compliance.
  • Measures such as withdrawal from the market, recall, or sales restrictions if safety cannot be demonstrated.
  • Potential penalties under national law for non-compliance.

Marketplaces may also restrict or delist offers if responsible person details or supporting documentation are missing, especially when platform compliance workflows flag identifier mismatches or incomplete safety files.

MSR nuance: the responsible person must notify the manufacturer if there is reason to believe a product presents a risk, but notifying authorities about serious risks is not the responsible person’s task in the same way it is for an authorised representative acting under its mandate.

How EARP helps with Responsible Person document management for GPSR compliance

We help non-EU manufacturers and sellers keep responsible person documentation organised, complete, and ready to provide to authorities when requested, with processes built around GPSR and MSR expectations.

  • Provide product-specific document checklists aligned to the GPSR and applicable EU harmonisation legislation.
  • Review submissions for completeness and identifier consistency across labels, manuals, listings, and test evidence.
  • Maintain secure EU-based document storage with structured folders and controlled access.
  • Support prompt, accurate responses to market surveillance authority requests, acting as the liaison channel.
  • Help maintain change control when you update labels, instructions, or product variants.

See our services for Responsible Person support, or contact us to discuss what documentation your specific products must have on file.

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