GPSR technical documentation: what, how long, where
9 min readRepresenta GmbH
GPSR technical documentation under Article 9: what the file contains, when the 10 years start, who keeps it in the EU and how it differs from a CE file.
Every consumer product covered by the General Product Safety Regulation (EU) 2023/988 needs GPSR technical documentation before it reaches the EU market. Article 9 sets the minimum content and a 10-year retention period, but not the format or the place. Here is what belongs in the file, when the 10 years start, who must produce it and how it differs from a CE technical file.
What GPSR technical documentation is, and what it is not
Under Article 9(2) GPSR (opens in a new tab), manufacturers carry out an internal risk analysis and draw up technical documentation before placing a product on the market. It holds the information that proves the product is safe, in a depth proportionate to its complexity and risks (recital 33).
The GPSR requires neither a Declaration of Conformity nor CE marking. For CE-marked products, Article 9 does not apply (Article 2(1)(b) GPSR); the sector act's technical file takes its place.
What the file must contain
Every file contains a general description of the product and its essential characteristics relevant for assessing its safety (Article 9(2) GPSR). Where the possible risks call for it, the file adds:
- an analysis of the possible risks and the solutions adopted, including test results (point (a));
- the European standards or other elements applied, and which parts, where only partly applied (point (b)).
Without a relevant European standard, the Commission's GPSR guidelines expect a list of national safety requirements, where available, or of the other methods used. Their optional model template has three parts: identification, characteristics and composition, and each risk with its measures. Our GPSR risk assessment article turns it into a checklist with legal bases.
A GPSR technical documentation example: the file index
The law sets the content, not the structure. This index covers the minimum and what your EU partners need:
| Part | Content | Basis |
|---|---|---|
| 1. Identification | Brand, name, type, batch or serial number, pictures of product and packaging | Art. 9(2) and (5); template, point 1 |
| 2. Description | Product description, materials, composition, safety-relevant characteristics | Art. 9(2); template, points 1 and 2 |
| 3. Risk analysis | Each risk with the measure taken against it | Art. 9(2)(a); template, point 3 |
| 4. Evidence | Test reports; drawings, supplier declarations | Art. 9(2)(a) for test reports; the rest recommended |
| 5. Standards | References with edition; parts applied | Art. 9(2)(b) |
| 6. Product information | Label, instructions and safety information as supplied | Recommended; basis for the checks under Art. 16(2)(b) |
| 7. Change log | Version, date, change, first batch affected | Art. 9(3); versioning recommended |
How long: 10 years, but from which unit?
Manufacturers keep the file up to date and available to market surveillance authorities for 10 years after the product has been placed on the market (Article 9(3) GPSR); importers keep a copy for 10 years (Article 11(6)).
Which unit starts the clock? The GPSR guidelines assess placing on the market unit by unit (point 2.1), and for CE-marked products the Blue Guide counts from each individual product the file covers (section 4.3). For a model sold over several years, plan for 10 years after the last unit.
Related records have their own periods: 10 years for the risk description, complaints, accidents and corrective measures (Article 15(4)), six years for supply chain data (Article 15(5)). Personal data in the complaint register may stay no longer than five years (Article 9(13)); anonymize old entries instead of deleting them.
Form, language and where the file is kept
No form is prescribed: the file can be electronic and consist of several documents (GPSR guidelines, point 3.1.1). No language either: on a reasoned request, documentation goes to the authority in a language it can easily understand (Article 4(3)(b) of Regulation (EU) 2019/1020 (opens in a new tab)), which can be agreed with the authority (Commission's Article 4 guidelines).
The GPSR does not say where the file sits, only that someone in the EU can produce it:
| Role | Duty regarding the file | Basis |
|---|---|---|
| Manufacturer | Draws it up, keeps it current and available for 10 years, provides it on request | Art. 9(2) and (3) GPSR |
| Importer | Keeps a copy for 10 years | Art. 11(6) GPSR |
| Responsible Person | Verifies that it exists, ensures access, provides documentation on a reasoned request | Art. 16(1) GPSR; Art. 4(3)(a) and (b) Regulation (EU) 2019/1020 |
| Authorized Representative | Provides the documentation proving safety on a reasoned request | Art. 10(2)(a) GPSR |
The Responsible Person need not store the file: it can check that it exists and obtain your assurance to share it on request (Article 4 guidelines, section 3; GPSR guidelines, point 3.2). Agree in the mandate how fast you deliver. More in who can be your GPSR Responsible Person.
