Your EU Responsible Person under the General Product Safety Regulation

GPSR risk analysis and technical documentation

Before placing a consumer product on the EU market, the manufacturer must carry out an internal risk analysis and draw up technical documentation (Article 9(2) GPSR). It is what the EU Responsible Person checks and what authorities ask for.

Article 9(2) GPSR Aspects listed in Article 6 Kept for 10 years Available to authorities

What the documentation should contain

The documentation must be kept up to date and kept for 10 years after the product has been placed on the market, and made available to market surveillance authorities on request (Article 9(3)).

Aspects to consider (Article 6)

1

The product itself

Design, technical features, composition, packaging, and instructions for assembly, installation and maintenance.

2

Other products

Its effect on other products it is likely to be used with, including interconnection.

3

Presentation

Labelling, warnings, instructions for use and disposal - and an appearance that could mislead, for example resembling food or attracting children.

4

Who uses it

Consumers at particular risk, especially children, older people and people with disabilities.

5

Connected features

Cybersecurity protections and any evolving, learning or predictive functionality where relevant.

6

Foreseeable misuse

Not only intended use but reasonably foreseeable use and misuse.

Standards help, but are not always enough

Applying relevant European standards gives a presumption of safety for the risks they cover. Where no standard exists, or a risk is outside it, the risk analysis must still address it. For CE-marked products, the sector legislation's own technical file usually covers most of this; the GPSR fills in aspects that the sector law does not cover.

Frequently asked questions

Is a risk analysis mandatory under the GPSR?

Yes. Article 9(2) requires manufacturers to carry out an internal risk analysis and draw up technical documentation before placing the product on the market.

How long must the technical documentation be kept?

For 10 years after the product has been placed on the market (Article 9(3)).

Does the EU Responsible Person write the risk analysis?

No. The manufacturer prepares it; the Responsible Person verifies that the documentation exists and can provide it to authorities.

Related guides

Note: This guide provides general information about Regulation (EU) 2023/988 (GPSR), not legal advice. Specific obligations depend on your product and supply chain. Last reviewed 5 October 2026.

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