5 Common Mistakes When Preparing GPSR Documentation
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Practical Guides | 8 November 2026 | 5-minute read
For independent businesses selling products to the European Union, preparing product safety documentation can seem complicated, especially when dealing with different materials, suppliers and product variations.
The EU General Product Safety Regulation (GPSR), applicable since 13 December 2024, requires manufacturers of covered products to assess product safety and prepare appropriate technical documentation before placing products on the market.
However, documentation is not simply about completing a form. It needs to accurately reflect the products being sold and the risks associated with them.
Here are five common mistakes to look out for — and practical ways to avoid them.
1. Using the same documentation for every product
One mistake is assuming that a single document can automatically cover an entire product collection.
While similar product models may share some supporting information, differences in materials, components, design or intended use can affect their safety.
For example, a business selling bracelets in several colours might be able to use common documentation where the variations have the same relevant safety characteristics. However, changing the material or construction could introduce different risks that require additional assessment.
The European Commission's 2025 business guidelines clarify that technical documentation generally relates to a product model, rather than every individual manufactured unit. Variations that affect safety must be considered separately.
How to avoid it:
- Identify each product or model clearly.
- Record materials, components and intended uses.
- Check whether variations introduce different safety risks.
- Keep documentation consistent with the products actually offered for sale.
The important principle is that documentation should reflect the relevant safety characteristics of each product.
2. Overlooking the product risk assessment
Some sellers assume that simple, low-risk products do not require a risk assessment.
Under Article 9 of the GPSR, manufacturers of covered products must carry out an internal risk analysis before placing them on the market.
This does not necessarily mean obtaining expensive laboratory reports for every product. The level of documentation should be proportionate to the product's complexity and potential risks.
For example, depending on the product, a risk assessment might consider sharp edges, small detachable components, chemical exposure, breakage or foreseeable misuse.
How to avoid it:
- Start with a straightforward assessment that records:
- What hazards could arise during normal or reasonably foreseeable use.
- Who might be affected.
- What measures reduce or eliminate the identified risks.
Whether testing, standards or other supporting evidence is relevant.
A risk assessment should explain how product safety has been considered, rather than simply stating that the item is safe.
3. Missing essential product identification and manufacturer information
A product should be identifiable from its supporting documentation.
Incomplete product names, missing model references or unclear manufacturer details can create problems when reviewing safety information or tracing affected products.
For products covered by the GPSR, relevant traceability requirements include product identifiers and manufacturer contact information.
How to avoid it:
- Maintain an organised product record containing:
- Product name and model or reference number.
- Photographs and a general description.
- Materials and relevant technical characteristics.
Manufacturer's name and contact details.
Applicable batch, serial or other identification information.
Keep this information consistent across the technical file, product labels and online listings.
If a safety issue arises, clear product identification makes it easier to determine which products may be affected.
4. Confusing physical labelling with online listing requirements
Adding compliance information to an Etsy or Shopify listing does not necessarily fulfil the requirements for information on the physical product.
Likewise, having the correct information on a product label does not automatically mean that an online offer contains everything required under Article 19 of the GPSR.
For covered online offers, specified information includes manufacturer details, EU Responsible Person details where applicable, product identification and relevant safety warnings.
Physical products, packaging or accompanying documents may have additional requirements.
How to avoid it:
- Carry out two separate checks:
- Physical product check: Review the product identifier, applicable economic operator details, instructions and safety information.
- Online listing check: Make sure the offer clearly displays the applicable information required for distance sales.
- Where warnings or instructions are required, check the language requirements for the EU countries in which the product will be offered.
5. Assuming an EU Responsible Person replaces product safety documentation
Appointing an EU Responsible Person is an important part of the compliance arrangements for many non-EU manufacturers.
However, an EU Responsible Person does not automatically certify a product, perform every required test or remove the manufacturer's obligations.
The manufacturer remains responsible for ensuring that the product meets applicable safety requirements and that the necessary documentation is prepared.
Similarly, paying for a Responsible Person service does not by itself establish a valid appointment. The relevant operator must agree to the arrangement and undertake the applicable responsibilities.
How to avoid it:
- Before arranging representation, check that:
- Your product falls within the service provider's accepted scope.
- The relevant safety documentation is available.
- The EU-established operator is eligible and has agreed to perform the required tasks.
The appointment and agreed responsibilities are confirmed in writing.
Treat Responsible Person arrangements as part of a wider product safety process, rather than a replacement for it.
A more organised approach to GPSR documentation
Preparing GPSR documentation becomes easier when businesses maintain a consistent process for each product or model.
Start with accurate product information, assess relevant risks, collect supporting documents and review labelling before making the product available to EU consumers.
Documentation should also be updated when product changes affect its safety.
Under the GPSR, relevant manufacturers must generally retain technical documentation for 10 years after the product has been placed on the market.
Good recordkeeping helps businesses respond more effectively to enquiries, product changes and safety concerns.
How CompliSwift can help
At CompliSwift, we understand that independent sellers often manage product development, customer service and regulatory requirements themselves.
Our EU GPSR Responsible Person service is designed to make the representation process more accessible, with annual plans starting from £90 for eligible products.
We review submitted product information and coordinate representation with our qualifying EU-established partner for accepted applications.
Representation takes effect only after the agreed product scope has been accepted and the required written mandate is completed.
Need help getting started?
Explore CompliSwift's GPSR Plans
Official Sources
European Commission — GPSR Guidelines for Businesses (2025)
Regulation (EU) 2023/988 — General Product Safety Regulation
UK Government — EU GPSR Detailed Guidance
This article provides general information and is not a substitute for product-specific legal or technical advice. Requirements vary depending on product type, supply-chain role and applicable legislation.