--- title: "We onboard a new supplier and want the documents first" description: "Before the first order, decide which documents each product type needs under EU law, check who the real manufacturer is, and agree that you receive the technical documentation and a reference sample. An importer keeps a copy of the file and names its suppliers on request (GPSR Articles 11(6) and 15). From 14 December 2027, products made with forced labour may not be placed on the EU market." type: "problem" url: "https://www.conphora.com/solutions/problem/new-supplier-onboarding/" markdown: "https://www.conphora.com/solutions/problem/new-supplier-onboarding.md" locale: "en" language: "en" updated: "2026-10-05" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529" tags: ["GPSR", "suppliers-imports"] license: "Free to quote with attribution and a link to the page" --- # We onboard a new supplier and want the documents first Before the first order, decide which documents each product type needs under EU law, check who the real manufacturer is, and agree that you receive the technical documentation and a reference sample. An importer keeps a copy of the file and names its suppliers on request (GPSR Articles 11(6) and 15). From 14 December 2027, products made with forced labour may not be placed on the EU market. ## Why this happens Onboarding is the cheapest moment to settle compliance, because the duties start before the first unit is sold. Under the General Product Safety Regulation (EU) 2023/988, the importer must ensure before placing a product on the market that it meets the general safety requirement and that the manufacturer has drawn up the internal risk analysis and technical documentation, marked the product with an identifier and given its name and addresses (Article 11(1)). The importer keeps a copy of that documentation for 10 years after placing the product (Article 11(6)). [1] The supplier's identity matters in two directions. The manufacturer's name, registered trade name or trade mark and postal and electronic address go on the product (Article 9(6)). And on request, every economic operator must identify who supplied it with the product, or with a part, component or software embedded in it, and must be able to present that information for six years after being supplied (Article 15(3) and (5)). The Commission's Blue Guide adds that an importer needs no mandate from the manufacturer, but must make sure that contact with the manufacturer can be established, for example to make the technical documentation available to an authority. It calls it good practice for importers to refer to the applicable EU legislation in the contract with the supplier and to secure access to the technical file, or the manufacturer's signed obligation to provide it (footnote 139). [1] [4] For products under Union harmonisation legislation, the sector act sets the documents. For the acts listed in Article 4(5) of Regulation (EU) 2019/1020, such as the Low Voltage Directive, the economic operator responsible in the Union also verifies that the EU declaration of conformity and the technical documentation have been drawn up and that the documentation can be made available on request (Regulation (EU) 2019/1020, Article 4(3)(a)). Customs suspend the release of products that arrive without the documentation their Union law requires (Article 26(1)(a)). [2] A newer question concerns how products are made. Regulation (EU) 2024/3015 prohibits economic operators from placing or making available on the Union market, or exporting, products made with forced labour (Article 3), defined as products for which forced labour was used in whole or in part at any stage of extraction, harvest, production or manufacture (Article 2(7)). The regulation applies from 14 December 2027 (Article 39) and states that it creates no additional due diligence obligations beyond those in Union or national law (Article 1(3)). [3] ## How to solve it 1. **Decide the document set per product type before you ask** A request for 'all certificates' gets you whatever the supplier has. Work out what the law needs for each product type first: for a GPSR product the risk analysis and technical documentation, for a CE product also the EU declaration of conformity and any notified-body certificate. Send the supplier that list, product by product. 2. **Verify who the supplier is** Find out whether you are dealing with the factory or a trading company, and record the legal entity, its address and the production site. The manufacturer's name and addresses will be on the product, and on request you must be able to name who supplied you, and who supplied parts or components, for years after delivery. 3. **Agree access to the technical documentation** As importer of a GPSR product you keep a copy of the technical documentation for 10 years (under the CE acts, the declaration, with the file available on request), and you must be able to reach the manufacturer when an authority asks. Make delivery of the file, and updates to it, a condition of the first order rather than a promise for later. 4. **Approve a reference sample** Have the first production sample checked against the documentation and the label, and keep it, or detailed photos and measurements, as the reference for later deliveries. It is your baseline when a shipment looks different. 5. **Ask about forced labour in the supply chain** From 14 December 2027, economic operators may not place or make available products made with forced labour, at any stage of extraction, production or manufacture. The regulation adds no new due diligence duty of its own, but the questions belong in onboarding: where the materials come from and who works on them. 6. **Record the approval** Close the onboarding with a dated record per product: the documents received, the gaps still open with an owner and a date, the reference sample and the decision. That record is what you show a retailer or an authority later. ## What you need to show - **Supplier record: legal entity, address, production site and the manufacturer's identity** — The supplier (GPSR Articles 9(6) and 15(3)) - **Technical documentation per product, with the risk analysis** — The manufacturer, with a copy kept by you (GPSR Articles 9(2) and 11(6)) - **EU declaration of conformity and any notified-body certificate, for CE products** — The manufacturer (Regulation (EU) 2019/1020, Article 4(3)(a), for the acts listed in Article 4(5)) - **Reference sample record and the onboarding decision** — Your quality files (GPSR Article 14) ## If you do nothing - **The first shipment arrives without a file** — Before placing a product on the market, the importer must ensure that the manufacturer has drawn up the technical documentation (GPSR Article 11(1)); without it, the goods cannot be sold, and customs may suspend their release where required documentation is missing (Regulation (EU) 2019/1020, Article 26(1)(a)). - **You cannot name your supplier when asked** — On request, economic operators identify who supplied them with the product or with a part, component or embedded software, and must be able to do so for six years (GPSR Article 15(3) and (5)). - **Products caught by the forced labour ban** — From 14 December 2027, economic operators may not place or make available on the Union market, or export, products made with forced labour (Regulation (EU) 2024/3015, Articles 3 and 39). ## Questions ### Which documents should we ask a new supplier for? Those the law requires for the product type. For a GPSR product: the risk analysis and technical documentation, including test outcomes where appropriate (Article 9(2)). For a CE product: the technical documentation, the EU declaration of conformity and any notified-body certificate the act requires. ### The supplier will only share documents after the order. Should we accept that? You can order, but you cannot place the goods on the market until you have ensured that the documentation exists (GPSR Article 11(1)). Make delivery of the file a condition of shipment or payment. ### Does the forced labour regulation apply already? It entered into force on 13 December 2024 and applies from 14 December 2027 (Regulation (EU) 2024/3015, Article 39). Eight articles on authorities and Commission tools applied from 13 December 2024, among them the database of forced labour risk areas or products (Article 8) and guidelines for economic operators (Article 11), both due by 14 June 2026. The prohibition itself is in Article 3. ### Is a factory audit enough? An audit shows how a factory works, not whether a specific product meets EU rules. The product evidence is the technical documentation and, for CE products, the declaration of conformity (GPSR Article 9(2); Regulation (EU) 2019/1020, Article 4(3)(a)). ## Regulations involved GPSR ## 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. [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 3. [Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market](https://eur-lex.europa.eu/eli/reg/2024/3015/oj) — 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