GPSR Product Photos and Technical Description Guide

You're filling in the technical documentation for a set of wireless headphones from China, and you reach the field "technical description and product photos." You have a few nice marketing photos from the listing — a model wearing the headphones against a sunset. You drop them in and move on. The problem is that these photos say nothing about the product itself: you can't see the markings, the label, the charging port or the data plate. If UOKiK asked for the documentation, that material would be useless. Photos and technical descriptions under GPSR (EU) 2023/988 serve an evidentiary function, not a promotional one. This article shows how to get them right.

Why GPSR requires a technical description and photos

Technical documentation is meant to let the surveillance authority assess a product's safety without holding it in their hands. Photos and a technical description are the product's "portrait" — they show what it is, what it's made of and what markings it carries. Without them, the risk assessment hangs in a vacuum, because it's unclear what it actually refers to. This is one of the three pillars of technical documentation, alongside the risk assessment and the list of standards.

It's worth remembering that the official assessing the documentation usually doesn't have the product in front of them — they work with whatever you provide. If the photos are blurry and the description superficial, the authority may deem the documentation insufficient and request additions, or challenge the product. Good photos and a factual description are therefore not just a formality — they're your way of convincing an inspector that you know what you're selling and that you've got the risks under control. In practice, Allegro sellers who put together a solid "technical portrait" for a model once save themselves weeks of correspondence at the first inspection.

Technical description — what it should include

A technical description is a factual characterisation of the product. For headphones, it would cover, among other things:

• Name and model — full trade designation and model number.
• Dimensions and weight — measurements relevant to safety and packaging.
• Power supply — battery type, charging voltage, power.
• Materials — plastics, metal parts, ear cushions.
• Functions and components — Bluetooth, microphone, buttons, charging port.
• Intended use and user group — what the product is for and who it's intended for.

The technical description is the starting point for the risk assessment — without knowing the materials and power supply, you can't reliably assess the hazards.

What photos are needed

Documentation photos differ from marketing photos — they need to show the product technically, not sell an emotion. See the comparison below.

Marketing photo	Documentation photo
Model wearing the headphones, striking background	Product on a plain background, sharp, fully visible
General shot, no detail	Close-up of the label and rating plate
Retouching, filters	No retouching — the true appearance of the markings
A single shot	Several shots: front, back, markings, port

The mandatory set of shots

A good set of documentation photos includes:

1. General view — the whole product on a neutral background.
2. Label and rating plate — a legible close-up with identification data.
3. Markings and pictograms — safety symbols, warnings, age markings.
4. Safety-relevant components — charging port, battery compartment, moving parts.
5. Packaging with markings — if identification data is on the packaging.

The photos should clearly show the data required for traceability — the model number, batch number, and the manufacturer's and importer's details.

Photos as proof that markings are present

Photos serve another purpose too — they document that the product actually carries the required markings. If the rating plate shows the Responsible Person's details in the EU, the photo confirms it. This matters for imports, because it shows the marking was actually applied, not just declared on paper. More on this data in the article on RP details on the product and in the listing.

Common mistakes in photos and descriptions

Sellers waste time fixing their documentation for the same handful of reasons, over and over. Worth avoiding from the start:

• Only renders or supplier graphics — 3D catalogue images don't prove what the actual unit and its markings look like.
• Illegible rating plate — the photo taken too far away or blurry, so the data can't be read.
• No shot of the packaging — when part of the identification data is on the box rather than the product.
• "Listing" description — marketing language instead of technical parameters (material, power supply, dimensions).
• Photos of a different variant — a different colour or version than the batch you're actually selling.

Each of these mistakes means the surveillance authority can't unambiguously link the documentation to the product in your listing — and that's the most common reason for a request for additional information.

How to archive photos and descriptions

Keep photos and the technical description together with the rest of the documentation for 10 years. It's worth keeping them digitally, labelled with the model number and date, in an organised folder — so that years later they can still be linked to a specific product and batch. We cover archiving rules in the article on archiving documentation for 10 years. Good practice is to save the original photos at full resolution plus a single combined PDF per model, bringing the description, shots and close-ups of the markings together in one document ready to send to the authority.

Frequently asked questions

Can I use photos from my Chinese supplier?

Yes, as long as they show the actual product you're selling, with the markings clearly visible. Marketing photos usually aren't enough — you need technical shots with a legible label and rating plate. It's best to verify them with your own photos of the delivered batch.

How many photos should be in the documentation?

Enough to fully document the product and its markings — usually anywhere from a few to a dozen or so shots. The key ones are: general view, label, markings and safety-relevant components.

Does the technical description have to be very detailed?

Proportionate to the product. A simple gadget needs basic parameters; an electrical product needs more data on power supply and materials. The description should be enough to carry out the risk assessment.

What format should the photos be kept in?

Any legible digital format (JPG, PNG, PDF). What matters is that the photos are sharp, show the markings, and are labelled so they can be linked to the model and batch throughout the entire retention period.