Technical Documentation Under ESPR
ESPR Article 29 requires manufacturers to compile technical documentation that demonstrates a product's compliance with the applicable ecodesign requirements. The technical documentation must be compiled before the product is placed on the EU market and must be retained for at least 10 years after the last product of that model is placed on the market. Market surveillance authorities have the right to request the technical documentation at any time.
Technical documentation is distinct from the Digital Product Passport. The DPP is a public-facing data record accessible via a QR code. The technical documentation is a private compliance record that is not publicly accessible but must be provided to market surveillance authorities on request. The DPP links to the technical documentation (via a restricted-access URL) but does not replace it.
Required Contents of Technical Documentation
| Document | Description | Required By |
|---|---|---|
| General product description | Description of the product, its intended use, and the product category | Annex VI, Section 1(a) |
| Design and manufacturing drawings | Technical drawings showing product dimensions, components, and materials | Annex VI, Section 1(b) |
| List of harmonised standards | List of harmonised standards applied, with publication references | Annex VI, Section 1(c) |
| Design calculations | Results of design calculations demonstrating compliance | Annex VI, Section 1(d) |
| Test reports | Reports of tests conducted to verify compliance with ecodesign requirements | Annex VI, Section 1(e) |
| EU Declaration of Conformity | Copy of the signed EU Declaration of Conformity | Annex VI, Section 1(f) |
| Digital Product Passport | Copy of the DPP data record or link to the registered DPP | Annex VI, Section 1(g) |
| Substance of concern data | Data on substances of concern present in the product | ESPR Annex III |
| Supply chain data | Evidence of supply chain due diligence for critical raw materials | Applicable delegated act |
Language Requirements
Technical documentation must be available in a language acceptable to the market surveillance authority of the EU member state where the product is placed on the market. In practice, English is widely accepted for B2B products. The EU Declaration of Conformity must be available in the official language(s) of the member state where the product is sold. Manufacturers placing products in multiple EU member states must maintain translations of the EU Declaration of Conformity in all relevant languages.
Retention Requirements
ESPR Article 29(2) requires technical documentation to be retained for at least 10 years after the last product of that model is placed on the EU market. This is a minimum — delegated acts for specific product categories may require longer retention periods. For products with long expected lifetimes (construction materials, industrial equipment), the retention period may effectively be the product's entire lifetime plus 10 years.
Electronic vs Physical Documentation
Technical documentation may be maintained in electronic form. There is no requirement to maintain physical paper copies. However, the documentation must be accessible on request from market surveillance authorities — which means it must be stored in a format that can be retrieved and transmitted quickly. Cloud-based document management systems are acceptable provided they meet the availability and security requirements.
Technical Documentation Under ESPR: What Must Be Included
Article 15 of ESPR specifies the content requirements for technical documentation. The documentation must contain sufficient information to demonstrate that the product meets the applicable ecodesign requirements and to enable market surveillance authorities to assess compliance. The required content includes: a general description of the product including its intended use, the product's design and manufacturing drawings and schemes, a list of the harmonised standards and/or common specifications applied, the results of the ecodesign calculations performed (energy efficiency, material efficiency, carbon footprint, etc.), test reports from accredited laboratories or internal test facilities, a copy of the EU Declaration of Conformity, and where applicable, the notified body's assessment report and certificate. For products with a Digital Product Passport, the technical documentation must also include a description of the DPP system, including the data carrier specification, the resolver URL, and the data fields included in the DPP.
Technical Documentation Retention Requirements
Manufacturers must retain the technical documentation for at least 10 years after the last unit of the product is placed on the EU market. This retention requirement applies to the manufacturer and, where applicable, to the EU Authorised Representative. For products with long production runs, this means the technical documentation may need to be retained for 15–20 years or more. Manufacturers should implement a document management system that ensures the technical documentation is stored securely, is accessible to authorised personnel, and can be retrieved and provided to market surveillance authorities within a reasonable timeframe (typically 10 working days, as specified in the market surveillance regulation EU 2019/1020). The technical documentation may be stored in digital format, but the storage medium must be durable and the documents must be readable without proprietary software.
