--- title: "We cannot keep track of documents from many suppliers" description: "With many suppliers, the problem is not storage but control: knowing which product lacks which document, from whom, and since when. The law expects up-to-date files kept for 10 years and each supplier identifiable for six years (GPSR Articles 9(3), 11(6) and 15(5)). Keep one register of suppliers and products, rank gaps by risk, chase them on a schedule and react to change triggers." type: "problem" url: "https://www.conphora.com/solutions/problem/many-suppliers-tracking/" markdown: "https://www.conphora.com/solutions/problem/many-suppliers-tracking.md" locale: "en" language: "en" updated: "2026-10-04" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529" tags: ["GPSR", "LVD", "suppliers-imports"] license: "Free to quote with attribution and a link to the page" --- # We cannot keep track of documents from many suppliers With many suppliers, the problem is not storage but control: knowing which product lacks which document, from whom, and since when. The law expects up-to-date files kept for 10 years and each supplier identifiable for six years (GPSR Articles 9(3), 11(6) and 15(5)). Keep one register of suppliers and products, rank gaps by risk, chase them on a schedule and react to change triggers. ## Why this happens An importer with many suppliers has the same duties per product as one with a single supplier; what changes is the effort of meeting them. Under the General Product Safety Regulation (EU) 2023/988, the importer must ensure before placing each product on the market that the manufacturer has drawn up the risk analysis and technical documentation (Article 11(1)) and keep a copy for 10 years after placing the product (Article 11(6)). The manufacturer must keep that documentation up to date (Article 9(3)). The Commission's Blue Guide reads the 10 years as running from the last item of the product model placed on the market (footnotes 115 and 142), so the retention period moves as long as new units are placed. [1] [4] Traceability adds a second register. Every economic operator must, on request, identify any operator that supplied it with the product or with a part, a component or embedded software, and any operator it supplied, and must be able to present that information for six years (GPSR Article 15(3) and (5)). For low voltage equipment, the Low Voltage Directive 2014/35/EU requires the same identification of suppliers and customers for 10 years (Article 11). [1] [2] Files do not stay current by themselves. The Low Voltage Directive requires manufacturers to take changes in product design or characteristics and in the harmonised standards adequately into account (Article 6(4)) and to keep the declaration of conformity continuously updated (Article 15(2)). When a supplier's product, standard or certificate changes, the importer's copy goes stale unless someone asks. [2] The GPSR does not prescribe a tool. It requires economic operators to have internal processes for product safety that allow them to comply (Article 14). Market surveillance authorities, for their part, can require documents and supply chain information in any form and wherever they are stored (Regulation (EU) 2019/1020, Article 14(4)(a) and (b)). A register of suppliers and products with status, owners and triggers is one way to meet both. [1] [3] ## How to solve it 1. **Build one register of suppliers and products** One row per product and supplier: the supplier's legal entity, the manufacturer, the product, the rules that apply, the documents those rules require, what you hold, the date received and the open gaps. Add the component suppliers where you know them, because authorities can ask for those too. 2. **Rank the gaps by risk** Not every gap is equally urgent. Put products for children and other vulnerable users, products with known Safety Gate hazards, and products under acts that require a notified body at the top. A missing risk analysis for a toy outranks a missing translation for a doormat. 3. **Send one standard request per supplier** Collect all open items for a supplier into one request with a clear list per product and a date, instead of many ad hoc emails. Log the request and the answer in the register, and escalate on a fixed schedule: reminder, purchasing manager, order hold. 4. **Set renewal triggers, not only dates** Documents go stale when something changes: a new edition of a harmonised standard, a change to the product or its components, an expired or withdrawn certificate, a new country of sale with a new language. Flag each trigger in the register so the right supplier is asked at the right time. 5. **Share the status with those who ask** Retailers, auditors and authorities ask the same questions. Give them a current status per product and the documents behind it, so you answer from the register rather than rebuilding the answer each time. ## What you need to show - **Supplier and product register with document status per product** — Your own records (GPSR Articles 14 and 15(3)) - **Copies of the technical documentation per product** — The manufacturers (GPSR Article 11(6); LVD Article 8(8)) - **Log of requests, answers and escalations** — Your purchasing and quality files (GPSR Article 14) ## If you do nothing - **Documents cannot be produced when the authority asks** — Authorities can require documents, technical specifications and information in any form or format and irrespective of where they are stored, and information on the supply chain (Regulation (EU) 2019/1020, Article 14(4)(a) and (b)). - **Out-of-date files** — Technical documentation must be kept up to date (GPSR Article 9(3)); for CE products, changes in design and in the harmonised standards must be taken into account (LVD Article 6(4)). A file received once and never reviewed may no longer describe the product. - **Missing supplier traceability** — Economic operators must, on request, identify who supplied them with the product or with a part or component, and be able to present that information for six years (GPSR Article 15(3) and (5)). ## Questions ### How is this different from organising our own files? Organising files deals with what you hold. This deals with what you still have to get, from whom, and when it goes out of date. Both end in one record per product; the register adds the supplier and the open requests. ### How often should we ask suppliers to confirm their documents? The law sets no interval. It requires the documentation to be kept up to date (GPSR Article 9(3)), and the responsible operator in the Union must, where appropriate to the risks, regularly check that the product matches the technical documentation (Article 16(2)), without a fixed frequency. A review driven by change triggers, such as new standards, product changes or new markets, follows the law more closely than a calendar date. ### Which suppliers do we have to be able to name? Those who supplied you with the product, or with a part, a component or software embedded in it, and those you supplied (GPSR Article 15(3)). Under the Low Voltage Directive the records cover the operators who supplied you and whom you supplied, for 10 years (Article 11). ### Do we need a separate system for this? The law asks for internal processes for product safety (GPSR Article 14), not a particular tool. A register that shows status per product and supplier, owners and dates is what matters. ## Regulations involved GPSR, LVD ## Sources 1. [Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529) — EUR-Lex, 2026-10-04 2. [Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530) — EUR-Lex, 2026-10-04 3. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-04 4. [The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)) — European Commission, via EUR-Lex, 2026-10-04