EU GPSR Traceability and documentation records

First record why the GPSR applies. It covers products intended for consumers or likely to be used by consumers under reasonably foreseeable conditions, including new, used, repaired, and reconditioned products. Article 2 excludes medicinal products, food, feed, living plants and animals, specified biological and agricultural products, certain service-operated transport equipment, specified aircraft, and antiques. A product clearly marked for repair or reconditioning before use is also outside the rule in Article 2(3).

Start the record at SKU or model level and connect every market-facing identifier to the physical product, packaging, accompanying document, online listing, and supplier file. GPSR Article 9 requires manufacturers to use a type, batch or serial number, or another visible and legible element enabling product identification, unless the information has to move to packaging or an accompanying document because of the product's size or nature.

The same record should capture the manufacturer name, registered trade name or trade mark, postal address, electronic address, and any separate single contact point. For imported products, add the importer's corresponding name, trade name or trade mark, postal address, electronic address, and single contact point, plus evidence that the importer checked the manufacturer's technical documentation and product identity duties before EU placement.

The technical file needs product-specific evidence. GPSR Article 9 requires an internal risk analysis before market placement and technical documentation containing at least a general product description and the essential characteristics relevant for assessing safety.

Where the product's possible risks make it appropriate, the record should add the risk analysis, risk elimination or mitigation solutions, test reports made by or for the manufacturer, and the European standards or other safety elements applied. If a standard or safety element is only partly applied, record which parts were applied so a reviewer can see the boundary of the evidence.

The GPSR and applicable delegated or implementing regulations are binding law. Commission manuals and portal instructions explain how to use systems such as the Safety Business Gateway, while the suggested identifier maps, evidence links, and review logs on this page are Sorena record-design recommendations. Those recommendations do not create extra statutory fields or replace a product-specific legal requirement.

For online and other distance sales, GPSR Article 19 requires the offer to clearly and visibly show manufacturer identity and contact data, responsible-person details when the manufacturer is not established in the Union, product identification information including a picture, type and any other identifier, and warning or safety information required for the product.

Marketplace evidence should prove that the listing interface can collect and display the same data rather than a shortened marketing version. GPSR Article 22 also requires online marketplaces to provide product-safety contact points, process product-safety notices, support recall and warning communications, and cooperate with authorities and economic operators when a dangerous product has been offered through the interface. Electronic information may supplement the physical markings and documents, but Article 21 does not allow it to replace information that Articles 9, 11, and 16 require on the product, packaging, parcel, or accompanying document.

After placement, documentation has to stay usable for incidents and corrective action. Manufacturers must provide public complaint and accident channels, investigate safety complaints and accident information alleging a dangerous product, and keep an internal register of those complaints, product recalls, and corrective measures. Importers have parallel duties to investigate complaints and accident information for products they made available and to file them in the manufacturer's register or their own internal register.

When a product is dangerous, the evidence file should show the risk, corrective measure, affected Member States, available quantity still circulating, Safety Business Gateway notification, consumer communication, and recall notice. GPSR Articles 35 and 36 require direct notice without undue delay where affected consumers can be identified, wider clear and visible notices where they cannot, and a written recall notice with product pictures, identification numbers, hazard, consumer action, remedies, contact route, and sharing instruction.

The baseline records above do not exhaust every possible GPSR traceability duty. Article 18 allows the Commission to create additional traceability systems by delegated act for products, categories, or groups likely to present a serious risk. Such an act must identify the covered products, required data, display and access methods, and who may access the data.

Do not assume that Article 18 creates a universal QR-code, data-carrier, or registration duty. Before adding a product-specific control, verify that an applicable delegated act covers the product and use that act's scope, data, timing, and access rules.