GPSR guidelines of the Commission: what they are and how to use them
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
The European Commission published its GPSR guidelines in the Official Journal of 21 November 2025 (C/2025/6233). They are not binding. They contain a template for the technical documentation and checklists per role: manufacturers, importers, distributors and other operators. Regulation (EU) 2023/988 remains the binding text. The guidelines show how the Commission reads it.
Commission guidelines C/2025/6233; Art. 9 GPSR
What the guidelines are
Guidelines explain how the Commission understands the Regulation. They create no new law. Courts and authorities are not bound by them. They are still a practical point of reference, because they show the Commission’s interpretation.
What they contain, as far as we have verified
Our fact base confirms this content:
- Publication in the Official Journal on 21 November 2025 (C/2025/6233)
- A template for the technical documentation (Article 9 GPSR)
- Checklists, separate for each role in the supply chain
What we do not claim
We do not summarise further details here, for example on edge cases such as second-hand goods or old stock, as long as we have not checked them against the original text. A wrong summary does more harm than a missing one.
How to use the guidelines
Take the checklist for your role as your test list and the template as the frame for your documentation.
- Determine your role: manufacturer, importer, distributor or another operator.
- Go through the checklist for that role product by product.
- Set up the technical documentation along the template.
- Keep the technical documentation, with the risk analysis it contains. Article 9(3) GPSR names 10 years after the product has been placed on the market.
- Note when you checked and who did it.
Frequently asked questions
Are the guidelines binding?
No. They are not binding. Regulation (EU) 2023/988 itself is.
When were they published?
In the Official Journal of 21 November 2025, as C/2025/6233.
Is there a template for the technical documentation?
Yes. The guidelines contain a template for the technical documentation and checklists per role.
With ProofPass
The product safety module stores product data, safety information and evidence per product in one place. That is the basis for working through a checklist per product. You still write the technical documentation and the risk analysis yourself.
The terms and legal notices are in German, and the German version is binding.
Sources
As of 3 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.