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EU products — manufacturer documentation duties

A list of checks and obligations with their cadence, ready to add to your agenda.

For manufacturers, importers and distributors placing products on the European Union market. Covers the documentation permanence duties: digital instructions accessible for at least ten years, technical documentation and the declaration of conformity to be kept, a responsible person established in the Union, traceability, the complaints register, the digital product passport and the national WEEE producer register. It does NOT cover conformity assessment of any specific product category, sectoral law on medical devices, toys and PPE, or customs duties.

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  • 12 planned checks, the most frequent every month from installation

Planned checks

Informative summary verified on 11/09/2026. It does not replace legal advice: the regulation cited prevails. If you spot an error, report it.

Version 1Countries coveredEuropean Union
Checks by country

Some checks are only mandatory in certain countries: pick yours and the list follows.

  1. 01

    Keep the GPSR technical documentation for 10 years

    Before placing a product on the market the manufacturer must carry out an internal risk analysis and draw up technical documentation containing at least a general description of the product and its essential safety characteristics; the documentation must be kept available to the authorities for ten years after placing on the market and updated as needed. Proof is the dated, versioned technical file. Applies to manufacturers of consumer products not covered by specific harmonisation legislation and, for the safety aspects that legislation does not cover, to harmonised products as well.

    continuous check, confirm every 12 monthsLegal obligationRegulation (EU) 2023/988 (GPSR) Art. 9(2) and Art. 9(3)European Union onlySourceverified on 11/09/2026
  2. 02

    Complete the transition to the Machinery Regulation by 20 January 2027

    Review technical files, risk assessments, declarations of conformity and manuals to align them with Regulation (EU) 2023/1230, which from 20 January 2027 replaces Directive 2006/42/EC, including the new requirements on cybersecurity, safety software and digital instructions. Proof is the transition plan with the status per product family. Applies to manufacturers, authorised representatives, importers and distributors of machinery and related products placed on the market from 20 January 2027, while machinery already placed on the market before that date remains subject to Directive 2006/42/EC.

    every year by 20 JanuaryLegal obligationRegulation (EU) 2023/1230 Art. 54 (date of application: 20 January 2027)European Union onlySourceverified on 11/09/2026
  3. 03

    Have a responsible person established in the Union

    A consumer product may be placed on the EU market only if an economic operator established in the Union is responsible for compliance tasks: their name and contact details must appear on the product, its packaging, the parcel or the accompanying documents. Proof is the written mandate together with the contact details shown on the pack and in the online listing. Applies to manufacturers established outside the Union selling to EU consumers, including online only, and to those importing or distributing their products: the role may be taken by the manufacturer established in the EU, the importer, an authorised representative or a fulfilment service provider.

    continuous check, confirm every 12 monthsLegal obligationRegulation (EU) 2023/988 (GPSR) Art. 16; Regulation (EU) 2019/1020 Art. 4European Union onlySourceverified on 11/09/2026
  4. 04

    Register in the national WEEE producer register (Italy)

    Anyone placing electrical and electronic equipment on the Italian market for the first time must register electronically in the WEEE register at the competent Chamber of Commerce before starting to sell, and update the registration on every change. Proof is the WEEE register number, to be shown on invoices and commercial documents. Applies to producers, importers and distance sellers of electrical and electronic equipment on the Italian market, including those reselling third-party products under their own brand, and registration must precede placing on the market.

    every month from installationLegal obligationD.Lgs. 14 marzo 2014 n. 49 art. 29; Direttiva 2012/19/UE (RAEE)Italy onlySourceverified on 11/09/2026
  5. 05

    Have the battery passport ready by 18 February 2027

    From 18 February 2027 every light means of transport battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the market must have an electronic record, the battery passport, accessible via a QR code and a unique identifier. Proof is the published passport together with the registered identifier. Applies to LMT batteries for light means of transport, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries, while portable batteries are outside the passport duty but remain subject to the labelling and collection obligations.

    every year by 18 FebruaryLegal obligationRegulation (EU) 2023/1542 Art. 77 (battery passport) and Art. 13(6) (QR code)European Union onlySourceverified on 11/09/2026
  6. 06

    Keep the internal register of complaints and recalls

    The manufacturer must keep an internal register of consumer complaints, non-compliant products and recalls and keep distributors, importers and marketplaces informed, providing public communication channels for receiving complaints. Personal data in the register must be kept no longer than necessary and in any case no more than five years after entry. Proof is the register with date, product, batch, outcome and action taken. Applies to manufacturers of consumer products within the scope of the GPSR, while importers and distributors have duties to cooperate and to pass on the complaints they receive.

