What Must Be in GPSR Technical Documentation

You're selling night lights on Allegro, imported from China. On Monday you get a message from the marketplace: "Submit the product's technical documentation within 14 days, or the listing will be suspended." You open the supplier folder and find only a proforma invoice and a few listing photos. This is the typical moment when a seller first runs into the GPSR (EU) 2023/988 regulation, in force since 13 December 2024. Technical documentation is the heart of your obligations — and despite appearances, you can put it together yourself. This article shows exactly what it must contain.

What technical documentation means under GPSR

The General Product Safety Regulation (GPSR) requires manufacturers, importers and so-called Responsible Persons (RP) to draw up and keep technical documentation for every product placed on the EU market. If you import goods from outside the EU (e.g. from China) and place them on the market under your own brand, or as an importer, GPSR treats you as a manufacturer — with the full scope of a manufacturer's obligations.

Technical documentation is a body of evidence that a product is safe. It isn't a single form but a folder: a product description, a risk assessment and a list of the standards applied. You don't have to publish it or send it to every customer — you must hold it and make it available to the market surveillance authority (in Poland: UOKiK) on request.

The three pillars of technical documentation

Every piece of GPSR technical documentation rests on three elements that must work together:

• Product description — what it is, what it's made of, how it works, who it's intended for.
• Risk assessment — what hazards the product poses and how they've been reduced.
• List of standards and requirements — which harmonised standards or other requirements you rely on to demonstrate safety.

We cover each of these three pillars in detail in separate articles — on the risk assessment step by step, and on how to use harmonised standards.

What exactly goes in the folder — a table

Below is the set of documents a surveillance authority may want to see. Not every element applies to every product, but it's worth knowing the full list.

Element	What it contains
General product description	Name, model, intended use, user group
Technical description and materials	Dimensions, power supply, materials, components, diagram
Product photos	General view, markings, label with identification data
Risk assessment	Hazard analysis and risk-reduction measures
List of standards	Harmonised standards or other reference requirements
Test reports (if available)	Test reports from a laboratory/supplier
Instructions and warnings	Content supplied with the product, in the language of the country of sale
Responsible Person's details	The EU entity liable for the product (Article 16)
Traceability	Batch or model number, manufacturer and importer details

Product description — where to start

This is the simplest part. Describe the product so that someone who hasn't seen it understands what it is. For an example night light: "LED night light powered by 230 V, ABS plastic housing, 5 W diode, intended for domestic use by adults and children over 3 years old." Add photos and a technical description to the description — with visible markings, the label and the rating plate. The more precisely you describe the product, the easier the risk assessment will be.

Risk assessment — mandatory for every product

Risk assessment is the element that most often trips sellers up, because it requires a bit of analytical thinking. In short: you identify hazards (e.g. electric shock, overheating, sharp edges, small parts posing a choking hazard), assess their likelihood and severity, and then describe the measures that reduce that risk (insulation, warnings, choice of materials). You document all of it. Without a risk assessment, technical documentation is incomplete — it isn't optional.

List of standards and traceability

In the documentation you state which standards you rely on. For electronics, these will usually be EN-family standards covering electrical safety and electromagnetic compatibility. Relying on a harmonised standard gives a presumption of conformity with safety requirements. A separate but closely related requirement is product traceability — a batch or model number that lets you recall a specific series in the event of a problem, rather than your entire range.

Who prepares the documentation and where the data comes from

Sellers' biggest worry is usually: "I'm not an engineer, how am I supposed to write this?" In practice, you gather much of the data from materials you already have or can obtain from your supplier. It pays to work methodically:

• From the supplier — technical specification, test reports, declarations of conformity, material data sheets.
• From the product itself — actual dimensions, markings, rating plate, package contents.
• From standards — the requirements for your product category that you rely on.
• From your own analysis — the risk assessment and decisions on mitigating measures.

Treat materials from a Chinese supplier as a starting point, not a finished product. A common mistake is pasting in a certificate for a different model or an outdated standard. Your job is to pull these elements together into a coherent whole, add the Polish instructions and the Responsible Person's details, and verify that everything actually relates to the product you're selling. This is editorial and organisational work, not designing a product from scratch.

How long to keep the documentation

GPSR requires technical documentation to be kept for 10 years from the product being placed on the market. This matters, because many sellers delete supplier files once they stop selling a model. We cover the details of archiving in the article on keeping documentation for 10 years. The rule is simple: the documentation must remain available to the market surveillance authority long after you've stopped selling the product in question.

Frequently asked questions

Do I need separate technical documentation for every product?

Yes, documentation relates to a product (or a family of very similar variants). If you sell 30 different models, you need a set for each of them. Variants of the same product that differ only in colour can be covered together, provided the risks are identical.

Will my Chinese supplier prepare the technical documentation for me?

Sometimes they supply part of the elements (test reports, declarations), but responsibility for complete and correct documentation rests with you as the importer. Materials from the supplier need to be verified and supplemented with Polish instructions, warnings and the Responsible Person's details.

Does the documentation need to be sent to UOKiK?

Not by default. You keep it yourself and make it available on request from the market surveillance authority. However, you must be able to present it within a reasonable time once requested.

What language must the technical documentation be in?

The documentation can be kept in a language understood by the surveillance authority of the given country — in Poland, that's Polish. Instructions and warnings supplied with the product must be in the language of the country of sale.