Updating Technical Documentation After Product Modifications
If a product is modified after the CE marking has been affixed — for example, if a software update changes the product's energy consumption, or if a component is substituted — the manufacturer must assess whether the modification affects the product's conformity with the ESPR requirements. If the modification does affect conformity, the technical documentation must be updated, a new conformity assessment must be performed, and a new EU Declaration of Conformity must be drawn up. If the modification does not affect conformity, the technical documentation should be updated to record the modification and the assessment that it does not affect conformity. Manufacturers should establish a formal product change management process that includes a conformity impact assessment step to ensure that modifications do not inadvertently create non-compliance.
Technical Documentation for Multi-Variant Products
Many manufacturers produce products in multiple variants — different colours, sizes, configurations, or regional versions. The ESPR technical documentation requirements apply to each product variant separately, as each variant may have different ecodesign characteristics. However, manufacturers can use a single technical documentation package for a product family if the variants share the same ecodesign characteristics — for example, if all colour variants of a product have the same energy consumption, material composition, and repairability score, a single technical documentation package covering all colour variants is acceptable. The EU Declaration of Conformity must list all variants covered by the technical documentation. Manufacturers should document their approach to technical documentation for multi-variant products and ensure that the approach is consistent with the requirements of the delegated act for their product category.
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Register Your Digital Product Passport →Technical Documentation Requirements Under ESPR
ESPR requires manufacturers to maintain technical documentation that demonstrates that their products meet all applicable requirements. The technical documentation is the evidence base that supports the EU Declaration of Conformity — it is the collection of documents, test reports, calculations, and records that prove the product is compliant. Market surveillance authorities can request the technical documentation at any time, and manufacturers must be able to provide it within a reasonable timeframe (typically 10 days).
The technical documentation required under ESPR includes: a general description of the product (including the product model, the intended use, and the key technical characteristics); the design and manufacturing drawings and specifications; a list of the harmonised standards applied (and, where harmonised standards were not applied, a description of the solutions adopted to meet the requirements); the results of design calculations and examinations; test reports (either from the manufacturer's own laboratory or from an accredited external laboratory); a copy of the EU Declaration of Conformity; and a description of the quality management system used to ensure ongoing compliance during production.
The technical documentation must be kept available for inspection by market surveillance authorities for a minimum of 10 years after the last unit is placed on the market. For products with a long expected lifespan (such as buildings and industrial equipment), the retention period may be longer. The technical documentation must be kept in a form that allows it to be provided to market surveillance authorities without delay — it is not acceptable to keep the documentation in a format that requires significant effort to retrieve and compile.
Frequently Asked Questions
The technical documentation must be in a language that is acceptable to the market surveillance authority of the member state where the product is placed on the market. In practice, English is widely accepted, but some member states may require documentation in their national language. Manufacturers should check the language requirements of each member state where they sell their products.
Yes. The technical documentation can be stored electronically, provided that it is accessible and can be provided to market surveillance authorities without delay. Electronic storage is the standard practice for most manufacturers. The documentation must be backed up and protected against loss or corruption.
The technical documentation must include test reports that demonstrate compliance with all applicable ESPR requirements. The test reports must be from accredited laboratories (ISO/IEC 17025 accreditation) or, for internal production control, from the manufacturer's own laboratory. The test reports must identify the test methods used, the test conditions, and the test results.
The DPP contains a subset of the technical documentation — the product data that is required to be publicly accessible under ESPR. The full technical documentation (including test reports and design drawings) is not publicly accessible but must be available to market surveillance authorities on request. The DPP may include a reference to the technical documentation and a contact point for requesting it.
If a manufacturer ceases to exist before the end of the technical documentation retention period, the obligation to maintain the documentation passes to the manufacturer's legal successor (if any). If there is no legal successor, the documentation should be transferred to the relevant national authority. The ESPR implementing regulations are expected to address this scenario in more detail.