How long keep CE technical documentation after sale?

How long keep CE technical documentation? For many CE rules, you must retain the technical documentation and EU Declaration of Conformity for ten years after the last unit of the product has been placed on the market. The exact period depends on the applicable sector legislation. You must also update the file when the product, components, software or conformity evidence changes.

Key takeaways

• CE technical documentation is often retained for ten years after the last unit of the relevant product has been placed on the market, subject to the applicable sector legislation.
• The manufacturer must be able to provide technical documentation and the EU Declaration of Conformity when a market-surveillance authority requests them.
• A CE-marked product change can require a revised risk assessment, additional testing and an updated EU Declaration of Conformity.
• A supplier or component change is not merely commercial: you must assess whether it affects characteristics covered by the conformity assessment.
• Version-controlled records should link every batch sold to the correct product version, tests, instructions and declaration.

How long keep CE technical documentation?

For many CE regulations, the manufacturer must keep the technical documentation and EU Declaration of Conformity for ten years after the last unit of the product concerned has been placed on the market. Always check the period set by the legislation that applies to your product category, because sector-specific rules can differ.

The reason is practical. A product can be inspected long after it was sold, and the authority must be able to reconstruct the conformity assessment for the particular unit under review, even where you have since replaced the model.

Decision No 768/2008/EC on a common framework for the marketing of products is the model used by many EU harmonisation laws. It commonly provides for ten-year retention of technical documentation and the EU Declaration of Conformity. The European Commission’s Blue Guide on the implementation of EU product rules also explains that documentation must remain available to authorities for the period required by the applicable legislation.

The starting date matters. It is not necessarily the manufacturing date of the first batch or the date you created the file. Where the legislation uses this wording, the period starts after the last unit of the relevant model is placed on the market. Keep reliable records of placing-on-the-market dates and batch references.

Example: a French brand stops selling a USB charger in 2026, but further units of the same model are placed on the market in 2027. If the applicable legislation requires ten years after the final placing on the market, the retention period is calculated from 2027, not from the first sale.

To identify CE legislation that may apply to electrical or radio products, use this practical guide to CE marking for manufacturers and sellers. If you have not yet mapped the obligations for your product and trade flows, an EU market-entry compliance assessment can organise the checks you need to make.

Which retention period applies to your product type?

The retention period depends on the EU act or acts that apply to the product. For radio equipment, low-voltage electrical equipment and electromagnetic compatibility, the relevant directives set out ten-year retention obligations for manufacturers.

One product can fall within more than one legal act. A Bluetooth speaker, for example, may be covered by the Radio Equipment Directive as well as other requirements depending on its features. You should not select one rule arbitrarily: the manufacturer’s technical documentation must demonstrate conformity with all applicable requirements.

Radio, electrical and electronic equipment

Directive 2014/53/EU on radio equipment (RED) requires the manufacturer to keep technical documentation and the EU Declaration of Conformity for ten years after the radio equipment has been placed on the market. Directive 2014/35/EU on low-voltage electrical equipment (LVD) and Directive 2014/30/EU on electromagnetic compatibility (EMC) follow the same approach for products within their respective scopes.

Do not assume that a single test report is enough. A report is one item of evidence among others. It must relate to the product actually sold, its configuration and the standards or methods used. For the expected evidence set, see the guide to CE technical documentation documents and evidence.

Toys and other sector-specific categories

For toys, Directive 2009/48/EC on the safety of toys also requires technical documentation that demonstrates conformity. Depending on the toy, you need to control warnings, the safety assessment and instructions. A toy is not simply a consumer item: its file must make the risks understandable in relation to age, foreseeable use and materials.

Cosmetics, food, medicines and certain chemical products are governed by other regimes and should not be handled as ordinary CE products. If you sell several product families, keep files and retention rules separate by product reference and legal regime.

EU Seller Kit — Use the EU market-entry compliance assessment when you need to identify the regulations to review before a first shipment or a new product range. It flags items to check; it does not replace the manufacturer’s conformity assessment.

What documents must you retain with the manufacturer’s technical documentation?

Your technical documentation must allow an authority to assess conformity without having to guess how the product was designed, made or supported by evidence. The exact content depends on the legislation, but it must remain consistent with the product placed on the market and its EU Declaration of Conformity.

In practice, centralise at least the following documents, separating the versions applicable to each product reference and variant:

• product description, references, variants, photographs and technical characteristics;
• drawings, diagrams, bills of materials and specifications for relevant components;
• the risk assessment and measures taken to reduce identified risks;
• the list of legal requirements and harmonised standards or other technical specifications used;
• test reports, calculations, certificates and assessments supporting conformity;
• instructions, warnings, labels and traceability information actually supplied with the product;
• the EU Declaration of Conformity: content, signature and documents to prepare;
• production records and controls that help demonstrate that manufactured units remain consistent with the assessed model.

