{
  "type": "problem",
  "slug": "keep-documents-how-long",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/keep-documents-how-long/",
  "markdown": "https://www.conphora.com/solutions/problem/keep-documents-how-long.md",
  "title": "How long must we keep compliance documents?",
  "description": "Retention in EU product law: 10 years for the technical file and declaration; GPSR: six years for traceability data, a five-year cap on complaint data.",
  "answer": "Most EU product acts require the manufacturer to keep the technical documentation and the declaration of conformity for 10 years after the product has been placed on the market; importers and authorised representatives keep copies for the same period. For products under the GPSR alone, it adds six years for traceability data and caps personal data in complaint registers at five years. Set retention per document type.",
  "theme": {
    "id": "documentation",
    "label": "Documentation and declarations"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "GPSR",
    "LVD",
    "RED",
    "TSD",
    "PPE"
  ],
  "path": [
    "regulation-library"
  ],
  "trigger": "Someone wants to clear out old files, or a retailer contract asks how long you keep compliance records",
  "keep": "Technical documentation and the EU declaration of conformity: 10 years after the product has been placed on the market (Directive 2014/35/EU Article 6(3); Directive 2014/53/EU Article 10(4); Directive 2009/48/EC Article 4(3); Regulation (EU) 2016/425 Article 8(3); GPSR Article 9(3)). GPSR traceability information: six years (Article 15(5)). Personal data in the complaints register: no longer than five years after entry (GPSR Articles 9(13) and 11(11))",
  "why": [
    {
      "text": "The common framework for product law does not fix one retention period. Article R2(3) in Annex I to Decision No 768/2008/EC leaves the period to each act, \"to be specified in proportion to the lifecycle of the product and the level of risk\", counted from when the product has been placed on the market. Article 4(5)(b) lets an act alter the periods set in the conformity assessment modules. In practice the main acts chose 10 years.",
      "sources": [
        3
      ]
    },
    {
      "text": "The Low Voltage Directive 2014/35/EU requires the manufacturer to keep the technical documentation and the EU declaration of conformity for 10 years after the electrical equipment has been placed on the market (Article 6(3)). An authorised representative's mandate must allow it to keep both at the disposal of authorities for the same 10 years (Article 7(2)(a)). Importers keep a copy of the declaration for 10 years and ensure the technical documentation can be made available on request (Article 8(8)). Economic operators must be able to identify who supplied them and whom they supplied for 10 years (Article 11). The PPE Regulation (EU) 2016/425 sets the same 10 years for the manufacturer (Article 8(3)), who also keeps the EU type-examination certificate with the technical documentation for 10 years (Annex V point 9). So do the Radio Equipment Directive 2014/53/EU (Article 10(4)) and the toy directive 2009/48/EC (Article 4(3)). From 1 August 2030 the Toy Safety Regulation (EU) 2025/2509 requires the technical documentation and the digital product passport to be kept for 10 years (Article 7(3)); its recital 50 counts that period until 10 years after the last item of the toy model was placed on the market. The Commission's Blue Guide reads the 10-year period in the same way for all products, for manufacturers and importers alike (footnotes 115 and 142). For products under the acts listed in its Article 4(5), Regulation (EU) 2019/1020 asks the EU-based operator to keep the declaration available \"for the period required by that legislation\" (Article 4(3)(a)).",
      "sources": [
        1,
        1,
        6,
        7,
        8,
        9,
        10,
        4
      ]
    },
    {
      "text": "The General Product Safety Regulation (EU) 2023/988 adds periods for products outside the CE acts. The manufacturer keeps the technical documentation for 10 years (Article 9(3)) and the importer keeps a copy for 10 years after placing the product on the market (Article 11(6)). Economic operators must be able to present the description of risks, complaints, accidents and corrective measures for 10 years (Article 15(4)), and the names of the operators who supplied them or whom they supplied for six years (Article 15(5)). Personal data in the complaints register has a ceiling: only as long as the investigation needs, and no longer than five years after entry (Articles 9(13) and 11(11)). Article 2(1), third subparagraph, point (b), says Chapter III Section 1, which contains Articles 9 to 18, does not apply to products subject to Union harmonisation legislation.",
      "sources": [
        2
      ]
    },
    {
      "text": "Newer acts add online retention. Under the Machinery Regulation (EU) 2023/1230, which applies from 20 January 2027 (Article 54), digital instructions must stay accessible online during the expected lifetime of the machinery and for at least 10 years after placing on the market, and a digital declaration of conformity likewise for at least 10 years (Article 10(7)(c) and (8)). Notified bodies keep their own records too: under the PPE Regulation, the notified body keeps a copy of the EU type-examination certificate and the technical file for five years after the certificate expires (Annex V point 8).",
      "sources": [
        5,
        6
      ]
    }
  ],
  "steps": [
    {
      "name": "List the document types you hold",
      "text": "Separate the technical documentation, the declaration of conformity, notified body certificates, the complaints register, supplier and customer records, and published instructions. Each has its own rule, and personal data has a ceiling as well as a floor."