Product models, variants and versions
The file is drawn up per product model, not per unit. Units with different features that may affect safety, such as a different color, composition or functionality, are specific products with their own documentation (GPSR guidelines, point 3.1.1). Variants can share documents; record why a variant does or does not need its own analysis. Spare parts you do not make need no file of their own, but if one affects safety, your risk analysis covers it (guidelines, footnote 18).
Updates are mandatory (Article 9(3)), yet older units stay on the market. Where a CE product is redesigned, the Blue Guide requires its file to reflect all versions and show how to identify them (section 4.3). Do the same for GPSR files: link each version to the batch or serial numbers of Article 9(5).
GPSR technical documentation or CE technical file?
| Aspect | GPSR-only product | CE-marked product |
|---|---|---|
| Legal basis | Art. 9(2) GPSR | The sector act; Art. 9 GPSR does not apply (Art. 2(1)(b)) |
| Purpose | Show that the product is safe (recital 33) | Show conformity with the essential requirements (Blue Guide, 4.3) |
| Declaration of Conformity | None | Required, as a rule also kept for 10 years (Blue Guide, 4.4) |
| Retention | 10 years (Art. 9(3)) | 10 years unless the act provides otherwise (Blue Guide, 4.3) |
| EU operator | Responsible Person verifies the file and ensures access (Art. 16(1)) | An Authorized Representative is generally mandated to keep the file (Article 4 guidelines, 4.3) |
A brand that sells both kinds of products needs both kinds of files.
Practical example: an Asian fitness equipment maker
An Asian maker sells a foldable home weight bench, a GPSR product without CE marking, through its own online shop to EU consumers. Its EU Authorized Representative is the mandated Responsible Person.
| Situation | Documentation | Basis |
|---|---|---|
| Bench in black and gray, same steel and coating system | One file; a note explains why the color does not affect safety | Guidelines, point 3.1.1 |
| Version with a leg-curl attachment | Own file and risk analysis; frame test report reused | Guidelines, point 3.1.1 |
| Tested to EN ISO 20957-1:2013 and EN ISO 20957-4:2016 | Listed with edition; presumption of safety only for the risks covered | Art. 7(1)(a), 9(2)(b); Implementing Decision (EU) 2026/901 |
| Frame supplier changes in 2027 | New version; old version kept and linked to earlier serial numbers | Art. 9(3) and (5) |
| Last bench placed on the market in 2030 | File kept until at least 2040 | Art. 9(3); guidelines, point 2.1 |
Gaps that surface when an authority asks
- Nobody in the EU can produce the file, neither from a copy nor through an assurance.
- The clock starts at launch, not at the last unit.
- One file for all variants, although a coating, material or function differs.
- Only the latest version, which does not match older units.
- A Declaration of Conformity instead of a file for a GPSR-only product: not required and no substitute.
Conclusion: one current file per model, reachable for 10 years
Good GPSR technical documentation gives authorities one current file per product model, versions that match each unit, and someone in the EU who can hand it over for 10 years after the last unit.
The file remains your responsibility as manufacturer. As your GPSR Responsible Person, Representa keeps your compliance files ready for inspections and handles communication with authorities. For CE-marked products, we act as your EU Authorized Representative and keep your technical documentation for 10 years. Our compliance consulting reviews your documentation and prioritizes the fixes.
Frequently asked questions
How long must GPSR technical documentation be kept?
For 10 years after the product has been placed on the market (Article 9(3) GPSR); importers keep a copy for the same period (Article 11(6)). Because placing on the market is assessed for each unit, count the 10 years from the last unit of a model you place on the market.
Does the technical documentation have to be kept in the EU?
The GPSR does not say where the manufacturer keeps it. Your Responsible Person in the EU must verify that it exists and ensure it can be made available to authorities on request (Article 4(3)(a) of Regulation (EU) 2019/1020). It may hold a copy or rely on your assurance to share the file.
Is there a template for GPSR technical documentation?
Not a mandatory one. The Commission's GPSR guidelines (C/2025/6233, point 3.1.1) offer an optional model template in three parts: product identification, characteristics and composition, and each potential risk with the measures taken against it.
In which language must the technical documentation be written?
The GPSR sets no language for the file. On a reasoned request, documentation must be provided in a language the authority can easily understand (Article 4(3)(b) of Regulation (EU) 2019/1020). According to the Commission's Article 4 guidelines, the language can be agreed with the authority.
Do CE-marked products need GPSR technical documentation?
No. Article 9 GPSR does not apply to products covered by Union harmonisation legislation (Article 2(1)(b)). They need the technical documentation required by their sector act, together with an EU Declaration of Conformity.