What data and documents to require from a supplier under GPSR

The supplier has sent a folder named 'GPSR documents', but do the files in it actually relate to the product ordered? Collecting documents should be a controlled process: from a clear request, through assessment of the response, to recording gaps and approving the correct version.

First establish which product you are asking about

A request such as 'send the GPSR documents' is too general. The supplier may respond with material concerning a similar model, an old version or an entire category.

In the request, specify:

• the product name and your own SKU,
• the model, type, series or supplier designation,
• the material, size and functional variant,
• a photo or drawing of the product,
• the order number or batch range,
• the market and language of sale,
• the planned role of your company: importer, distributor or own-brand manufacturer,
• the deadline and expected format of the response.

If the request covers several SKUs, ask the supplier for a mapping table. It should clearly indicate which document relates to which variant and why a shared piece of evidence can be applied to the whole group.

Product and entity identification data

The first group of information allows you to answer the question of who is responsible for the product and how to distinguish it from other versions.

Ask for:

• the manufacturer's full name and contact details,
• the manufacturer's postal and electronic address,
• details of the responsible person in the EU, if the manufacturer is not established in the Union,
• product identifiers: model, type, series, batch or other designation,
• photos of the product, label, packaging and nameplate,
• a description of the intended purpose and user groups,
• a list of variants and the differences between them,
• information on changes to the design, materials and components.

Compare this data with the physical sample, the order and the sales offer. A document for designation X100 should not be automatically assigned to X100 Plus.

Risk analysis and technical documentation

The manufacturer should carry out an internal risk analysis and draw up technical documentation. This does not always mean that the supplier will send one file with a fixed name. Therefore, ask for a specific range of information.

The list may include:

• a general description of the product and the characteristics relevant to safety,
• intended and reasonably foreseeable methods of use,
• identified hazards and groups of exposed users,
• measures applied to eliminate or reduce risk,
• residual risk and the resulting warnings,
• a list of the standards and other criteria applied,
• test reports, calculations or other evidence,
• the date, author and version of the analysis,
• information on which models the documentation covers.

If the supplier does not want to disclose the full document for confidentiality reasons, an alternative way of demonstrating that the obligations have been performed and that the documentation is available to authorised bodies must be established. A general assurance in an email should not close the matter without an assessment of its content and the product risk.

Test reports and certificates

Do not ask only 'does the product have a certificate'. Under GPSR there is no single universal certificate that replaces an analysis of a specific product.

For each report, check:

• the name and details of the laboratory or issuer,
• the document number and date,
• photos and identifiers of the tested sample,
• the method or standard applied,
• the scope of the test and the results,
• exclusions, deviations and remarks,
• the link to the current model,
• whether the design or material was changed after the test.

A document may be genuine but not useful. For example, a report on chemical properties does not answer questions about mechanical hazards. In turn, a test carried out for an earlier version may require reassessment after a component change.

Instructions, warnings and marking

Ask for source materials, not just a photo of a random leaflet:

• instructions for use, assembly, maintenance and disposal, where applicable,
• warnings arising from the risk analysis,
• the label and packaging design,
• the place where identifiers and entity details are located,
• language versions,
• confirmation of which product version the content relates to.

Then check the translation. A mechanical translation may change the meaning of a warning or omit a condition for safe use. The person approving should compare the local version with the source material and the product characteristics.

Data needed for online sales

An offer for a product sold at a distance should present the required information before purchase. In addition to materials on the product and packaging, therefore collect an approved set of data for sales channels:

• the manufacturer's name and identification,
• the manufacturer's postal and electronic address,
• details of the responsible person in the EU, if required,
• the image and product identifiers,
• warnings and safety information in the language of the market of sale.

It is best to keep this data as one approved version linked to the SKU. This makes it possible to compare the shop, marketplace and documentation without manually establishing which spreadsheet is current.

How to assess the supplier's response

Each item received can be given one of the simple statuses:

• received - the file or value has arrived but has not yet been assessed,
• under review - the scope, recency or authenticity is being assessed,
• accepted as a source - the material may support the indicated part of the documentation,
• inadequate - it does not concern the correct product, risk or version,
• requires completion - a specific piece of information is missing,
• withdrawn - a newer version has replaced the earlier one.

'Received' should not mean 'approved'. This distinction protects against a situation in which any attachment automatically closes the task.

How to describe a gap

Instead of entering a general 'missing documents', name the gap precisely:

• no link between the report and model X100,
• no electronic manufacturer details,
• no Polish version of the instructions,
• the risk analysis does not cover use by children,
• unconfirmed material change after the test date,
• no information on the label version.

Each gap should have an owner, a deadline, a contact history and a decision on whether it blocks the next stage. This means the team knows exactly what to complete, and the follow-up to the supplier is specific.

Proposed cadence for cooperation with the supplier

• Send a structured request with the product scope and deadline.
• Record the date of sending and the contact person.
• When the response is received, register the files without automatic acceptance.
• Assess the scope of each piece of evidence and assign it to the SKU.
• Send a list of specific gaps.
• Save subsequent versions of the response instead of overwriting previous ones.
• Pass the complete set to the responsible person for approval.
• Establish which product changes the supplier must report before the next delivery.

What should trigger a renewed request

The supplier's documentation requires review after a change to the product, material, component, place of production, label, instructions or standard applied. A further check may also be needed after a safety complaint, accident, authority communication or change of market of sale.

Do not set one expiry date for all documents without due consideration. Some evidence loses its adequacy because of a product change, even if the file itself has no formal expiry date.

Checklist before approving material from the supplier

• Are the manufacturer and product data complete and consistent with the sample?
• Is it clear which SKUs and batches each document concerns?
• Does the risk analysis correspond to the actual use?
• Do the reports cover the correct model and the hazards considered?
• Do the instructions and warnings arise from the analysis?
• Are the language versions understandable in the market of sale?
• Are the data for the online offer consistent with the product and packaging?
• Have changes after the date of the documents been disclosed?
• Are all deviations and gaps visible to the approver?

A platform can make it easier to send a request, assign material to a SKU, monitor deadlines and preserve revisions. However, it does not automatically assess product safety and does not turn a supplier's declaration into confirmation of compliance. The final decision must take into account the actual product and the full legal context.