How detailed does my GPSR technical documentation need to be for a low-risk product?

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Jason van de Zande

For a low-risk consumer product, your GPSR technical documentation should be proportionate: detailed enough to show why the product is safe under normal and reasonably foreseeable use, but not a full engineering dossier if the risks are simple and well controlled. Under the General Product Safety Regulation (EU) 2023/988 (GPSR), you must be able to provide this documentation to authorities on request and keep it aligned with the exact product you place on the EU market.

What does the GPSR require in technical documentation for low-risk products?

The GPSR requires manufacturers to prepare technical documentation that demonstrates product safety and to keep it available for market surveillance authorities on request. The level of detail should be proportionate to the product’s risks and complexity, so a low-risk product can usually be supported by a simpler file than a higher-risk product.

The documentation must be drawn up before the product is placed on the market and kept for 10 years. It can be electronic and made up of multiple documents. The GPSR applies broadly to consumer products, including products offered online, and it can apply alongside other EU harmonisation legislation. If a product is covered by a specific EU harmonisation act (for example, for electrical products or toys), that legislation can add technical file requirements, and the GPSR still applies to any risks not covered by the specific rules.

What should a proportionate GPSR technical file include for a low-risk product?

A proportionate GPSR technical file for a low-risk product should allow an authority to quickly identify the product, understand how it is used, see the main hazards considered, and review the evidence that the risks are controlled. It should be consistent with the product listing, labelling, and the units actually shipped.

  • Product identification and traceability: model name/number, type, batch or serial method, photos, and variant list (separate files if variants change safety-relevant features).
  • Description and intended use: what it is, who it is for, where it is used, and any clear limits of use.
  • Risk assessment and controls: main hazards, foreseeable misuse, and the design or labelling measures that reduce risk.
  • Standards or specifications used: list any relevant EU or international standards applied, noting partial application where relevant.
  • Test reports or other safety evidence: targeted tests, supplier material declarations, or checks that support key safety claims.
  • Instructions and safety information: user instructions and warnings needed for safe use, in the languages required for the Member States where you sell.
  • Labelling and packaging details: artwork, label photos, and required economic operator contact details, as applicable.
  • Complaint and accident monitoring: how you capture, review, and act on safety complaints and accidents.
  • Supply chain traceability: manufacturer site details, key suppliers, and records that allow you to trace affected batches.

How do I decide the right level of detail without over-documenting?

Use a simple risk-based method: document what could go wrong, how likely it is, how severe the harm could be, and what you did to prevent it. For low-risk products, the goal is clear reasoning plus credible evidence, not volume. If you can explain the safety logic in a few pages and back it with focused proof, that is often sufficient.

  1. Define intended use and reasonably foreseeable misuse.
  2. Identify hazards (mechanical, chemical, flammability, choking, electrical, cybersecurity where relevant).
  3. Evaluate risk severity and likelihood, then choose controls (design changes first, then guards, then warnings).
  4. Match evidence depth to risk: lightweight checks for minor risks, deeper testing where harm could be serious.

Example of “lightweight but sufficient” for a low-risk household item: a short risk assessment, material declarations for restricted substances where relevant, basic mechanical checks, and clear instructions. More testing or deeper analysis is warranted if the product targets vulnerable users (such as children), has heating or electrical functions, includes batteries, or if complaints or accidents suggest a new hazard.

Update your file when you change the design, materials, suppliers, labelling, or instructions; when new complaints or accidents arise; or when new hazards or regulatory expectations become relevant.

How does EARP help with GPSR technical documentation and Responsible Person requirements?

We help you build and maintain proportionate GPSR documentation and meet EU Responsible Person obligations in a practical, audit-ready way, including making documentation available to authorities on request and supporting ongoing updates.

  • Technical documentation gap checks and completeness reviews
  • Guidance on what “proportionate” means for your specific product and risk profile
  • Secure documentation storage and controlled retrieval for authority requests
  • EU Responsible Person services aligned with the GPSR and Market Surveillance Regulation (EU) 2019/1020 (MSR) requirements
  • Process support for change control, complaints, and accident monitoring documentation

See our GPSR compliance services, or contact us to discuss what your low-risk product technical file should contain.

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