    },
    {
      "name": "Find the period in each act that applies",
      "text": "Read the retention article of every act the product falls under. For CE products it is in the manufacturer's obligations, usually 10 years. For products only under the GPSR, add the six-year traceability period and the five-year cap on complaint data.",
      "item": "regulation-library"
    },
    {
      "name": "Decide when the clock starts",
      "text": "The acts count from when the product is placed on the market. A model sold over several years places new units each year, so record the date of the last unit placed on the market for each model and count from there. The Commission's Blue Guide reads the period that way."
    },
    {
      "name": "Write a retention schedule and apply it",
      "text": "Put the document type, the period, the start date and the legal source in one schedule. Block deletion of files still inside their period, and, for GPSR-only products, delete complaint personal data when the investigation no longer needs it and at the latest five years after entry."
    },
    {
      "name": "Make sure copies outlive people and suppliers",
      "text": "Importers and authorised representatives keep their own copies for the same period. If a supplier or a test lab stores your evidence, keep a copy yourself, because the duty stays with you."
    }
  ],
  "documents": [
    {
      "name": "A retention schedule: document type, period, start date, legal source",
      "from": "Your own compliance records",
      "ground": "Directive 2014/35/EU Article 6(3); GPSR Articles 9(13) and 15(4)–(5)"
    },
    {
      "name": "The archived technical documentation and declaration for each model, with the date of the last unit placed on the market",
      "from": "The manufacturer",
      "ground": "Directive 2014/35/EU Article 6(3); GPSR Article 9(3)"
    },
    {
      "name": "The importer's or authorised representative's copies",
      "from": "The importer or authorised representative",
      "ground": "Directive 2014/35/EU Articles 7(2)(a) and 8(8); GPSR Article 11(6)"
    }
  ],
  "risks": [
    {
      "title": "No file when the authority asks",
      "text": "Manufacturers keep the technical documentation and the declaration for 10 years and provide all information and documentation needed to demonstrate conformity on a reasoned request (Directive 2014/35/EU Article 6(3) and (9)).",
      "source": 1
    },
    {
      "title": "Keeping personal data too long is also a breach",
      "text": "For products under the GPSR alone, the complaints register may store only the personal data needed to investigate, kept only as long as necessary and in any event no longer than five years after the data have been entered (GPSR Articles 9(13) and 11(11)).",
      "source": 2
    },
    {
      "title": "Formal non-compliance can lead to withdrawal",
      "text": "Authorities can require operators to rectify formal non-compliance and ensure withdrawal, recall or a prohibition where the operator does not act (Regulation (EU) 2019/1020 Article 16(3)(a) and (5)).",
      "source": 4
    }
  ],
  "faq": [
    {
      "q": "Is it 10 years from when we made the product or from when we stopped selling it?",
      "a": "The acts say 10 years after the product has been placed on the market (Directive 2014/35/EU Article 6(3)). Each unit is placed on the market separately. The Commission's Blue Guide reads the period as running from the last item of the product model placed on the market, and recital 50 of the Toy Safety Regulation (EU) 2025/2509 says the same for toys."
    },
    {
      "q": "Does the importer have to keep the full technical file?",
      "a": "Under the low voltage directive the importer keeps a copy of the declaration for 10 years and ensures the technical documentation can be made available on request (Directive 2014/35/EU Article 8(8)). Under the GPSR the importer keeps a copy of the technical documentation for 10 years (Article 11(6))."
    },
    {
      "q": "Do the GPSR periods apply to CE-marked products?",
      "a": "No. The GPSR says Chapter III Section 1, which holds Articles 9 to 18, does not apply to products subject to Union harmonisation legislation (Article 2(1), third subparagraph, point (b)). The sector act applies instead, for example 10 years for supplier and customer identification under the low voltage directive (Directive 2014/35/EU Article 11). The GPSR five-year cap on complaint data does not apply either."
    },
    {
      "q": "How long must online instructions stay online?",
      "a": "Under the Machinery Regulation (EU) 2023/1230, which applies from 20 January 2027, digital instructions must be accessible online during the expected lifetime and for at least 10 years after placing on the market (Article 10(7)(c))."
    },
    {
      "q": "Can an act set a different period?",
      "a": "Yes. The common framework leaves the period to each act, in proportion to the product's lifecycle and level of risk (Decision No 768/2008/EC Annex I, Article R2(3)), and lets an act alter the periods in the modules (Article 4(5)(b))."
    }
  ],
  "sources": [
    {
      "title": "Directive 2014/35/EU on electrical equipment designed for use within certain voltage limits (consolidated text of 30 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Decision No 768/2008/EC on a common framework for the marketing of products",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008D0768",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2023/1230 on machinery (consolidated text of 27 July 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1230-20260727",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2016/425 on personal protective equipment (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R0425-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 2014/53/EU on radio equipment (consolidated text of 30 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0053-20260530",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 2009/48/EC on the safety of toys (consolidated text of 29 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009L0048-20260829",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2025/2509 on the safety of toys",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2509",
      "accessed": "2026-10-04"
    },
    {
      "title": "The 'Blue Guide' on the implementation of EU product rules 2022 (Commission Notice 2022/C 247/01)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "documents-scattered",
    "complaints-register",
    "authority-asks-technical-file",
    "no-technical-documentation",
    "instructions-online-only"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-05",
  "notice": "General information, not legal advice."
}