what should I do if my supplier refuses to send test reports or documents

A supplier who does not deliver does not change your own obligation

If a supplier refuses to send test reports or technical documents, the question remains: what is your own role in the supply chain — and that role determines what is expected of you, not the supplier's willingness. Whoever imports products from outside the EU is considered a manufacturer, and the manufacturer verifies whether the producer has fulfilled its obligations. Missing documentation is then not something to ignore or wait for, but a signal that this verification is not yet complete.

What is also important here is the own-brand rule: whoever sells a product under their own name or brand — even if it is simply purchased and only a logo is added to it, or if it is substantially modified — is not considered a distributor or manufacturer but a producer. The obligations that normally rest with the producer, such as technical documentation and risk analysis, then factually rest with your own enterprise, and a reluctant supplier is not a party that "arranges things for you", but part of your own manufacturing chain. Whoever really is a distributor — resells products of another brand without modifying them — does not need to draw up technical documentation or risk analysis, but does verify that the required information is present before the product is offered. Which documents exactly and how this request proceeds in practice is described at which documents must I request from my supplier.

Where this follows from: Articles 11 and 12 of the regulation

Article 11 of Regulation (EU) 2023/988 requires the manufacturer to verify that the producer has fulfilled its obligations, and lists the obligations of manufacturers; Article 12 of the same regulation provides that the distributor verifies the presence of the required information. Which of these two roles applies, and what exactly follows from it, is set out on the page am I a manufacturer, importer or distributor under GPSR. For those who must draw up a risk analysis themselves after documentation is not forthcoming because the role is factually that of a producer, there is an explanation at how do I conduct a risk analysis for my product under GPSR.