GPSR Documentation Archiving: Keep Records 10 Years

It's 2026. You're winding down sales of a lamp model that sold brilliantly for two years. You're tidying up your drives: deleting photos, supplier invoices, the old documentation folder. "The product's no longer on offer, why do I need these files" — you think. Three years later you get a letter from the market surveillance authority about a complaint concerning that very lamp. The request: provide the technical documentation. And you deleted it. This is one of the most common and most costly mistakes under GPSR (EU) 2023/988. The regulation requires documentation to be kept for 10 years — and this obligation doesn't end the moment the product leaves your range.

How many years you must keep documentation

GPSR requires technical documentation to be kept for 10 years from the product being placed on the market. This period runs from the moment the product first entered the EU market — not from when you stopped selling it. This means that even long after you've stopped offering a given product, you must be able to present its documentation to a market surveillance authority.

The obligation covers the whole of the technical documentation: the product description, risk assessment, list of standards, photos, instructions, and batch and traceability records.

What exactly needs to be kept

It's not just one file. A complete archive includes:

• Product description and technical description — parameters, materials, intended use.
• Risk assessment — a full analysis of hazards and mitigating measures.
• List of standards and test reports — evidence of conformity.
• Documentary photos — the product, label, markings.
• Instructions and warnings — in the version supplied with the product.
• Traceability records — batch numbers, deliveries, manufacturer and importer details.
• Details of the Responsible Person in the EU — confirmation of appointment and their details.

Paper or digital — how to store it

GPSR doesn't require a paper format. Documentation can be stored digitally, which is more practical given the 10-year period. What matters is that it's complete, legible, and available on request. Below is a comparison of approaches.

Format	Advantages	Risks
Digital (drive + cloud copy)	Easy access, no paper degradation, backup copies	Data loss without backup, file chaos
Paper	Independent of technology	Storage space, risk of damage, hard to search
Hybrid	Flexibility	Risk of version inconsistency

How to organise your archive so you can find it years later

Documentation you can't find after five years is just as useless as documentation you deleted. A practical structure:

1. A folder per product/model — one model, one folder with a clear name and number.
2. Subfolders for each element — description, risk assessment, photos, standards, instructions, deliveries.
3. Recorded dates — the date placed on the market and the date of the last update.
4. A backup copy — in at least two locations (e.g. local drive plus cloud).

Link your folders to the batch numbers we cover in our article on product traceability — that way, if a complaint comes in, you'll quickly find the right batch.

Who is responsible for storage

The obligation to store documentation rests with the entity responsible for the product — the manufacturer or importer — and is linked to the role of the Responsible Person in the EU. The Responsible Person must be able to make the documentation available to the surveillance authority. More on their role in our article on the Responsible Person — when it's required. If you're the importer, organising and maintaining the archive is on you.

The most common archiving mistakes

Sellers most often lose documentation because of:

• deleting files once a product leaves the range,
• keeping everything on a single drive with no backup,
• failing to link documents to a specific model and batch,
• losing access to correspondence with the supplier (test reports in an email account that's gone).

Each of these mistakes leaves you empty-handed during an inspection — even though the documentation once existed.

Frequently asked questions

When does the 10-year period start counting?

From the product being placed on the market, i.e. from when it was first made available on the EU market — not from when sales ended. That's why you need to keep documentation even after withdrawing a product from your range.

Can I keep documentation only in the cloud?

Yes, a digital format is acceptable. Make sure you have backups and that the documentation is complete and can be made available on request within a reasonable time.

What if I deleted the documentation but the product is still in circulation?

You need to reconstruct it — based on supplier data, retained invoices, photos, and a fresh risk assessment. A lack of documentation during an inspection can result in the product being challenged, so it's better to reconstruct it in advance.

Can documentation for different batches of the same model be shared?

The description, risk assessment, and standards are usually shared for the model, but batch records (delivery numbers, quantities) are kept separately for each batch to preserve traceability.