Which documents must I request from my supplier?

Which documents you request depends on your role

What you request from a supplier differs fundamentally between an importer and a distributor — and that difference lies in what the regulation requires of each role. An importer sources a product from outside the EU and brings it into the Union itself; that role verifies whether the manufacturer has fulfilled its obligations, and therefore requests the complete supporting documentation: the technical documentation, the risk analysis, the EU compliance information, the instructions and warnings in the required language, and the data that make the manufacturer traceable. A distributor — anyone who resells the product within the EU without being the first to import it or placing it on the market under their own name — only verifies that the required information is present on the product or packaging: warnings, instructions for use, identification data. A distributor therefore does not need to request the underlying risk analysis or technical files; that obligation belongs to the manufacturer and the importer, not to them.

Anyone who places a product on the market under their own name or brand is themselves considered a manufacturer — even if the product was developed elsewhere and only a logo was added to it. In that case, requesting documents from the supplier is not enough: the underlying data (specifications, test reports, material information) then form the starting point for your own technical documentation and risk analysis, which the online shop must be able to present itself. What originally begins as 'requesting documents from the supplier' becomes, in that situation, building your own file.

Where that distinction appears in the regulation

The distinction follows from Article 11 of Regulation (EU) 2023/988, which describes the importer's verification obligation, and Article 12, which governs the lighter verification obligation of the distributor. Both articles apply identically across all twenty-seven Member States, because the GPSR is a regulation and not a directive that is transposed country by country.