GPSR Article 9 · Annex II

Risk assessment and technical documentation under the GPSR

Before a consumer product is sold in the EU, its manufacturer must carry out an internal risk analysis and draw up technical documentation. ohdock turns that into a guided form and a printable file for each product.

What the GPSR asks for

Regulation (EU) 2023/988 (GPSR)

How it works in ohdock

  1. Create a record for the product, with its label details and the countries you sell to.
  2. Answer the questions: description, users, hazards suggested for the product type, measures, standards and tests.
  3. Print the risk assessment and technical file or save it as PDF. Each saved version is kept in your account.

Hazards

Risk levels use a simple severity × likelihood matrix to set priorities. It is not the official Safety Gate method.

Sample file

This is what the file looks like for an example product. Your own file uses your answers. The file is in English, which market surveillance authorities widely accept. Keep a translation if an authority asks for one.

Risk assessment and technical documentation — Wooden stacking toy (sample)

ProductWooden stacking toy (sample)
Type or modelWS-10
Batch or serial numberB2410
SKU or EANSAMPLE-001
ManufacturerExample Toys Co., Ltd., No. 1 Example Road, Ningbo, China, safety@example.com
EU responsible personExample EU Rep GmbH, Musterstraße 1, 10115 Berlin, Germany, gpsr@example.eu
MarketsGermany, France, Netherlands
DocumentVersion 1, saved 2026-10-01
Assessed byJane Example, Product Manager
Date of assessment2026-10-01
Next review2027-10-01

1. General description of the product GPSR Art. 9(2); Annex II

DescriptionStacking toy of seven painted beech-wood rings on a wooden base, for children from 3 years. Base 12 cm, rings 4–9 cm. Sold in a cardboard box.
Essential characteristics (materials, components, power source, packaging)Solid beech wood; water-based paint; no batteries or electrical parts; cardboard packaging with no plastic film.
Intended usePlay by children from 3 years, stacking rings on the pole.
Reasonably foreseeable misuseUse by children under 3; mouthing and chewing the rings; throwing rings.

2. Who uses the product GPSR Art. 6(1)

ConsumersChildren from 3 to 14 years, Children under 36 months

3. Risk analysis and measures taken GPSR Art. 9(2); Annex II

HazardHow someone could be harmedSeverityLikelihoodRiskMeasures takenResidual risk
Small parts — choking, swallowing or inhalationA ring or a piece of broken pole could be swallowed by a younger sibling.4 — very serious or fatalPossibleHighSmallest ring is larger than the small parts cylinder; drop and torque tests passed; age warning “Not suitable for children under 36 months” on the box and the listing.Unlikely · Medium
Harmful substances — skin contact, mouthing or inhalationPaint could come off when the toy is mouthed.3 — seriousPossibleHighPaint tested for migration of certain elements; supplier declaration for the paint kept on file.Unlikely · Medium
Sharp edges and points — cuts and puncturesSplinters or sharp edges after the toy is dropped.2 — moderateUnlikelyLowAll edges rounded and sanded; visual check of every batch.Unlikely · Low

Risk = severity × likelihood on a simple matrix used to set priorities. It is not the official Safety Gate risk assessment method. Residual risk is the likelihood after the measures taken.

4. Standards and other references applied GPSR Art. 7–8; Annex II

EN 71-1 (mechanical and physical properties), EN 71-2 (flammability), EN 71-3 (migration of certain elements).

5. Tests and reports GPSR Annex II

Test report no. EX-2026-0001 from Example Testing Laboratory, dated 2026-09-15.

6. Instructions, warnings and safety information GPSR Art. 9(7)

Warnings on the labelWarning: Not suitable for children under 36 months. Small parts. Choking hazard.
Own warning text—
Label languagesDE, FR, NL
Instructions and other safety informationAge warning and instructions in German, French and Dutch on the box; keep the box for the manufacturer’s address.

7. Identification and contact details GPSR Art. 9(5), 9(6), 16

Identifier on the productWS-10 · B2410
ManufacturerExample Toys Co., Ltd., No. 1 Example Road, Ningbo, China, safety@example.com
EU responsible personExample EU Rep GmbH, Musterstraße 1, 10115 Berlin, Germany, gpsr@example.eu
Importer—

8. Complaints, accidents and corrective action GPSR Art. 9(8), 20

Customers can report problems at safety@example.com or through the marketplace. Complaints are reviewed weekly; serious incidents are reported through the Safety Business Gateway and the product recalled if needed.

9. Keeping this documentation GPSR Art. 9(2)–(3)

Keep this documentation for 10 years after the product is placed on the market and make it available to market surveillance authorities on request.

Update it when the product, its components, its users or the applicable rules change, and after any accident or complaint about safety.

Prepared with ohdock (ohdock.com) from the information entered by the manufacturer or seller.

This document records your own assessment. It is not legal advice, a test report or a certificate, and it does not show that the product complies with EU law. Check Regulation (EU) 2023/988 and any product-specific legislation, or ask a qualified adviser or testing laboratory.

Price

€19 per product, one-off — or included in EU Pro (€12 per month) for all your products.

For one product: the risk assessment and technical file, its GPSR label and listing text, kept in your account.

The listing check and the label generator stay free.

This records your own assessment. It is not legal advice, a test report or a certificate, and it does not show that the product complies. ohdock provides software tools and general information, not legal advice. Check the official texts, or ask a qualified adviser, for your situation.