Which documents must you retain for six years under the GPSR?
The regulation stipulates a ten-year retention period for technical documentation held by manufacturers, and shorter, less clearly defined periods for other documents such as complaints and incident reports. Because these periods vary by document and can differ depending on your role in the supply chain, the question that business operators would do better to ask themselves is not "how long" but "which documents must I be able to produce at all, and to whom".
In practice, this comes down to four types of documents: the risk analysis per product, the technical documentation that the manufacturer (or whoever acts as such) has prepared or had prepared, the declarations and test reports that you have requested from your supplier, and your own records of complaints, incidents and any recall actions. Anyone uncertain about which role they occupy, and therefore which documents fall within their responsibility, can find guidance through a few questions via the role check that shows your position in the supply chain.
Why precisely these documents
The risk analysis is the starting point: it substantiates why a product is considered safe for its intended use and what warnings follow from it. The technical documentation sets out how the product is composed, tested and assessed, and for an importer or distributor is often something that must be requested from the manufacturer rather than prepared themselves. The supplier's declarations, such as declarations of conformity, test reports and material specifications, serve as evidence that you request and review them, not that you create them yourself. And the complaint register, which also includes reports of accidents or near-misses, is the document that a supervisor will request first when something goes wrong, because it demonstrates whether signals were identified in a timely manner.
The detail most frequently overlooked here
The point where businesses most often stumble is not the collection of documents, but their accessibility at the moment a supervisor requests them. Documents that are stored somewhere in a mailbox, on a supplier portal or with a former contact person do not count in practice if you cannot produce them within a reasonable timeframe. Additionally, the retention period usually begins to run from the moment a product model or batch is placed on the market, not from the last sale. For products that remain in an assortment for years, or for batches you reorder periodically, this means you must be able to demonstrate which version of the documentation applies to each model or batch, not merely that documentation once existed.
A second detail that is often underemphasized: documents that exist only in paper form or exist only with the supplier are vulnerable once that relationship ends. Anyone switching suppliers or phasing out a product would be well advised to secure the underlying documents at that time rather than relying on access that may no longer be available later.
How to organize this without it becoming a project
Most SMEs do not have a separate compliance department, and they do not need one. What does help is to maintain a fixed file for each product containing the risk analysis, technical documentation, supplier declarations and any complaints, so that you do not have to search again every time a question arises. In the knowledge base, organized by subject it is explained which document applies to which role and where it can be found in the regulation text; the latter is deliberately freely accessible, even without an account.
Structuring these dossiers, including the internal compliance system with complaint register and monitoring of what must be done per product, is the component that gpsria.eu offers as a paid system. We structure the risk analysis and the dossier, but do not provide our own assessment and never declare that a product complies with the law; that remains your responsibility or that of a specialized partner. What it costs and what it includes is clearly set out on the pricing page, and how the information is compiled you can read on the page on how it works.
Are you uncertain which documents are relevant in your situation, or do you want to first see which role you fall under before building a dossier? The free quick-scan provides an initial indication for that, without requiring you to register.