How long must GPSR documentation be kept?

Article 9.4 of Regulation (EU) 2023/988 requires manufacturers to keep the GPSR technical documentation available to national competent authorities for a period of ten years from the date on which the product was last placed on the market. The same obligation is imposed on importers by Article 11.2. This 10-year period is calculated from the last date the product was supplied to a customer or distributor — not from the date of manufacture or the first sale. If you continue selling a product for several years, the clock does not start until you stop selling it entirely.

The practical implications of this obligation extend well beyond the active sales period. A product sold from 2024 to 2030 would require documentation to be retained until 2040. For businesses with large or rapidly changing catalogues, this creates a significant records management challenge: you must be able to retrieve and produce the complete technical file for discontinued products, not just current ones. If the product design, materials, or manufacturing process changes substantially, the updated version effectively restarts the obligation — the file for the modified product must be retained for 10 years from the last sale of the new version.

The GPSR does not prescribe a specific format or storage medium for the technical documentation. It can be kept in digital form — a cloud folder, a document management system, or even a structured email archive — provided it is complete, accessible to the EU Responsible Person at all times, and can be produced in full within 10 days of an authority's request. The 10-day deadline is firm: failing to produce the file within that window is itself a GPSR infringement, separate from any underlying product safety issue.

What the law says

Consequences of non-compliance