    continuous check, confirm every 6 monthsLegal obligationRegulation (EU) 2023/988 (GPSR) Art. 9(11), Art. 9(12) and Art. 9(13)European Union onlySourceverified on 11/09/2026
  7. 07

    Ensure product traceability

    The manufacturer must put on the product, or where that is not possible on the packaging or in the accompanying documents, a type, batch or serial number allowing its identification, together with the name, registered trade name, postal and electronic address and single contact point. For products presenting a serious risk the Commission may impose an enhanced traceability system. Proof is the actual marking on the products together with the internal batch master data. Applies to all consumer products within the scope of the GPSR: the enhanced traceability system of Art. 18 is triggered only for the categories identified by Commission delegated acts, and at the time of verification no delegated acts had been adopted on that basis.

    continuous check, confirm every 12 monthsLegal obligationRegulation (EU) 2023/988 (GPSR) Art. 9(5), Art. 9(6) and Art. 18European Union onlySourceverified on 11/09/2026
  8. 08

    Notify accidents and recalls through the Safety Business Gateway

    Where a product placed on the market has caused an accident, or where the manufacturer considers it unsafe, it must immediately take corrective measures, notify the authorities of the Member State without delay via the Safety Business Gateway and inform the consumers concerned. Proof is the notification receipt together with the published recall notice. Applies to manufacturers, importers and distributors of consumer products: the duty is reactive and triggered by the event, so the periodic check only serves to confirm that the internal reporting channels work.

    continuous check, confirm every 6 monthsLegal obligationRegulation (EU) 2023/988 (GPSR) Art. 9(8) and Art. 20; Art. 35 e 36 per l'informazione ai consumatori e i richiamiEuropean Union onlySourceverified on 11/09/2026
  9. 09

    Keep digital instructions online for at least 10 years

    Where instructions for use are supplied in digital format, the manufacturer must state on the machinery or the packaging how to access them, make them printable and downloadable, and keep them accessible online for the expected lifetime of the product and in any case for at least ten years after placing on the market. Proof is the live stable URL together with the internal register of instruction versions per model and year of placing on the market. Applies to manufacturers of machinery and related products placed on the EU market from 20 January 2027: at the user's request, within one month of purchase, the instructions must still be supplied free of charge on paper, and for machinery intended for non-professional users the safety instructions must always be supplied on paper.

    continuous check, confirm every 12 monthsLegal obligationRegulation (EU) 2023/1230 Art. 10(7), point (c); Annex III 1.7.4 (contenuto delle istruzioni)European Union onlySourceverified on 11/09/2026
  10. 10

    Keep the technical file and EU declaration of conformity for 10 years

    The manufacturer must keep the technical documentation and the EU declaration of conformity at the disposal of market surveillance authorities for at least ten years after the product has been placed on the market or put into service. Proof is the document archive indexed by placing date, serial number and file version. Applies to manufacturers and authorised representatives of machinery and related products: the manufacturer of partly completed machinery has the mirror duty under Art. 11(3), while the importer, whose duties sit in Art. 12 and not in Art. 11, must keep a copy of the EU declaration of conformity available.

    continuous check, confirm every 12 monthsLegal obligationRegulation (EU) 2023/1230 Art. 10(3) (fabbricanti di macchine); Art. 11(3) (fabbricanti di quasi-macchine); Art. 12 (importatori)European Union onlySourceverified on 11/09/2026
  11. 11

    File the annual WEEE declaration by 30 April (Italy)

    Producers registered in the WEEE register must file electronically, by 30 April each year, the declaration of the quantities of equipment placed on the national market in the previous year; the declaration is due even when the quantity is zero. Proof is the electronic submission receipt. Applies to every party registered in the WEEE register: it is not due for exported equipment and it is due even for a nil quantity. Cadence to be confirmed on the cited source.

    every year by 30 AprilLegal obligationD.Lgs. 14 marzo 2014 n. 49 art. 29 comma 6Italy onlySource
  12. 12

    Watch the ESPR delegated acts and the digital product passport

    The ESPR imposes no direct duties until the delegated act for your product category is adopted: it needs a periodic watch on the Commission working plan and on consultations, to prepare for ecodesign requirements and for the digital product passport. Proof is a dated review note listing the relevant delegated acts. Applies to businesses producing or importing goods in the categories identified by the 2025-2030 working plan, following the indicative Commission timetable: iron and steel from 2026, energy-related products between 2026 and 2029, textiles, tyres and aluminium from 2027, furniture from 2028, mattresses and ICT products from 2029.

    continuous check, confirm every 6 monthsRecommendedRegulation (EU) 2024/1781 (ESPR) Art. 4 (atti delegati), Capo III (passaporto digitale di prodotto); Working Plan 2025-2030 adottato il 16 aprile 2025European Union onlySourceverified on 11/09/2026

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