Getting GPSR Documentation From a Chinese Manufacturer
You write to your Alibaba supplier: "Send me GPSR documentation, please." In reply, you get a PDF with a CE certificate nobody can verify, or — more often — "What…
You write to your Alibaba supplier: "Send me GPSR documentation, please." In reply, you get a PDF with a CE certificate nobody can verify, or — more often — "What is GPSR?". This is everyday life for an importer from China. Regulation (EU) 2023/988 (GPSR) requires technical documentation and a risk assessment from you, but the Chinese manufacturer has no obligation to supply them, because GPSR itself doesn't apply to them. All the pressure falls on you.
This article is a practical guide: how to get the most useful materials out of a Chinese supplier, and what to do about what you won't get.
Key takeaways
- A Chinese manufacturer isn't subject to GPSR — you obtain documentation on your own initiative, often contractually.
- Materials from the supplier are raw material for your technical documentation, not a finished package.
- You fill in the gaps yourself — as importer, you take on the manufacturer's duties.
- The most important items: test reports, product spec sheet, photos of markings, batch number.
What you can realistically get from a supplier
The scope depends on whether you're buying from a factory (manufacturer) or a middleman (trading company). Factories usually have more technical documents. Typical materials:
| Document | Usefulness for GPSR | How often available |
|---|---|---|
| Test report from an accredited lab (e.g. SGS, TÜV) | Very high | Varies — ask directly |
| Declaration of conformity / CE (where applicable) | High, but needs verification | Common, sometimes unreliable |
| Technical data sheet / product specification | Medium — basis for the description | Usually available |
| Bill of materials / composition | Medium — for the risk assessment | On request |
| Photos of markings and factory label | Medium | Easy to obtain |
Have materials from your supplier but don't know how to assemble them into documentation?
GPSRReady gives you a framework for technical documentation and risk assessment, into which you plug materials from the Chinese manufacturer, plus templates to fill the gaps (Polish warnings, importer label). You turn a chaos of PDFs into a complete, GPSR-compliant package.
How to phrase your request to actually get something
A generic "send GPSR docs" doesn't work. Ask specifically, in English, about things the factory understands:
- "Do you have a test report from an accredited laboratory (SGS, Intertek, TÜV) for this product?"
- "What standards does this product comply with?" (e.g. EN standards for the category)
- "Please send the product specification sheet and material list."
- "Can you provide photos of the product markings and packaging?"
- "What is the batch/lot number system for this order?"
It's best to write the documentation requirement into the purchase order (PO) or contract — suppliers take it more seriously that way. Gaps in the paperwork are a signal to verify the supplier, covered further in AliExpress and Alibaba under GPSR — what you need.
Verification — why you shouldn't take it at face value
A CE certificate from China can sometimes be a self-declaration by the factory with no backing test data, and sometimes it's simply "China Export" (a similar-looking mark with a different meaning). Before you add a product to your documentation:
- check whether the test report comes from a genuine, accredited laboratory (report number, verifiability),
- make sure the report matches exactly the model you're importing,
- check whether the test scope covers the risks relevant to your product.
How to distinguish a valuable certificate from a useless one is covered in Chinese supplier certificates and GPSR.
What your supplier won't give you — and what to do about it
You'll almost never get a ready-made Polish GPSR risk assessment or Polish warnings. You have to do this yourself — and this is precisely the moment when the importer takes on the manufacturer's duties.
- Risk assessment — carry it out based on the specification, composition, and foreseeable use.
- Polish warnings and instructions — translate and complete them according to the risk assessment.
- Importer label — add your name and address.
Assembling technical documentation — checklist
- I have a product description, model, and batch numbering system.
- I have a (verified) test report, or a justification why one isn't required.
- I have carried out my own risk assessment.
- I have Polish warnings and instructions.
- I have a label template with the importer's details.
- I know my supplier and have purchase documents (traceability).
Frequently asked questions
What if the supplier has no documentation at all?
That's a serious warning sign — consider switching suppliers. If you still want to sell the product, you'll need to build the technical documentation and risk assessment yourself, and for some categories commission tests at an accredited laboratory at your own expense. As an importer without manufacturer support, you take on full responsibility.
Is a test report from SGS enough as the entire GPSR documentation?
No. A test report is an important element, but technical documentation also includes a risk assessment, product description, list of standards, warnings, and identification data. The report is evidence of meeting part of the requirements, not the whole thing.
Do I need to translate the technical documentation into Polish?
Technical documentation can be in a language understood by the authorities (English is often accepted), but the authority can request a translation. Warnings and instructions for the consumer, however, must absolutely be in Polish.
Can I reuse a supplier's documentation for a similar but different model?
Not automatically. Documentation and test reports must relate to the specific model you're placing on the market. A different variant may have different materials, different risks, and requires its own verification.