Does my Responsible Person create my technical documentation or do I?

A GPSR responsible person does not usually create your technical documentation; the manufacturer does. Under the General Product Safety Regulation (EU) 2023/988 (GPSR), the responsible person is an EU-based economic operator that helps ensure required safety information and documents are available in the EU and can be provided to authorities on request. This article explains what the responsible person must do, what remains with the manufacturer, and how to organise a GPSR technical file.

What is the GPSR Responsible Person, and what are their documentation duties?

The GPSR responsible person is an EU-established economic operator designated to carry out specific compliance support tasks for products placed on the EU market by a non-EU manufacturer. The responsible person is not the same as the manufacturer, importer, or distributor, and is not automatically the author of the technical documentation unless you agree to that by contract.

In practice, documentation-related duties focus on availability and cooperation. The responsible person should be able to:

Verify that the manufacturer has drawn up the required technical documentation.
Ensure the documentation can be made available to market surveillance authorities when requested, in a language the authority can understand.
Cooperate with authorities during checks and follow-up actions.

Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the responsible person must also inform the manufacturer if there is reason to believe a product presents a risk.

Who must create and maintain the technical documentation: the manufacturer or the Responsible Person?

The manufacturer is typically responsible for creating and maintaining the technical documentation and for ensuring the product is safe and compliant before it is placed on the market. The responsible person’s role is usually to ensure the documentation is accessible in the EU and can be provided to authorities—not to design the product, conduct the risk assessment, or “make it compliant” on the manufacturer’s behalf.

What you can delegate by written agreement often includes practical tasks such as compiling files, checking for completeness, keeping copies, and managing secure storage and retrieval. What you cannot delegate is the manufacturer’s legal responsibility for product safety and for the accuracy of the technical documentation.

Also consider the legal framework that applies to your product. For CE-marked products under EU harmonisation legislation, the technical documentation requirements come mainly from the relevant directive or regulation. The GPSR is a horizontal safety framework that applies broadly, including to many non-harmonised consumer products.

What should be included in technical documentation for GPSR, and how should it be organised?

GPSR technical documentation should show why the product is safe under reasonably foreseeable conditions of use and misuse, and it should be easy to retrieve quickly if an authority asks. A single file per model is often workable, but variants that change safety-relevant characteristics may need separate documentation.

Practical GPSR technical documentation checklist

Product identification: model, type, batch or serial approach, photos of the product and label, and SKU or listing mapping if you sell online.
Product description: intended use, user groups, age suitability where relevant, and key safety-relevant characteristics.
Design and manufacturing information: materials, critical components, and manufacturing controls that affect safety.
Risk assessment: hazards, foreseeable misuse, vulnerable consumers, and risk-reduction measures.
Testing and standards: test reports, methods used, and standards applied (note if partially applied).
Instructions and safety information: warnings, safe use, disposal, and translations for the Member States where you sell.
Traceability and contacts: manufacturer details, supply chain contacts, and responsible person details as shown on the product or packaging.
Complaints and accidents: internal log, investigation notes, and trend monitoring.
Corrective actions: records of withdrawals, recalls, consumer communications, and effectiveness checks.

Organisation tips that prevent delays

Use version control, with dates and clear ownership for each document.
Keep label artwork, manuals, and listings consistent, using the same brand and model identifiers.
Store files in a structured folder system so you can export a complete “authority pack” quickly.

How can EARP help with GPSR Responsible Person and technical documentation support?

We help you meet GPSR responsible person requirements by acting as your EU-based responsible person and by putting practical documentation processes in place so you can respond quickly to market surveillance requests.

We act as your GPSR responsible person, serving as an EU contact point for authorities.
We perform documentation presence and completeness checks against GPSR expectations.
We provide secure technical documentation storage and controlled access.
We support rapid retrieval and submission of documentation when authorities request it.
We guide you on what documents are needed for your product and how to keep identifiers consistent.

See our GPSR services, or contact us to discuss your product and the documentation you already have.