EU Cyber Resilience Act, CRA Product Security and CE Marking Technical Documentation and Audit File

The technical documentation must contain all relevant data or details of the means used by the manufacturer to ensure that the product and the manufacturer's processes comply with Annex I. Annex VII lists the minimum elements.

The file should therefore make it easy to identify the product, the applicable requirements, the risk basis, the standards or alternative solutions used, and the evidence supporting conformity.

The most efficient structure is a stable index plus linked evidence repositories. That lets engineering update tests and advisories without rebuilding the entire file every release.

Keep the structure consistent across products so legal, product, and engineering teams can all navigate it quickly.

The Commission FAQ explains that technical documentation should reflect relevant redesigns, re assessments, and cybersecurity information that emerges after placement on the market. That includes vulnerability findings, test results, and changes in the product or its processes.

A product that evolves during the support period should therefore have file updates tied to releases, incidents, and major architectural change.

Manufacturers must keep the technical documentation and the 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 for the support period, whichever is longer. Importers also need to keep a copy of the declaration and ensure the technical documentation can be made available on request.

This is a record retention and retrieval problem as much as a writing problem.