The EU Declaration of Conformity is the signed document through which the manufacturer accepts responsibility for conformity. It does not replace the technical documentation. Equally, a detailed technical file without a properly drawn-up declaration can create problems during an inspection or when a marketplace listing is blocked.

Imagine a US manufacturer selling a connected lamp under its own brand in France. It holds a 2023 test report, but the product shipped in 2026 contains a new radio board and new firmware. The 2023 report does not, by itself, establish conformity of the 2026 version. The manufacturer must assess the impact of the changes and retain the corresponding evidence.

For products made outside the EU, also verify the identity of the actual manufacturer, the consistency of product references and the documents supplied by the factory. This guide on CE marking for products made in China explains the checks to make before import.

When must you update CE technical documentation after sale?

You must review the file when the product or the evidence demonstrating its conformity changes. Updating CE technical documentation does not always mean rebuilding the entire file, but it does require a documented assessment of the change’s impact.

The European Commission’s Blue Guide makes clear that the manufacturer remains responsible for the conformity of products it places on the market, including where production changes. CE marking does not freeze a product in time.

Changes that should trigger a review

Start a formal review where there is:

• replacement of a critical component, battery, mains adaptor, antenna or material;
• a change of factory, subcontractor or manufacturing process that could affect product characteristics;
• a software or firmware update that changes a safety function, radio emission, power level, interface or intended use;
• a new variant, accessory or intended use;
• changes to labelling, warnings, instructions or traceability information;
• a new harmonised standard, regulatory development or safety information that reveals a gap in the original assessment;
• an incident, recurring complaint, recall or authority request.

The review should answer one practical question: does the existing evidence still cover the product as sold? If the answer is uncertain, document the gap, obtain further technical information and decide whether further testing or a new assessment is needed.

A common mistake is treating a supplier change as purely commercial. Two components with the same description can differ in composition, tolerance, embedded software or performance. Before placing a new order, use Supplier Check to centralise supplier identity, payment and delivery information and identify inconsistencies that need review. It does not validate CE conformity: the technical documents and evidence still need assessment.

How do you manage a component, supplier or software change?

Every change should lead to a traceable conformity decision. You should be able to show what changed, who assessed the impact, which evidence was reviewed and which product version was cleared for sale.

A five-step practical process

1. Open a change record. Record the product reference, affected batches, old and new versions, date and reason for the change.
2. Compare relevant characteristics. Review specifications, bills of materials, materials, electrical parameters, radio functions, software and warnings. Do not rely only on the supplier invoice.
3. Assess the regulatory impact. Check essential requirements, the risk assessment, standards applied and test reports. An antenna change on a connected product, for example, may need particular attention under the RED.
4. Decide and justify the action. Depending on the outcome, retain a no-impact note, obtain further tests, update the risk assessment, instructions and EU Declaration of Conformity, or stop placing the product on the market until the position is clear.
5. Archive the marketed version. Link batch numbers to the versions of the file, labels, instructions and declaration. This link is crucial if an authority asks about a specific product years later.

Where your product requires a notified body, check that its role, scope and certificates match the product and applicable procedure. Read when a notified body is required for CE marking.

Treat software changes with the same discipline as hardware changes. A remote update that alters how a product behaves can affect its conformity assessment. Retain the version number, release date, functions changed, tests completed and the affected products or batches.

Who must provide the file to market-surveillance authorities?

The manufacturer is primarily responsible for technical documentation and the EU Declaration of Conformity. Depending on the applicable legislation and supply chain, the importer, distributor and authorised representative may also have duties to cooperate, retain information or provide it.

Regulation (EU) 2019/1020 on market surveillance and compliance of products strengthens the framework for checks on products made available in the Union. A request may follow an inspection at a warehouse, border, marketplace or a report of concern. If documents are not accessible, the competent authority may require corrective action, suspend marketing or require withdrawal, depending on the circumstances and its powers.

Non-EU manufacturers: understand the authorised representative’s role

If the manufacturer is established outside the EU, some CE legislation requires or permits the appointment of an authorised representative established in the European Union. The written mandate must define the tasks assigned. A CE authorised representative can perform tasks permitted by the applicable legislation only after acceptance, entity assignment, a signed mandate and active payment.

This does not transfer the manufacturer’s core responsibility. A CE authorised representative does not replace the manufacturer’s conformity assessment, testing, technical documentation or EU Declaration of Conformity. Review the role and limits of a CE authorised representative for non-EU manufacturers before setting up that relationship.

Do not confuse this role with the responsible person under Regulation (EU) 2023/988 on general product safety (GPSR). The GPSR concerns consumer-product safety and economic operators; it does not remove the need to meet sector-specific CE obligations.

