Do all products under the GPSR need technical documentation?

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Jason van de Zande

Most products covered by the General Product Safety Regulation (EU) 2023/988 (GPSR) need some form of safety documentation, but not every product needs the same “technical file.” The key rule is that economic operators must be able to demonstrate product safety and provide safety information to authorities on request. What you keep depends on the product’s risks and any additional EU rules that apply, such as CE-marking legislation.

Do all products covered by the GPSR need technical documentation?

Yes, in principle, because the GPSR expects manufacturers to be able to show how they ensured the product is safe, but the depth and format are product- and risk-dependent. The GPSR does not impose a single harmonized “technical file” template for every consumer product, but it does require you to have safety-relevant information available and kept up to date.

The GPSR applies broadly to consumer products, including many physical products and also certain non-tangible items such as software, apps, and chatbots, when offered to consumers. It also covers new, used, repaired, reconditioned, and refurbished products, with limited exclusions for specific sectors.

The GPSR also acts as a safety net. If a product is covered by specific EU harmonisation legislation (for example, a CE-marking regime), that legislation can impose its own technical documentation requirements, and the GPSR applies only to aspects and risks not already covered. In practice, many businesses maintain one documentation set per product model and then add variant-specific documents when differences affect safety.

What counts as “technical documentation” under the GPSR?

Under the GPSR, “technical documentation” is the set of documents and records that let you identify the product, trace it, and explain your safety assessment and controls. It should be proportionate to the product’s characteristics and risks, and it should be maintained so it matches the product actually being sold.

Common elements include:

  • Product identification: model, type, batch or serial identifiers, and a clear product description.
  • Manufacturer details: name, registered trade name or trademark, postal address, and electronic address.
  • Risk assessment: an internal analysis of foreseeable hazards, misuse, vulnerable users, and risk controls.
  • Evidence supporting safety: test reports or certificates where relevant, and a list of standards applied (including partial application, if applicable).
  • Instructions and safety information: warnings, safe use, and disposal information in languages required for the markets supplied.
  • Complaints and accident records: what was reported, how it was assessed, and what actions followed.
  • Corrective actions and recalls: decision records, consumer communications, and implementation tracking.
  • Traceability and supply chain data: who supplied what, when, and how affected units can be identified.

The documentation can be electronic and can consist of multiple documents. The important point is that it is complete enough to explain why the product is safe under normal or reasonably foreseeable conditions of use.

When can authorities ask for documentation and how fast must it be provided?

Authorities can ask for GPSR documentation whenever they perform market surveillance, including checks triggered by consumer complaints, product characteristics, or online offer monitoring. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), authorities have powers to request information and assess compliance, and they expect economic operators to provide it promptly and in a usable form.

Requests can arise from border controls, in-market inspections, or online marketplace reviews that look for basic, verifiable indicators such as traceability, consistent identifiers, and the presence of required safety information. Do not assume a request only happens after an accident or a recall.

To respond quickly without scrambling, set up:

  • Document control: versioning, approval dates, and a clear “current version” per model and variant.
  • Retention and accessibility: keep records organized so they can be shared without delay.
  • Language readiness: ensure key safety information can be understood in the Member State concerned, where required.

How EARP helps with GPSR technical documentation readiness

We help non-EU manufacturers, brands, and sellers get ready to answer GPSR documentation requests and meet EU Responsible Person obligations without building an in-house EU compliance function. Our support is practical, document-focused, and designed for fast operational readiness.

  • Documentation gap checks against GPSR expectations and the product risk profile
  • Tailored document lists per product type, sales channel, and foreseeable use
  • Secure documentation storage and controlled availability for authority requests
  • Liaison support with market surveillance authorities when documentation is requested
  • Process setup for version control, traceability, and complaint and accident handling records

Review our GPSR services, or contact us to discuss what documentation you should have ready for your specific products.

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