Technical Documentation
Technical documentation is the set of documents that a manufacturer must compile to demonstrate that a product complies with the applicable ESPR ecodesign requirements. It includes design drawings, test reports, the EU Declaration of Conformity, and the Digital Product Passport.
Full Definition
Technical documentation under ESPR is defined in Article 29 and Annex VI. It is the core evidence base 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.
The minimum contents of the technical documentation are specified in ESPR Annex VI, Section 1: a general description of the product and its intended use; design and manufacturing drawings; a list of harmonised standards applied; results of design calculations and examinations; test reports; a copy of the EU Declaration of Conformity; and a copy of the Digital Product Passport. The technical documentation must be sufficient to allow a market surveillance authority to assess the product's compliance without conducting its own tests.
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, but the EU Declaration of Conformity must be available in the language of the member state where the product is sold.
Related Terms
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Register Your Digital Product Passport →Technical Documentation Under ESPR: Content Requirements
Article 15 of ESPR specifies that the technical documentation must contain sufficient information to demonstrate that the product meets the applicable ecodesign requirements. The minimum content requirements are: a general description of the product, design and manufacturing drawings, a list of harmonised standards and common specifications applied, the results of ecodesign calculations, test reports, a copy of the EU Declaration of Conformity, and where applicable, the notified body's assessment report. For products with a DPP, the technical documentation must also include a description of the DPP system. The technical documentation must be prepared before the CE marking is affixed and must be kept available for at least 10 years after the last product is placed on the market.
Technical Documentation vs Product Information Sheet
The technical documentation and the product information sheet (PIS) are two distinct documents under ESPR. The technical documentation is a comprehensive internal document that supports the conformity assessment — it contains detailed technical data, test reports, and calculations that demonstrate compliance with ESPR requirements. The product information sheet is a shorter, consumer-facing document that provides key product information in a standardised format. The PIS is typically provided with the product or available on the manufacturer's website. The DPP incorporates and extends the PIS — the DPP contains all the information in the PIS plus additional data on the product's environmental performance and end-of-life treatment.
Technical documentation must be prepared before the product is placed on the market and must be kept available for at least 10 years after the last product of the model is placed on the market. The documentation must be in a language that is accepted by the market surveillance authorities of the EU member states where the product is sold — in practice, this means English is acceptable for most EU member states, but some member states (notably France) may require documentation in their national language. Technical documentation must be made available to market surveillance authorities within 10 days of a request. Failure to provide technical documentation on request is itself a non-compliance that can result in market surveillance action, regardless of whether the product itself meets the applicable requirements.