EU Seller Kit — The CE authorised representative service is for a non-EU manufacturer that needs a written mandate where the applicable CE legislation allows it. It becomes active only once the contractual and operational steps are complete; it does not create your technical documentation for you.

How should you archive and version-control technical documentation?

An accessible, version-controlled file shortens your response time during an inspection and reduces the risk of supplying documents that do not match the product being checked. The goal is not simply to store PDFs. You need a chain of evidence between the product reference sold, the batch, the technical version and the signed declaration.

Create a folder structure by product family, then by product reference and version. Give each document a stable identifier, such as DOC-RED-042-v3. Keep superseded versions read-only and record their validity period. Do not overwrite an earlier report or declaration: it may be the evidence that applies to units already placed on the market.

If you sell online, also check that the compliance information displayed matches the version actually dispatched. A pre-publication review with the Marketplace Product Compliance Scanner can flag traceability, safety and compliance information to verify before publication. It analyses a product listing; it does not replace conformity assessment or testing.

Documentation management checklist for manufacturers and importers

• Identify each applicable CE law and confirm its required retention period.
• Retain the signed EU Declaration of Conformity with the corresponding technical documentation.
• Link every reference, variant and batch to a version of the bill of materials, instructions, label and test evidence.
• Create a change record for components, suppliers, software and manufacturing processes.
• Revisit the risk assessment after an incident, significant complaint or product change.
• Confirm that test reports cover the configuration actually placed on the market.
• Decide who responds to authorities, in which language and where the documents are held.
• Keep historic versions for the applicable period, even after a model is discontinued.

Tools and services to take action

• EU Market Entry Compliance Assessment — Use it before a first shipment or new product range to organise CE, GPSR, customs, VAT and environmental checks that may apply.
• Supplier Check — Use it before an order or factory change to centralise supplier information and identify inconsistencies requiring investigation.
• CE Authorised Representative — Use this service if you are a non-EU manufacturer and a written mandate is appropriate under the relevant CE legislation; it does not replace your testing or technical file.
• Marketplace Product Compliance Scanner — Use it before publishing or restoring a listing to identify compliance and traceability information that needs checking.

Frequently asked questions

Must the EU Declaration of Conformity be kept separately from the technical documentation?

You may archive it in the same document system, but it should remain identifiable, signed and linked to the correct product version. The EU Declaration of Conformity is separate from the technical documentation: it records the manufacturer’s responsibility, while the file contains the evidence supporting that declaration.

Does an importer need a full copy of the technical documentation?

This depends on the applicable legislation and the allocation of roles in your supply chain. Importers must, among other things, verify that the manufacturer has completed the relevant procedures and cooperate with authorities. In practice, arrange rapid access to the necessary documents rather than discovering they are missing during an inspection.

Do all tests need to be repeated after a supplier change?

Not automatically. First determine, using evidence, whether the change affects characteristics covered by the conformity assessment. Where materials, components, performance or processes differ in a relevant way, additional testing or a new assessment may be necessary.

Does a new product colour require an update to the CE file?

A purely cosmetic colour change may have limited impact, but that is not an automatic conclusion. The pigment, coating or finishing process can affect safety properties, fire resistance, composition or labelling. Document the assessment before deciding that there is no impact.

Can you provide documents only in English to a French authority?

Language requirements depend on the applicable legislation and the request from the competent authority. Plan for this early: identify documents that may need to be supplied in French or another language accepted by the authority in the country concerned, then make them available accordingly.

Is the CE mark enough to prove that a product is compliant?

No. The CE mark is the visible expression of conformity declared by the manufacturer under applicable rules; it must be supported by a conformity-assessment procedure, technical documentation and an EU Declaration of Conformity. The official Your Europe guidance on CE marking confirms that CE marking applies only to products covered by specific EU rules.

Official sources

• Decision No 768/2008/EC — common framework for the marketing of products — sets out the reference framework for obligations frequently reproduced in EU harmonisation legislation.
• Commission Notice — The Blue Guide on the implementation of EU product rules (2022) — explains the practical application of EU rules on placing products on the market, documentation and surveillance.
• Directive 2014/53/EU — radio equipment — covers manufacturer obligations for radio equipment, including document retention.
• Directive 2014/35/EU — low voltage electrical equipment — covers requirements for certain low-voltage electrical equipment.
• Directive 2014/30/EU — electromagnetic compatibility — covers obligations relating to the electromagnetic compatibility of equipment.
• Regulation (EU) 2019/1020 — market surveillance and compliance of products — sets the framework for product surveillance and cooperation with authorities.
• Directive 2009/48/EC — safety of toys — sets out the safety and documentation framework for toys.
• Regulation (EU) 2023/988 — General Product Safety Regulation — covers general consumer-product safety and economic-operator obligations.

This content provides general information and is not legal advice.