How long must I keep my product documentation?

Six years applies to technical documentation and traceability

Under the GPSR, there is a retention period of six years for technical documentation and traceability data. Who must keep that documentation depends on the role in the supply chain. The manufacturer draws up the technical documentation — including the risk analysis, design and production data — and keeps it for six years. Traceability data, such as from whom a product was received and to whom it was delivered, is broader: this record affects the manufacturer, importer and distributor alike, because each link in the chain must be able to demonstrate where a product comes from and where it goes.

This is where the own-brand rule immediately applies. A web retailer that sells a purchased product under its own name or logo does not qualify as a distributor but as a manufacturer — with the corresponding obligation to keep the full technical documentation for six years, not just the traceability data. Anyone who merely resells without their own brand on it, and does not substantially alter the product, remains a distributor: they do not have to draw up or keep technical documentation, but they do have to keep data on the product's origin and distribution. That distinction between "six years of technical documentation" and "six years of traceability data" is therefore not a matter of preference, but flows directly from which role an enterprise fulfills in the supply chain.

Where the retention period comes from: Article 18 GPSR

The six-year period is set out in Article 18 of Regulation (EU) 2023/988, which governs product traceability and the associated retention obligation. Because the GPSR is a regulation, this provision applies directly and identically in all twenty-seven member states — there is no national transposition that could shorten or extend the period.